As a former Industrial Health and Safety Manager, there is nothing I hated to hear more from an excited employee approaching me, yelling something like this, “Fitz, why do you make me Lockout, and you allow that contractor over there not to do the same?” Usually, I did not even know we had contractors in the plant to do any work. So, I would just stand there looking inept and perplexed, which I also hated most of all! As an organization, “drains the swamp” in its safety journey, towards Lean World-Class Safety, Contractor Safety will probably rise-up as one of the alligators. Pre-transformation stage many organizations are trying to just manage all that safety stuff! Frankly, when you are up to your butt in other alligators Contractor Safety many just do not have the time to manage contractors. However, as you begin the transformation to World-Class you will begin to eliminate the other alligators. At some point Contractor Safety will still rise-up to bite you.
Unenlightened managers might say something like, “Contractors work for someone else, why worry about them? I have enough to do worrying about my own employees. That is usually why I hire a contractor!” However, before you just dismiss a worrying about Contractors from being your responsibility remember:
- In the eyes of OSHA, if you are directly supervising the Contractor, you are as much responsible for that person as you are your own permanent employees. In that case they are considered “Contract Employees” and their injuries go on your OSHA 300 Log just as any other employee. The rules about contacting OSHA upon an injury also apply to contract employees. We called them, “Temps” for Temporary Employees.
- A significant injury to ANYONE on your property may trigger an OSHA visit! OSHA can then go anywhere and check anything else they question in your facility. You could find you end up with real OSHA citations as a result of the actions of your contractors. If you have a contractor electrician get badly burned in your building you may not have to call OSHA, but the contracting company still must. If OSHA feels the incident warrants their investigation they will be visiting you!
- Depending on the state, you may not be responsible for Workers Compensation, but because of something called subrogation, you are not immune to liability lawsuits, which can be many times more costly than WC, especially where negligence can be proven.
- Your contractors must follow the same OSHA and Company Standards and Policies as your own employees! Many contractors brought into your plant have superior training and experience in their fields than your own employees. That may be partly the reason you are bringing them in. Contractors, with their superior skills, are examples to your employees. You sure want them to be positive and safe examples, not negative and unsafe ones.
- Organizations that have ISO 9001 in Quality understand vendor and supplier control. ISO 14000, 18000, and now 45001, understand the same practice for “Contractors”. Look at it this way; Contractors are vendors and suppliers too, and every ISO Policy I have ever seen addresses these relationships.
If you do not have an effective Safety Contractor Program, you are not going to be in the Lean World Class Safety Club until you do. A good Contractor Management Program is part of the entire Management of Change (MOC) process. Furthermore, speaking from experience, effective Contractor Safety Programs can be one of the hardest things to do in your safety journey. I have learned, you cannot do it yourself. You will need assistance. Most of all from your own Project Managers who may hire Contractors.
Your Project Managers (PMs) must understand your Safety Policies and their requirements. They must work be diligent in ensuring the Contractor knows your Safety Program and its requirements, and then ensure the Contractors follows them. Along the same lines, someone must ensure the Contractor is keeping current with their employee safety training. Many PMs struggle with all this unless properly trained. However, as you address draining the entire swamp of safety concerns, the alligator of Contractor Safety must be addressed if you want a World Class Safety Culture. There are many different approaches to Contractor Safety. Safety Fitz LLC has the experience to assist you with all this if you feel the need. One thing is for sure, to not deal with Contractor Safety will leave you behind, open to further problems. Not dealing with it will drag you down! No one says the road to a Lean World-Class Safety Culture is easy!