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Alf999  
#1 Posted : 15 November 2013 21:57:36(UTC)
Rank: Forum user
Alf999

I work in a high risk heavy engineering environment. We contract in between 6 - 10 companies at any given time to work with us - their work represents perhaps 40% of the work we do.

Recently we've received some "expert" advice that we should be "checking and signing off" every RA they bring to site. I am absolutely clear on the fact that H&S Obligations cannot be devolved via contract, however I feel this all encompassing approach is way over the top. In my view it could lead to our contractors actually getting complacent when deciding if their controls are adequate because we, as their Client,will be vetting everything for them. Indeed it could even be argued that by taking this route we might be inheriting extra liabilities that we don't currently have.

I understand that it will be difficult to comment on our specific case given the lack of detail above. However, I'd be very interested in fellow members views in general but even more so in learning how far your company goes in this regard?
Ron Hunter  
#2 Posted : 15 November 2013 22:50:13(UTC)
Rank: Super forum user
Ron Hunter

"checking and signing off" every RA they bring to site would be inefficient, unnecessary, meddlesome, confusing and possibly counter-productive.

Assessment of competency starts at Stage 1 pqq & stage 2 tender evaluation.
Thereafter the client can monitor by sample - best done in cooperation with the contractor AND by writing into the contract a requirement for the contractor to regularly provide you with his own performance reports, audits etc.
All this counts towards Stage 4 - evaluation at review, looking towards reappointment.

Such satisfactory systems will give the client sufficient confidence and exercise due diligence.
The "expert" advice you reference suggests uncertainty, lack of confidence and a leaning towards an overly bureaucratic approach.

I qualify all of the above where the contractor is working in close concert with your own employees. That's an entirely different kettle of fish, where there is often a requirement for closer scrutiny, document and systems sharing etc. on a task-by-task basis. Perhaps your expert is offering advice on this other scenario.
RayRapp  
#3 Posted : 16 November 2013 07:28:53(UTC)
Rank: Super forum user
RayRapp

Alf, I agree with Ron on this one. Having engaged competent sub-contractors it is not necessary to check all their documentation and a sample check should suffice. The only time I would depart from that is where the work may be particularly complex, hazardous and/or where there is an interface with your own staff, in which case you may wish to provide some element of supervision as well.

The problem with external 'expert' advice is the consultant tends to err on the safe side. Covering their back of course, but not too helpful for those who have to implement any recommendations.

Ray
aiden  
#4 Posted : 16 November 2013 08:10:24(UTC)
Rank: Forum user
aiden

To me it would depend on your Safe System of Work (SSOW). If this was a suitable RA/MS followed by issuing a Permit to Work (PTW), then I would look at the work area, talk to the person supplying the RA/MS before issuing and signing a PTW.
Rationale; you say you work in a high risk heavy engineering environment and contractors regardless of competency may not be as aware of e.g. other work activity nearby which you as a permit issue would be.
How will you control working at heights, hot work, confined space, trench activity, use of a crane etc without having an oversight by say a PTW system?
Whay not go down the route for all low risk routine tasks supported by a RA/MS can be completed under an Standard Operating Practice, whilst all high risk tasks continue under a PTW.
Other thoughts;
Display all active permits on say a plan of the site so all contracting companies can see what other activity is going on in parallel with their activity?
Use of a Contractor Management System to reduce the paper work load, although the permits still have to printed and signed.
Ask your insurance company re their thoughts.
What do peer companies do?
What does say a best in class heavy engineering company do?

If you down the route you are proposing I suspect you will have to do say more E,H&S inspections to ensure contractors are working safely, taking less responsibility from them and putting additional responsibility on your company

If you have an accident what will you be happy with if a HSE inspector comes calling following a serious accident and you end up in court, do you feel your system would stand up to scrutiny?

westonphil  
#5 Posted : 16 November 2013 22:29:51(UTC)
Rank: Super forum user
westonphil

The problem is of course if there is an accident then the relevant risk assessments will be checked in minute detail by the relevant people and if they are found not to be suitable and sufficient they will not necessarily understand that we did not check every single risk assessment due to workload involved. I have had the HSE inspect two significant contractors accidents, which of course the RA's did not prevent, and on both occasions they said they could not fault the RA's and that we had met our responsibilities, as the company using the contractor. I ask myself how things would have turned out had those risk assessments not been suitable and sufficient! I think however one approach does not fit all and you need to play it the way you think best; if you can show your approach is safe so far as is reasonably practicable then you should be fine with your approach.

Regards.
firesafety101  
#6 Posted : 18 November 2013 11:28:49(UTC)
Rank: Super forum user
firesafety101

Alf999 asks a question but does not state whether it is about CDM or not?

I believe CDM has requirements and duties for the PC but without CDM things are a little "looser".

If someone can provide a specific duty to check the RA/MS I would appreciate it.

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