Ways to maintain OSHA contractor safety compliance

As an EHS manager, my best practice for OSHA contractor safety compliance is to treat third-party workers like all my other employees. Holding everyone to the same standards makes it so much easier to track and manage compliance. Here are the top ways I put this approach into practice to keep my contractors just as safe as everyone else.

Oversee contractor training

All workers (including contractors) must go through a safety training program that includes process-specific hazard training.

A best practice I always follow is to check out the contractor’s general safety training program. If the content is good, then we just verify that they’ve completed those requirements independently. But I always have workers go through site-specific and process-specific lessons as well. Here’s what I include:

• Process training
• Emergency response plan
• Hazard identification and reporting
• Materials handling

You’ll find more in-depth information on OSHA’s contractor training requirements in individual standards. Two examples of standards that have specific contractor training information are:

• 1910.119: Process safety management of highly hazardous chemicals
• 1910.272: Grain handling facilities

NOTE: Under OSHA’s construction industry guidelines, contractors must have a dedicated safety program that aligns with their hiring company’s program.

Share information with contractors

One of the biggest mistakes you can make regarding contractor safety is not communicating often and effectively. Ideally, you should notify contractors of any changes to your safety program, procedures, or protocols. This is especially important for high-risk industries or processes. The more communicative you are, the safer and more productive your contractors can be.

OSHA has several requirements for communicating important information between contractors and hiring companies. For example, OSHA requires companies to share any information they have regarding known hazards with contractors. And when hiring a contractor, you need to evaluate their safety program and overall performance.

Because OSHA doesn’t have a regulation dedicated to contractor safety, the requirements are scattered. Here are some the standards that specifically mention information sharing and what you need to do to reach compliance.

1926.65(b)(1)(iv): If you’re using contractors for hazardous waste management, share your emergency response plan with them. Also, make sure you tell them about any hazards within your facility’s waste management process.

1910.119(h)(2)(vi): Keep a detailed log of any contractor activity in process areas.

1910.147(f)(2)(i): Inform contractors of your site’s lockout tagout procedures.

1910.119(h)(3)(iii): Make sure contractors know the fire, explosion, and/or toxic release hazards in their process.

If you don’t want to get bogged down in researching the specific OSHA criteria, follow these best practices. Always update your contractors when you change safety procedures, find new hazards, or increase the risk level of a process. And, if you can, document all your communications just in case of an incident.

Encourage contractor participation

Worker participation is one of the core elements of OSHA’s EHS program recommendations. And your contractors should count as “workers” if you want to run an effective safety program.

I always try to engage contractors in the various initiatives we have going around our site. Examples of these initiatives include:

• Safety moments and shoutouts at standup meetings
• Health and safety committees
• EHS department’s weekly or monthly newsletter
• Continuous improvement project implementation

Depending on what type of contractors you have onsite, some of these may not apply. For example, if you hire a contractor to do facility repairs, chances are they won’t be onsite for long. So, involving them in some of the ongoing initiatives might not make sense.

But regardless of how long contractors are there for, you can still include them in your safety moments or get their input on how to improve a process. Don’t miss out on these opportunities to engage workers and (hopefully) prevent safety incidents.

Document contractor compliance

One of the most important ways to maintain OSHA contractor safety compliance is to document everything. You want to keep thorough records of all the work they’re doing, equipment they’re using, etc. That way, if a safety incident happens, you have detailed information about the project.

Here are a few other documents you need to collect and organize so they’re easily accessible:

• Signed employment contracts
• Drug tests
• Employee licenses, certifications, permits, etc.
• Safety training records

The trick is to have a good system for organizing and updating these documents. Contractor safety management software is a great option for managing documents and verifying compliance. If you use a manual document management system, just make sure you label everything clearly and organize it in an intuitive way. You want to make sure documents are easy for anyone in your team to find.

Overall, the key to contractor safety is to treat all your employees the same. Engaging contractors in your safety program will make it easier for you to maintain compliance and achieve your goals.