Contractor management: onsite insights
Bridget looks at the questions to ask of people who come onto your site.
First published in Health and Safety at Work Magazine, January 2015.
This is the second of two linked articles, you can read the first one Contractors – prequalified success.
They're here!
The previous article considered how health and safety professionals should be involved in checking contractors before they are awarded a contract — the planning and choosing elements of the HSE’s five steps for managing contractors. This time we look at contractors arriving on site, keeping check of them and reviewing their work.
In an administrative organisation the office manager might manage the contractors; in a factory or workshop the supervisor or facilities manager might oversee the process; in other organisations the health and safety manager might be in charge. We’ll use the term supervisor for the client’s representative in charge of overseeing the contractors’ work.
We’ll also use the term gatekeeper. In a large organisation the gatekeeper might be a dedicated security team; in other organisations it could be a single receptionist; in even smaller organisations, it could be whoever is at the door when the contractor arrives. Each organisation should be clear who its gatekeepers are and make them aware of the process and their responsibilities.
Before they arrive
For some trivial jobs, the first time someone from the contracting organisation arrives on your site may be the point they are going to start the work. But for jobs with any significant safety implications, the supervisor should arrange a previsit so that the contractor can tailor its generic risk assessments (if it uses them) to your site.
Be suspicious if the contractor isn’t keen on a site visit. Risk assessments that suggest controls “where required” and method statements that prescribe “appropriate access equipment, eg ladder, scissor lift, cherry picker or scaffold tower” are not specific enough.
A weighty volume of generic risk assessments and methods statements (RAMS) is unlikely to be helpful; RAMS must reflect the scope of the work. While it is unreasonable to specify that every contractor rewrites its RAMS to fit your own preferred format, there are some essential features you can insist on (see box below).
More paperwork?
Some organisations require contractors, even preapproved and prescreened ones, to complete another set of documents before the work starts. This should be proportionate to the site hazards, but is likely to include:
- a commitment to the site rules
- agreement on arrangements on the day, including parking, induction and welfare facilities
- names of workers who will be coming on site, and who they should contact on arrival
- a reminder of issues that have been covered in the contract, but that need emphasising, such as use of electrical equipment, scope of work permits and arrangements for waste.
This extra documentation provides one way of checking that the contractor understands the work — and responsibility for risks — before the work starts. If you do not use forms to collect this information, supervisors should make equivalent checks by phone, email or face to face.
Commitment anxiety
Contractors can be reluctant to commit themselves to a date and time, so that when they arrive the supervisor is not available and the induction and supervision processes are not ready. If your contractor procedure requires a particular person to be available, you have to explain to contractors that they will be refused entry and will not be paid if they turn up without an appointment.
Once the agreed day and time arrives, the pre-arrival information will ensure contractors know who to report to. Problems arise if contractors are allowed to wander on and off site at will. Even if a job takes several days, or contractors visit regularly, the gatekeepers must check that the right people have come to do the job and get them to sign in. Too often, contractors are admitted because they have the right logo on their van or their overalls; individuals should have their identities checked against the list of competent people provided by the contractor.
Many organisations that have multiple contractors on site every day run computer based systems to manage this process (see box on page 38). Features vary, but in general these systems allow the gatekeeper to check the following points.
- Is the approval for this contracting company still valid? Is its insurance up to date?
- Is the contractor scheduled to come today?
- Who is its site contact?
Have the right permits been raised and signed off? - Is each individual competent for the job described?
- If a substitute has been sent, can you check their qualifications (such as GasSafe, Part P, FGas)
- Has each individual completed the site induction? Some systems allow remote induction, others present the induction on site and record operators’ completion of a follow-up test.
- Have RAMS been approved in advance for this contractor?
- Does the contractor have permission to bring tools, chemicals or vehicles on site?
- What checks need to be made before the contractor leaves and who has to carry them out?
Whatever the computer says, someone should make basic visual checks that the equipment contractors bring on site is fit for use. Contractors with untested electrical equipment, unchecked ladders, and damaged kit are unfortunately not uncommon. As the client, do not rely on the piece of paper they sign to say all their equipment is compliant with all relevant legislation.
