Contractor Safety a Growing Issue

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Summary Statement

A presentation on the necessity and benefits of having a comprehensive safety program and an introduction to the requirements of a program.


  • Why do contractors need to be prequalified?
    • New regulations.
    • Best management practices.
    • Improved relationships.
Performance-Oriented Standards
  • Designed for flexibility to protect employees.
  • Offers general guidelines.
    • Health & Safety (H&S) plans must be developed for hazardous waste sites.
      Contractor control is required.
  • Lockout/Tagout
    • When contractors are utilized, the on-site employer and the outside contractor must inform each other of their respective lockout or tagout procedures
  • Permit-Required Confined Space
    • Contract employees who perform work in confined spaces.
      Rescue Service.
  • Process Safety Management
    • To ensure that the actions of contractors do not lead to catastrophic releases, fire, or explosions.
PreQualification Safety Evaluation
  • Must complete prequalification safety evaluation.
  • Prequalification based on a numerical experience system:
    • Incidence rates, BLS - SIC codes.
    • EMR - Workers compensation.
    • OSHA recordable cases.
Evaluation of Contractor Safety
  • Effectiveness of a contractor's safety performance:
    • Measurable results
        Recordable cases (Lost time, Restricted cases, OSHA citations).
    • Is senior management committed to safety?
    • Is safety an integral part of project management?
    • Are safety and training improvement programs in place?
Contractor-Management Responsibilities
  • 29 CFR 1926.16(a), OSHA states, "In no case shall the prime contractor be relieved of overall responsibility for compliance with the requirements of this part for all work to be performed under the contract."
  • 29 CFR 1926.16(c) OSHA further states, "With respect to subcontracted work, the prime contractor and any subcontractor or subcontractors shall be deemed to have joint responsibility."
  • 29 CFR 1926.16(d), "Where joint responsibility exists both the prime contractor and his subcontractor or subcontractors, regardless of tier, shall be considered subject to the enforcement provisions of the Act."
Key Factor - Contractor Relationship
  • Identifying who supervises contract employees.
  • OSHA may treat contract employees as direct-hire employees if management of the host employer provides the majority of supervision and the contractor supervisor only serves as a figure head.
  • Contractors have the responsibility to ensure that all employees are properly trained.
  • Safety orientation should include a review of:
    • Physical and chemicals hazards on site (fire, explosion, and toxic release type hazards).
    • General safety rules and regulations.
    • Emergency reporting and response procedures.
    • Work permit procedures.
    • Other day-to-day issues.
  • Training will raise the level of safety awareness.
Work Plan
  • Essential in reducing injuries and illnesses and in maintaining a safe work environment.
  • Designed to protect employees, company's facilities, and local community.
  • Conduct pre-entry briefing prior to site entry and at other times, as necessary, to ensure that employees are aware of site hazards.
  • JHA techniques can be used to develop project-specific specification and procedures by:
    • Reviewing scope of work.
    • Identifying and evaluating controls for reducing hazards.
    • Reviewing hazards of each task.
      • Biological hazards.
      • Fall hazards.
      • Overhead/Underground Utilities.
      • Heavy equipment.
      • Other hazards.
  • Periodic safety inspections
    • Correct known deficiencies.
  • Must be kept at the work area - Readily available for all personnel.
  • Must be documented, reviewed, and updated as necessary.
Contractor Project Management
  • Must have on-site project manager (Site-Supervisor).
    • Essential for providing a smooth and efficient operation.
  • Must share overall responsibility and liability.
  • Must be a professional:
    • Able to interpret and manage safety programs, solve problems efficiently and expediently.
  • Must develop skills for recognizing and managing legal, financial, and customer relations.
Continual Improvement
  • Guidelines must be created for contractors.
    • Company policies and standards, contractor safety rules and procedures.
    • Initial training.
  • Must learn from mistakes or near misses.
  • Safety must be measured and monitored.
  • A good safety program is a catalysts for reducing accidents.
  • Minimal or "paper" safety programs - Not Acceptable.
  • Commitment to excellence in safety and quality practices.
  • Safety first.
    • Without safety - Poor quality.
    • Poor quality - increased production cost - poor employee morale.