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Contractor's Performance is Employer's Responsibility Make Safety and Environmental Requirements Explicit
January, 2008
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DESIGN FACTORS INFLUENCE SAFETY COMPLIANCE
By Marianne Santangelo
A survey of safety professionals has found that noncompliance with personal protective equipment (PPE) protocols continues to be an issue in the workplace. When surveyed at the 2007 National Safety Council (NSC) Congress, 87% of respondents said they had observed workers failing to wear PPE when they should have been.
"We not only asked why people did not comply with PPE protocols, but what could be done to alter these behaviours," notes Randy Kates, a General Manager with Kimberly-Clark Professional, which gathered survey results from 197 professionals employed in industrial manufacturing, construction, hazmat, emergency response, clean manufacturing, laboratories and science, health care, transportation, law enforcement and government.
Nearly two-thirds of respondents cited discomfort as the primary reason for noncompliance. Other ranking reasons included: workers thinking PPE was not necessary for the task; PPE was "too hot"; PPE fit poorly; and PPE was "unattractive looking".
When asked what could be improved about the PPE they were currently purchasing, three quarters of survey respondents called for increased comfort. Safety professionals also endorsed the development of more fashionable PPE - 84% agreed that they would be more apt to purchase more attractive PPE if workers would be more likely to wear it and if the price was comparable to current prices for similar products.
The survey also explored the effect of environmental considerations on purchasing PPE and other personal safety products. Here, the verdict was nearly unanimous. 94% of respondents said environmental considerations and reducing the impact on the environment were important to them - 64% ranked these as "very important," while 20% described them as "somewhat important." 10% said environmental factors were "increasingly important now" as compared to a few years ago.
When it comes to green purchases, the top consideration was buying products made with recycled materials. Next was the ability to reuse or recycle products after use. Source-reduced products and packaging and a manufacturer's overall commitment to the environment were nearly tied for third place. These were followed by:
* Purchasing from one supplier to reduce energy costs resulting from the transport of supplies from different sources.
* Products that are shipped in biodegradable packages with as little packaging material as possible.
* Products manufactured in a carbon neutral facility.
Marianne Santangelo is Segment Marketing Manager, Manufacturing, with Kimberly-Clark Professional. For more information, see the web site at www.kcprofessional.com.
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By Al Aiello
Working at heights, with hazardous materials, near energy sources and in confined spaces are everyday activities for many contractors' workers. Employers might presume that the contractors they've hired have all of the necessary controls (programs, procedures, training) and insurance coverage (provincial workers' compensation, general liability, automobile, etc.) in place to ensure worker and environmental safety and compliance with applicable legislation. However, property owners and managers should be aware of their responsibilities and potential liabilities where contractors are concerned.
Legislation governing occupational health and safety, environmental protection and workers' compensation outlines the responsibilities of the owner, constructor and employer hiring a contractor to perform work on their behalf or at their facilities/project. Recent court decisions and increasing enforcement measures have made it increasingly clear that the assurance of a safe working environment is ultimately that of the party with the greatest degree of care and control of the workplace and work activities. Acting in any of these capacities will require clear lines of communication and involvement with or establishment of a health, safety and environmental system to ensure the safety of all workers involved with the work.
There are many considerations when using contractors to perform work. Is the work "construction" work? Is the work a "project"? Is a "pre-start health and safety review" required?
Employers should have procedures in place establish and demonstrate due diligence for work performed by contractors. Even where the contractor's work is not complicated, a typical contractor management program should include measures to ensure the pre-qualification of all contractors to perform work for the organization. This should include both professional and labour intensive services, from construction managers and contractors to maintenance, custodial, landscape and other service providers.
Procurement procedures are specific to each project/contractor and include: instructions to bidders (identifying hazards and hazardous processes); review of evaluations for previous work done; and submittal of key information such as Provincial workers' compensation experience rating, safety and environmental policies, safety programs, trade certifications and hazard training programs, specific procedures etc.
Contractual agreements should have an addendum devoted to health, safety and the environment. This would include the organization's safety and environmental guidelines or standards. Discipline and corrective action must be clearly stipulated. Designation of various roles should also be clearly identified, such as that of Constructor or Prime Contractor for larger capital projects.
Hazard assessments are carried out as they relate to high risk or non-routine tasks/activities. Procedures should be established by the contractor to control hazards to both contractors' workers and occupants of existing facilities/work areas, and to ensure equipment, materials, processes, and, particularly, the general public are not affected.
Orientation meetings should be held with the contractor prior to the execution of the work. This orientation would provide the contractor management with the specific requirements for the work assignment/workplace. Particular concerns/interferences can then be resolved prior to work.
All project-specific documents (training records, equipment certification, testing, etc.) should be submitted and reviewed at this time. Each contractor worker should also receive an orientation to the workplace, work assignment, hazards and procedures.
Coordination meetings should be held with the contractor(s) often enough to ensure adequate pre-planning of work activities and possible interferences or overlaps. The work activities/workplace should also be inspected to identify and correct any deficiencies.
An evaluation should be conducted for every contractor upon final completion of work. This should identify their performance in health, safety and environment and may be consolidated with other assessments of their production and quality performance. The evaluation process should also incorporate measures to ensure the structure, equipment, machinery or process meets applicable codes and standards and is signed off by competent workers (and Joint Health and Safety Committee members) for return-to-service.
Al Aiello is with The TRH Group, consultants in occupational and environmental health and safety, workers' compensation and loss control management. For more information, see the web site at www.trh-group.com.
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