Box: RAMS
Note: these examples illustrate typical content, not ideal content!
Example 1: Separate risk assessment and method statement
| Risk assessment | Method statement |
|---|---|
| Hazards identified, often from a tick list | Activity: short description of job to be performed |
| Controls to be applied, often derived from the hazards only, rather than considering the task and environment | Location: specific discription of where the work will be done |
| Who is responsible for the controls, without clearly indicating whether a one-off or continuous activity | Plant, equipment and materials: making clear who is providing tools and resources |
| Sequence of tasks: how the job will be done, step-by-step, with precautions required |
Example 2: Integrated risk assessment and method statement
| Tasks | Tools & materials | Hazards | Controls |
|---|---|---|---|
| 1. Move equipment into position | Pallet trolley, tools sealed in containers and secure to trolley | Obstacles, tools falling from trolley, trolley running over feet | Clear route, secured tools, people away from the route |
| 2. Next step | Inventory of substances… | Other hazards | Controls following hierarchy, including PPE |
Features to check
Based on errors I’ve seen in contractor RAMS, here are some things to look out for:
Date: if the RAMS was produced before you placed the contract, it clearly hasn’t been tailored to work on your site. For a long term contract you would expect the contractor to review the RAMS at least once in two years, and more often if there are incidents, accidents or changes in ways of working or equipment.
Responsibility: has anyone put their name to the document? It is surprising how many times RAMS are sent out without a name, or with the name of someone who has left the organisation. If something goes wrong, who will be responsible? Even if a generic risk assessment has been written by someone who has since left, someone with credibility should be prepared to put their name on the tailored version of the RAMS.
Method statement: it might not be called a method statement — it could be headed method of work, sequence of operations, safe system of work or process steps — but it should make it clear what needs to be done, step by step, including preparation and tidy up stages. It does not need to be so detailed that a novice could follow it, but should be unambiguous to a suitably trained person. For example, “isolate and lock off the power at the fuse board in switch room 2” is unambiguous because it describes where the power will be isolated, but it is not necessary to describe what “lock off” means.
Risk assessment: again, the document might not include a section headed “risk assessment” but does it demonstrate a clear understanding of the hazards involved with the work, and with working on your site? If you have supplied a risk register, has the contractor included relevant hazards? For each hazard they identify, is it clear what controls they will apply? These are the essentials. Rating and ranking risk is not that important in most cases, as long as the significant hazards and their controls have been documented. If your organisation uses a numeric system for evaluating risks, consider whether you would rather your contracting organisation spent its time changing its maths to suit yours or identifying hazards and putting in controls.
Brief encounter
Contractor inductions vary from a two hour classroom session with the health and safety manager, incorporating a video and test, to a sheet of paper thrust into a contractor’s hand by a security guard, on which they tick a box to confirm they understand emergency arrangements. The induction should be proportionate to the risk, but should be more than just a box ticking exercise. The gatekeeper must be competent to talk through key issues (see box below) with the contractor to confirm their understanding, and should give the contractor a brief written reminder of the emergency arrangements.
You can buy off the shelf induction e-learning, but it is unlikely such training would teach contractors anything they don’t already know. E-learning is a useful way of making sure that everyone gets the same information, but choose an organisation that will tailor the induction training and include video and photographs of your site.
Frequency of induction also varies. For some sites it is a one-off process, valid until retirement; elsewhere it must be renewed on every visit, or every project. Frequency based on risk and complexity is the ideal, but an annual renewal is common and acceptable.
However you arrange the induction, it should be backed up by an escorted walk round areas the contractor will be working in, highlighting any areas its workers should not enter.
On the job
The supervisor should check that the contractors understand the risks. Don’t assume that, because their boss sent you a carefully produced RAMS, the workers will know what precautions to take. Adrian Crawley, health safety and facilities manager at vehicle maker BMW Group UK, has learned to take nothing for granted.
“Guys turn up who are third party sub-contractors, and have never seen the job or any of the safety documentation,” says Crawley. “Once we realise this, it is a huge drain on resources to chase the relevant paperwork, to make sure everyone is briefed, and to make more frequent checks that the task is being carried out safely.”
