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Thinking of using contractors at your worksite?
It's a new ballgame on safety
By Jim Stanley
President, FDRsafety
 The economic revival now underway is unlikely to be nice and smooth and many employers will be hedging their bets by hiring contractors rather than full-time employees as they increase production.
That's a tried-and-true approach, but industrial employers should be aware that there is a new Factor X to be figured into their calculations: increased OSHA enforcement against companies for exposure of contractor employees to unsafe conditions.
A court ruling earlier this year affirmed OSHA's ability to issue citations/violations to companies for actions taken by contractors at their worksite, even if the companies didn't create the hazard and didn't expose their employees to it. The "New" OSHA is choosing to exercise that authority as part of a wider step-up in enforcement and is applying that authority to industrial companies, not just construction companies.
Companies expecting to use contractors need to plan now - before contractors set foot on the premises - to make sure that they are not needlessly exposing themselves to OSHA liability. If you already have contractors on-site, it's time to step back and do a thorough review of your contractor safety program.
Every employer that hires outside contractors needs to have a well-defined safety program for contractors, distinct from the safety program for their employees.
Here are 7 key steps in preparing a contractor safety program:
1) Management must be part of the process to identify contractors that are eligible to bid on work within their facility. Before any contractor gets on that list, managers should satisfy themselves that the contractor has the following:
- A written overall safety and health program.
- Specific plans within the overall safety program for such things as fall protection, lockout, work in confined spaces, personal protective equipment, etc.
- OSHA logs going back 3 years and the OSHA recordable rates from those logs.
- Any citations/violations issued by OSHA at any of the contractor's location in the past three years.
2) Once a contractor has satisfied management that it is eligible to work in the facility, its workers must follow all plant safety rules, including personal protective equipment requirements. The contractor must be able to provide workers that have negative results from a recent drug test. If a contractor cannot provide the recent negative tests, the company must require that a drug test be administered to those workers before they can continue any work in the facility.
3) Most companies require that any contractor with more than a few employees have a full-time safety professional with them who is responsible for the contractor's employees and their safe working environment.
4) Many companies require that contracted employees be trained in the 10-hour OSHA course or have equivalent training. Proof of this training should be required before any worker can come onto the worksite.
5) Company managers and contractor managers should meet at the beginning of each day to discuss any potential hazards in the workplace. This meeting should be documented by both parties.
6) Company management must be aware of what contractor employees are working on and where they are located every day. Contractors need to observe their workers daily and audit their compliance with company and OSHA rules.
7) Both the contractor and company management need to understand their responsibilities for protecting their workers while contractors are on the premises. These responsibilities cannot be delegated to anyone else. Each has to be responsible for providing a safe place to work while on company property. Most world-class companies have a zero tolerance policy for violation of health and safety rules.
FDRsafety can provide your company assistance in creating a contractor safety plan and help set it up. We can also assist you in overseeing contractor safety performance.
Contact FDRsafety at info@fdrsafety.com or 1-888-755-8010.
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Fatality underscores need for training about hydrogen sulfide
A fatal accident at an Ohio oil and gas well in September underscores the potential danger posed to oil and gas workers by hydrogen sulfide and the importance of training to avoid the hazard.
One man was killed and four others were injured after breathing hydrogen sulfide gas at a well they were plugging near Cambridge, Ohio.
The accident prompted the Ohio Oil and Gas Energy Education Program (OOGEEP) to fully fund and execute training for Ohio's natural gas and crude oil industry on how to protect workers from this naturally occurring gas, which can be found in oil and gas deposits in certain parts of the country, including very limited areas in Ohio.
One session of the training was held in October and two more are scheduled for this month. The training includes segments on safety planning and hazards assessments for hydrogen sulfide. Also addressed will be detection, emergency response and first aid procedures as well as instruction on dealing with confined spaces in oil and gas work, including identification, awareness, planning and procedure implementation.
Hydrogen sulfide can pose a potential hazard during the drilling, production and plugging of an oil and gas well. It can also be generated from geothermal power exploration, sewage and landfills. Three people were killed in an accident at a sewage plant in New York earlier this year and four died in an accident in 2007 at a landfill in Wisconsin.
"Fatal accidents due to hydrogen sulfide exposure in the oilfield can be eliminated," said Jason LeMasters, vice president of FDRsafety, who was contracted by OOGEEP to conduct the training. "Companies need to provide detailed hazard and emergency response training to all employees. Awareness and pre-planning on sites where H2S could be present is key."
"There is no reason why employees can't go home to their families safe from H2S hazards," LeMasters said. "OOGEEP is providing a priceless resource in conducting these seminars for the industry. We are excited to be able to assist them with their ongoing safety and health training efforts."
"Obviously, anytime someone gets accidentally killed or hurt, it negatively impacts everyone in the oilpatch," said Rhonda Reda, OOGEEP executive director. "While H2S incidents are very rare in Ohio, we believe that this recent accident provides an opportunity to pro-actively support and conduct these training programs, and we are pleased that FDRsafety was selected as our contractor," she said.
FDRsafety stands ready to provide hydrogen sulfide training to other trade associations or individual companies. Contact Jason LeMasters at jlemasters@fdrsafety.com (740) 207-3104.
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Have a specific question on OSHA's new recordkeeping push?
Give Jim Stanley a call for advice at no charge
OSHA's
has begun its new program of emphasizing enforcement of recordkeeping
requirements and plans to focus on industries with high injury and
illness rates.
The
inspections include a records review, employee interviews, and a
limited safety and health inspection of the workplace. For more
details, see OSHA's directive on the issue.
FDRsafety
offers assistance to employers on developing a strong recordkeeping
program and company President Jim Stanley is happy to answer limited
specific questions about the issue at no charge. Call him at (513)
317-5644.
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The latest from Jim's blog
Read Jim Stanley's Workplace Safety Blog to keep on the latest changes at OSHA, which is being reshaped by the Obama administration.
Among Jim's recent topics: detail on which industries will be the focus of OSHA's new enforcement push and the steps your company needs to take to be ready for the "New" OSHA.
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FDRsafety
278 Franklin Road
Brentwood, Tennessee 37027888-755-8010
info@FDRsafety.com
ABOUT FDRsafetyAt the heart of FDRsafety is this simple idea: Extensive expertise and experience bring the best results. FDRsafety is led by two nationally recognized, long-time leaders in safety: Fred Rine and Jim Stanley. Each has decades of experience improving occupational safety and health performance at companies of all sizes, including complex multi-billion dollar, multinational organizations. FDRsafety can meet your needs for a wide range of safety and health services, including training, OSHA compliance, safety staffing and expert witnesses. Contact us to learn how we can help you reduce accidents, meet federal, state and local legal requirements, reduce costs, and most importantly, protect your greatest assets - your employees.
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