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When should subcontractors be required to have a
full-time safety professional?
By Jim Stanley
President, FDRsafety
 With controlling contractors now being held responsible for
the safety actions of subcontractors at their sites by OSHA's Multi-Employer
Citation Policy, many contractors are now asking what levels of safety staffing
should be required from their subs.
While every situation is, of course, unique, there are some
generally recognized industry practices you can follow.
The Rule of 15
If a subcontractor has 15 or more workers on a site, the
controlling contractor should require them to employee a full-time, onsite
safety representative who monitors all contracted work being performed.
Pay attention to the EMR rate ...
All subcontractors should have a Worker Compensation
Experience Modification Rating (E.M.R.) of 1.0 or less. If a contractor exceeds
that level, the controlling contractor should require them to employ an onsite
safety representative even if there are fewer than 15 workers present.
... the OSHA
Total Recordable Rate/DART Rate ...
All
subcontractors should also have an OSHA Total Recordable Rate and DART rate
least 35 percent below their industry average. Those rates are usually based
the contractor's previous three years of work activity. If a contractor does not attain those rates,
it should have an onsite safety representative.
... and to OSHA citations
Any subcontractor
who has received OSHA citations
containing Serious, Repeat or Willful violations in the last three years should
be required to have an onsite safety representative, regardless of the size it
is work force.
Evaluate high-risk situations ...
Even subcontractors who meet all standards should be
required to have an onsite safety representative during situations when there
will be critical or high risk work that requires strict compliance to safety
and health regulations. An onsite safety
representative should be present for work planning, preparation and execution.
... and community relations
On large scale projects the controlling and/or the owner
may require all subcontractors to have an onsite safety representative solely
based on its size and visibility to the surrounding community and relationship
with OSHA.
Jim Stanley, president of FDRsafety, is a former
No. 2 at OSHA headquarters. He has special expertise in the use of
subcontractors at construction sites and other work sites. Contact Jim at (513)
317-5644 or jstanley@fdrsafety.com.
Have a specific question about safety requirements
for subcontractors at your worksite? Ask us
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We can help you qualify as a safe vendor, get contracts
 Doing a good job providing information
about safety credentials to ISNetworld can often spell the difference for a
vendor between getting a contract or being left out in the cold. FDRsafety can
help make sure you get ISN approval.
ISN is an information source for
connecting corporations with vendors in capital-intensive industries. ISN collects
information about safety credentials self-reported by vendors, verifies its
accuracy and then provides a report that is available to industry.
It can be challenging to make sure that
information provided to ISN is presented to your best advantage and in the
proper format. At FDRsafety, we are experts in helping you put your best foot
forward.
Contact us for more information. |
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Secret recipe behind one company's very low OSHA recordable rate
Personal attention from
the CEO and the expertise offered by a highly experienced advisor are two of
the ingredients that have helped National Steel City LLC, a steel erector,
achieve an OSHA Recordable Rate for accidents and illnesses that is one-fifth the
industry average.
National Steel City, based
in Plymouth, MI, with an office in Birmingham, AL, reported a rate of 1.18 to
OSHA this year. The rate reflects the number of injuries or illnesses at a
worksite multiplied by 200,000 then divided by the number of hours worked.
"We employ only the most qualified
safety managers on our construction projects, all of whom report directly to me
and I am personally involved in reviewing our daily safety reports," said
Bob Dunn, CEO of National Steel City.
Dunn also credits the advice provided
by Jim Stanley, President of FDRsafety and former No. 2 official at OSHA headquarters.
"Thanks to our important alliance
with FDRsafety, we've not only built and perpetuated an outstanding safety
track record, but instilled a culture of safety that helps us remain competitive
for our customers and ahead of the curve as a company," Dunn said.
Stanley regularly consults with National Steel City on its
corporate safety program and on all projects. Stanley delivers advice, counsel
and training for all managers and supervisors, and has counseled senior
managers, presented at company meetings and submitted safety articles for
company publications.
"I
believe National Steel City continues to serve as a model example of a company
committed to safety excellence," Stanley said. "It's not enough to
make safety a priority. Safety must become an inherent company value because
priorities always change, and such a commitment always begins at the top."
Learn more about
FDRsafety's OSHA compliance services.
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Latest from our blog: Improving safety and
efficiency with the 5-S approach
Good housekeeping has historically been a
foundation for occupational safety. 5S, a process used in lean manufacturing,
improves both efficiency and safety at the same time. The five "S" words: Sort,
Straighten, Shine, Standardize, Sustain. Read Mike Taubitz's post.
Penalties for violation of OSHA standards are not high enough to discourage some employers from violating the law and they ought to be increased, according to the agency's new director.
Subscribe to our blogand get the latest news about safety from Mike
Taubitz, Jim Stanley and CEO Fred Rine. |
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If
you're in Ohio, catch our seminar on getting ready for increased OSHA
enforcement
OSHA's
director has warned industry "there's a new sheriff in town." Inspections are
increasing and penalties are getting tougher.
The best way for companies
to react is with a strong safety program.
The Central Ohio Chapter
of the National Safety Council is sponsoring special training conducted by
FDRsafety to help companies protect their employees and themselves:
"Remaining
competitive as OSHA increases enforcement"
Date:
Wednesday, May 19
Time:
9 a.m. - 11:30 a.m.
Location:
The Fawcett Center
2400 Olentangy River Rd.
Columbus, OH 43210
Cost:
$25 Member; $30 Non-Member
Topics
will include:
- How to meet OSHA
rules on recordkeeping
- How to create a
successful contractor safety program.
- How supervisors
should handle safety issues in light of tougher OSHA enforcement.
To
register:
Contact
Patsy Glasgow at pglasgow@nsc-centralohio.orgor 614.324.5934.
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Visit our site!
www.FDRsafety.com
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 usto 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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