Service Overview

To have a successful control of supplemental workers program, the host employer must first hire contract companies that have high standards, programs, training and operate in a safe manner. Our contractor safety program covers all aspects of safety for potential and current contract companies working on your property.

We have an à la carte services menu for you to choose to what depth you reviewed for your contract companies. Our method combines technology with “old school” investigative work. While we certainly use technology to increase our production speed, we do not rely upon computer programs that perform word or phrase searches to decide if a contract company has all the “buzz words” in their documents. We have safety professionals read each document to ensure it meets federal standards (or your standards as an option).

Each of the following services is à la carte for you to decide what depth of discovery is necessary. We will also help you decide which menu items you need and programs to focus on.

 

Pre-Qualification

ASH will investigate and supply a report to the Customer on the following:

• BLS rates for OSHA recordable Injuries and illnesses for Contract Companies the North American Industry Classification System code (NAICS) (i.e. heavy construction, roofing, nuclear power, electrical, etc.)
  • BLS – Bureau of Labor and Statistics, publish and annual set of rates for all NAICS
  • Injury rate is:   # of OSHA recordable injuries x 200,000
                                                Work hours
  • ASH does this for the following categories:
    • Last 3-years by year, including current, plus performance trending
    • Last 3-years average
    • Total Case Injury Rate (TCIR) (all recordable injuries and illnesses)
    • DART Rate (Days Away, Restricted Duty Job Transfer injuries and illnesses
    • Days Away (Days away from work or Lost Time for injuries and illnesses)
    • Fatalities
    • Contractor company verses NAICS peers against BLS:
      • Median/Average
      • Quartile*
      • Contractor size verse median and quartile*

*Depending on the NAICS and year, not every NAICS code will have full quartile data for all size companies

• OSHA Inspection and Citation 5-year Review
  • Each inspection (if applicable) will be reviewed and categorized by:
    • Complaint
    • Fatality
    • Referral
    • Scheduled
    • Follow-up
    • Trends in issues causing inspections (other than scheduled)
• Experience Modification Rate (EMR)
  1. Review EMR verses standard of 1.0 or client determined value
  2. EMR verses TCIR, DART & Days Away validation

• Pre-Qualification Report
  1. A report that looks at the attributes of the pre-qualification program as a whole, informing the client the deviations from acceptable norms and how they may interact with each other to “tell us a story” about the potential contractor.

 

Safety Program Review

ASH will work with the Customer to determine which safety programs every contractor must have and then an additional à la carte program menu based upon work scope.

• Review Types:
  • The standard review consists of ASH safety professionals reviewing the designated contractor safety programs verses the applicable OSHA standards; which may include, depending on Customer needs, API, ANSI, ASTM, NFPA, etc.
  • The custom review includes the standard review, but will include a gap analysis from the Customers safety procedures, policies, manuals, etc.
• The ASH review will identify the following in the contractors safety procedures:
  • Covers all legal requirements as per applicable regulatory agency
  • Does the procedure make sense? It is written in a way that a worker can follow? Is it written in a way for the type of work the contractor performs? For example an electrical contractor has a fall protection procedure that focuses on low pitched roofs and leading edge work and 6’ warning lines, but OSHA standard does not permit these activities unless performing roofing or pre-cast concrete work.
  • Do the various procedures and programs reference each other and tie together or are they a random bunch of purchased documents.
  • Last time procedure was reviewed
• Gap identification or closure options
  • If ASH identifies regulatory a gap(s), it can be addressed in several ways.
    • The standard method is ASH will inform the contractor their “X” procedure is not in compliance with section a.1.iv of 29 CFR 1926.XXX. The Customer and ASH decide if the contractor can revise the gap(s) or determine that the contractor is not suitable. Normally ASH and the Customer will have a number of gaps with a weighting scale to decide if a contractors program is acceptable.
    • This next level is for ASH to correct the deficiency for the contractor; which is typically funded by the contractor, but an option to permit or not by the Customer is decided in set-up phase. This option can be done for both standard (OSHA) and custom procedure review options.

Safety Training Program Review

There are also various training program reviews available. A company might have rules on safety, but how the employees know how to find and follow these rules is just as important as having them. Just as the other programs, the host employer determines which training programs it requires the contractor to have, to what depth of training and any type of check for understanding. There are multiple options to the training review program for the host employer and contractor as well.

• Review Types:
  • The standard review is of the OSHA required training for the applicable safety procedures.
  • Option-1 is a review against the host employers training requirements and Customer procedure content.
• The ASH review consists of the following:
  • OSHA required content
  • Quality of the training documents
  • Training document verses applicable procedure correlation. Does the procedure and training match each other/
  • Do procedure and training revisions coincide with each other?
  • Training documentation review. ASH will review training records to ensure employees are actually being trained and the documentation is correct. This helps ensure the contractor is doing what they say and protects YOU, the Customer from liability
• Gap Analysis and Closure
  • This process and options are the same as the procedure gaps. ASH provides a full set of services:
    • Identify
    • Identify and correct gaps
      • OSHA
      • Customer

Field Safety Auditing & Oversight Services

All of the pre-work of the contractor’s history, procedures and training are critical tasks, but tying it all together with on-the-job auditing of the contractors performing work is essential. ASH uses the same approach in the field audits as in qualifying the contract company for work at the host employer’s site.

ASH safety professionals are armed with a summary the contractor’s history, copies of their applicable procedures and training in order to perform a focused audit of the supplemental workers in action. This final step validates the contractor is using their procedures, applying the training and sending workers who have completed the training to the host employers site.

Depending on the scope of work, hazards, number of supplemental workers and more, ASH can perform in-field audit on your contractors at other customers of theirs, before you hire them. This way, you get a third party report on how they do business, before you agree to hire them for your work activities. We spend one or more days performing a validation audit of the contractor(s). For larger projects, ASH can supply one or more full-time safety professionals to provide third party safety oversight. This saves the in-house resources for host-employer employee oversight and more especially it provides a buffer between the contractor safety personnel, contractor management and host employer project management to avoid the conflict of interest of contractors getting the job done and completing the project with safe, high quality work.

The oversight can be supplemental employees and their employers procedure and training, supplemental workers and host employer procedures and training or a combination of both. The ASH safety professionals can also monitor JHA’s, pre-job briefs, 2-minutes drills, injury/incident investigations, as well as providing a full range of safety training, including hands-on training and Dynamic Learning Activities.

Summary

Having ASH, a professional safety, consulting and training company act as a third-party review service before the contractor is approved, all of the way through working on site will give the host employer a comfort level that someone is out there watching their backs. ASH’s only job is to ensure the host employer is protected and has an injury/event free project. You can count on ASH to be there every time you need safety support.