With RAMS in hand, ask the contract workers to outline how they will do the job and what precautions they will take. When he was a quality, environment and health and safety manager for a civil engineering company, Jon Dawson picked up problems in this way.
“Sometimes we stopped the work and helped the contractor to rewrite the method statement,” he recalls. Dawson recommends quizzing the contractor supervisor in a discreet and friendly way.
Chris Jerman, safety manager at the John Lewis Partnership, prefers a direct approach, suggesting questions such as “Can you tell me what might go wrong here?”, “How would you prevent that?”, and “What would you do then?”.
As the supervisor, you do not need to know what the answers should be, but you will be able to read something into the confidence with which the contractor responds. “If the answer to any of the questions is, ‘errm…’,” Jerman adds, “there is no point going any further.”
The problem for the supervisor is being confident in telling a contractor to stop work if they do not feel the contracting staff know enough about the hazards and controls, or are simply not working safely. Management systems must provide back-up to a supervisor having to take a decision, particularly if the contractor’s inability to complete a piece of work would affect business or production.
Watching brief
Supervisors have to make further checks once the work has started. Even without specialist knowledge of the contractor’s task, anyone can see that standing on a roof with no visible means of support is dangerous, and permanent staff will know about site hazards. The supervisor might not know much about the hazardous substances being used for water treatment, for example, but they can see what the RAMS said about protective gear and check that operators are wearing gloves, aprons and goggles.
For a job lasting more than a day, a supervisor should check the work soon after a contractor starts, and then at least once a day, more often for complex or high risk work.
As well as controlling entry to the workplace, your gatekeepers should prevent departure until the named supervisor has agreed the work has been done satisfactorily and left safe. Instruct all other staff that they should not sign contractor documents and make it clear to the contractor at the start that they will not be paid unless their paperwork is signed by the named supervisor.
Some aspects of the work can be checked on the day: have the decorators taken away all the half used tins of paint? Has the demolition company cleared all the debris? Have the service engineers left you with the appropriate records? Other aspects may require a more detailed analysis, depending on the contract value and duration, and on the safety
criticality.
Post-job review
A minimal review might involve the maintenance staff discussing at their weekly meeting whether there had been any problems with contractors in the previous week, even if they hadn’t thought it worth raising at the time. A more detailed review would involve a checklist.
- Did they finish the job to the standard required within the agreed timescale?
- Did they have any accidents?
- Did they need to be reminded of health and safety rules?
- Did they sign in and out correctly?
- Did they send anyone who wasn’t on the original list of competent people?
- Was everyone there when they needed to be for induction training?
- Did they leave a mess?
The results of the review need to feed back into your own procurement process, so you know whether to use an organisation again. But the review is more than an evaluation of the contractor, it is a review of the success of your own contractor management processes.
Emergency contact details for contractors
Your contact is…
Your nearest alarm call point is…
The fire alarm drill sound is… It is tested every (Wednesday) morning. At other times you should switch off all your equipment and leave immediately.
Your exit route will be…
Your assembly point is…
If you need first aid, contact…
Please report all accidents and near misses, or dangerous circumstances to …
The price of failure
Like many organisations, Brintons Carpets probably thought it was doing everything it needed to do by outsourcing the inspection of its pressure vessels to Allianz Engineering Inspection Services. Allianz was contracted to provide an inspection as “a competent person in accordance with the requirements of such statutory regulations as apply to the plant”.
When one of the vessels exploded with such force that the lid hit the roof six metres up and dented the girders, and it was discovered that Allianz had not completed the periodic thorough examinations of the vessel for three years, Brintons might have thought that only its contractor would be found at fault.
Allianz pleaded guilty to breaching the Pressure Systems Safety Regulations (Regulation 9(2)) and paid £14,111 in fines and costs. But Brintons was also prosecuted, and had to pay out £11,174 under Regulation 12 of the same regulations.
So what is the client expected to do? Brintons used a well-known organisation with a recognised reputation to carry out a specialist job. Was it supposed to hire a second contractor to follow the first around?
A reasonably practicable approach might be to carry out sample checks once or twice a year. Pick a spread of items and check the paper documentation provided against computer records and against any local inspection stickers on the equipment.