Defining the Problem
As a host employer you may find yourself responsible for the safety and health of your workers, temporary workers provided by staffing agencies, and workers employed by other contractors or subcontractors, such as electrical contractors, machine installation or maintenance vendors, or long-term contractors that provide ongoing services such as building cleaning and maintenance.
This can create several challenges and hazards for you and your workers, and contractors and their employees.
To keep it simple, we will be referring to contractors, subcontractors, and staffing agencies as “contractor/s” and their respective employees as “contractor employees.”
Three Reasons for Concern
- Contractors Are Vulnerable
Contractor personnel are unfamiliar with your machinery and work processes which makes them vulnerable to accidents and injuries.
- You don’t get to train them the way you do your own workers.
- They don’t know their way around your site.
- They’re more likely to inadvertently work on energized equipment or improperly enter confined spaces.
- Contractors Can Put Your Workers at Risk
Having contract workers on your site can compromise your safety program and put your own workers at risk.
- Contract workers who aren’t familiar with your safety systems may inadvertently shut off or disable key controls or start up processes or equipment.
- Workers unfamiliar with your workplace or processes may accidentally cause a leak or spill or even start a fire or explosion.
- Your workers may not be aware of the hazards associated with the work contract workers are performing.
- You Could Be Liable for Contractors’ Injuries
- Various OHS and OSHA legislation in both Canada and the US hold host employers at multi-employer work sites responsible for contractor injuries.
Setting the Goals
The safety of everyone on site is enhanced when you have reliable systems in place for coordinating tasks, jobs, and projects and communicating safety procedures, hazards, and injury and illness information.
The goal is to ensure that before coming on site, contractors and their workers are aware of:
- The types of hazards that may be present.
- The procedures or measures they need to use to avoid or control their exposure to these hazards.
- How to contact the host employer to report an injury, illness, or incident or if they have a safety concern.
And, that host employers and their workers are aware of:
- The types of hazards that may arise from the work being done on site by workers employed by contractors.
- The procedures or measures needed to avoid or control exposure to these hazards.
- How to contact the contractor – and who to contact if they have a safety concern.
- What to do in case of an emergency.
So, how do you successfully make this happen? The Occupational Health and Safety Administration offers these suggestions for establishing effective communication and coordination between host employees and contractors.
Establishing Effective Communication
Each host employer establishes and implements a procedure to ensure the exchange of information about hazards present on site and the hazard control measures in place. Thus, all workers on the site are aware of worksite hazards, and the methods and procedures needed to control exposures to them.
- The host employer communicates with contractors to determine which among them will implement and maintain the various parts of the safety and health program, to ensure protection of all on-site workers before work begins. These determinations can be included in contract documents that define the relationships between the parties.
- The host employer establishes and implements procedures to exchange information with contractors about hazards present in the workplace and the measures that have been implemented to prevent or control such hazards.
- The host employer gathers and disseminates information sufficient to enable each employer to assess hazards encountered by its workers and to avoid creating hazards that affect workers on the site.
- Contractors regularly give the host employer any information about injuries, illnesses, hazards, or concerns reported by their workers and the results of any tracking or trend analysis they perform.
- Each contractor establishes and implements a procedure for providing the host employer with information about the hazards and control measures associated with the work being done by its workers and the procedures it will use to protect workers on the site.
- The host employer gives contract employers the right to conduct site visits and inspections and to access injury and illness records and other safety and health information.
- The host employer communicates with contractors and their workers about nonroutine and emergency hazards and emergency procedures.
- Information is communicated before work starts and, as needed, if conditions change.
Establishing Effective Coordination
Host employers and contractors coordinate on work planning, scheduling, and resolving program differences to identify and work out any concerns or conflicts that could impact safety or health.
- Include in contracts and bid documents any safety-related specifications and qualifications and ensure that contractors selected for the work meet those requirements.
- Identify issues that may arise during on-site work and include procedures to be used by the host employer and contractors for resolving any conflicts before work starts.
Host employers coordinate with contractors to:
- Ensure that work is planned and scheduled to minimize impacts on safety.
- Ensure contract workers are adequately trained and equipped before arriving on the worksite.
- Harmonize their safety and health policies and procedures to resolve important differences, so that all workers at the site have the same protection and receive consistent safety information.
Host employers and staffing agencies:
- Work together to deal with unexpected staffing needs by ensuring that enough trained and equipped workers are available or that adequate lead time is provided to train and equip workers.
- Make sure that managers with decision-making authority are available and prepared to deal with day-to-day coordination issues.