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Anneliese1973  
#1 Posted : 26 July 2016 15:27:50(UTC)
Rank: Forum user
Anneliese1973

Hi
I'm new to H&S and learning as I go on. I'm trying to get my head around the subject of contractors and what documentation is needed from/for them.
In the past we've obtained (without any regularity) the odd method stmt, H&S policy, risk assessment from Contractors. We have a general Visitors & Contractors RA that's reviewed annually, which states that we obtain method statements, risk assessment & policy docs from contractors.

Most of our contractors are local companies (Landscape gardeners, window cleaners, aircon, electricians) carrying out regular maintenance; some of which may be less than 5 employees.

We've recently received an NCR at external audit, because we had 2 contractors working on site at the time of the audit, whom we'd not completed an RA for, nor had we asked them to provide their H&S paperwork.

I'm trying to read up on this, so I can find a way to address this in future. Should I be working with the contractor every time they visit, to put together a risk assessment based on the work they're going to be carrying out? - Sometimes I'm not even aware they've been asked to come out. Plus some of the companies have already said they won't provide paperwork..

Can someone give me some advice on how I get a balance here between overkill on paperwork that's not needed and what we're currently (not) doing?
Many Thanks
PH2  
#2 Posted : 26 July 2016 15:44:51(UTC)
Rank: Super forum user
PH2

Hi,
I recommend that you download and read the HSE booklet "INDG 368 - Use of contractors". Keeping paperwork on contractors is a thankless job until something goes wrong.

Insurers sometimes provide their own requirements for clients employing contractors: it might be with checking with them , after reading the HSE guidance.


PH2
FG  
#3 Posted : 26 July 2016 16:01:17(UTC)
Rank: Forum user
FG

Hi Anneliese,

As a general rule - all contractors should submit a risk assessment for the task they will perform without exception.

The size and scale of it however, will vary. i.e. a window cleaner won't have a very big one compared to someone servicing a complex machine for example. Method statements will also be helpful but it will be down to yourselves as to whether you deem it necessary in all cases.

The idea is that your own risk assessments should adequately cover the contractor for any pre-existing hazards in their area of work. So make sure this is captured in some form of induction / familiarisation exercise.

Most places will operate permit to work systems on top of this for activities deemed particularly hazardous, this normally includes but is not limited to: Works at height, hot work, confined space entry, live electrical working, excavations, work with ionising radiation etc.

Finally there are some instances where competency must be checked. Gas Safe registered workers is an absolute must for example for any Boilers including domestic. Other competencies that are normally checked are IPAF for work involving MEWPS (a cherry picker for example) or PASMA for mobile scaffold towers. The latter examples are not strict legal requirements and other courses are available, but they are normally considered the industry standard by many organisations. Unfortunately there isn't a cheat sheet (at least that I'm aware of) that lists all these competencies but most people learn as they go along.

This is complicated I know, so most places will train and nominate individuals responsible for dealing with contractors and enforcing the above requirements. Hope this helps!
jodieclark1510  
#4 Posted : 26 July 2016 16:08:42(UTC)
Rank: Super forum user
jodieclark1510

You could also have a look at PAS 91;2013 as well which you could create your own pre-qualification questionnaire to make sure all the bases you need are covered. We have an approved contractors list which documents all contractors and what documentation they have provided, including evidences of health and safety policies, signing up to terms and conditions, asbestos awareness training evidence, insurances etc.
Centurion  
#5 Posted : 26 July 2016 16:09:56(UTC)
Rank: Forum user
Centurion

Hi,
You say your are new to h&s and learning as you go.
If you are engaging contractors and do not know what you need from them then you are placing yourself in a very precarious position.
You need to be careful if you have been placed in this position by an employer who has a poor regard for h&s management.
I would advise you to contact a local consultant from the OSHCR to assist you in bringing you up to the necessary levels of awareness.
Your employer will have to pay the costs.
You need to make your employer fully aware of your levels of knowledge and abilities so that they can support you accordingly.
Cheers
Andy
Anneliese1973  
#6 Posted : 26 July 2016 17:22:05(UTC)
Rank: Forum user
Anneliese1973

Hi Andy

I appreciate & understand your concern, but just to put your mind at rest; I am not the "competent person" in the business, that's my Boss.
I am learning the role, but so far my experience has been only what I've learnt from my Boss as we go along and I'm having to research things myself tbh. I am due to do my NEBOSH Gen Cert later this year, which I'm hoping will improve my knowledge.
Thanks
Centurion  
#7 Posted : 27 July 2016 11:46:01(UTC)
Rank: Forum user
Centurion

Hi Anneliese,
If you would like to email me with a general overview of your company i.e. it's type of work, number of employees, size of the site it occupies etc., then I'll provide you with some relevant information that you need to be aware of.
Cheers
Andy
andymccluskey@btinternet.com
RayRapp  
#8 Posted : 27 July 2016 11:59:24(UTC)
Rank: Super forum user
RayRapp

Anniliese

The overarching principle is the controls should be proprotionate to risks. I suggest from a client's perspective you should focus on the risks to your organisation and staff. Most contractors are more than able to manage themeselves, you are not required to closely surpervise or monitor them.

Incidentally, why have you been given these h&s duties when, with respect, it is obvious from your postings you have none or very little h&s training? People within your organisation should be giving you the information or referring you to company policies.
stevie40  
#9 Posted : 27 July 2016 17:43:48(UTC)
Rank: Super forum user
stevie40

I did an audit last week and pulled up a client on contractor management (wasn't you was it Annaliese?).

That instance involved work at height above a public entrance to a leisure complex. Contractor had used scaffold and barriers one day, a simple ladder with no barriers the next.

To me that ticked several boxes - height, public access and contractors not sticking to their RAMS.

FG offers some good guidance but at the same time, remember the info sharing is a two way street. Contractors can reasonably expect to be informed of dangers on your site such as asbestos, hazardous chemicals and processes.

The trickier ones to manage are the emergency machinery break down type incidents and contractors working on your site for a staff member. I'm thinking here about motor mechanics and windscreen fitters working on a staff members vehicle in the car park. Generally low risk but not if they pull out a portable welding set next to your flour silo or waste skip.

Its an interesting project to get stuck into and when you do the NEBOSH cert you will gain a greater understanding for the legal implications.
aiden  
#10 Posted : 28 July 2016 22:43:38(UTC)
Rank: Forum user
aiden

I was that soldier!
A basic approach would be along the following lines;
1. Draw up a site induction for all contractors (Do's and Don't on site e.g. where to sign in, smoke, park vehicles, fire assembly points,canteen, WC, Report any accidents, etc). Every contractor should do this annually, draw up a short multiple "test of understanding" - based on the Induction content.
2. Insist on a suitable and sufficient risk assessment (RA), from every contractor, bespoke to the task in hand. Useful to have a Permit to Work system so you can issue an Acceptance of their RA, but failing that insist as a minimum on the RA . In time you could broaden this out to a RA & Method Statement(MS) - step by step from a safety perspective of doing the task.
3. Occasionally check the task the contractors are doing, are they following the same approach they said they would do? Check contractor housekeeping during and at end of task.
4. Have a short say at a Monthly frequency, Contractors Meeting, with all main foreperson/supervisors - cover off EHS, Issues discovered on housekeeping inspections, shortcomings with RA etc. Any accidents, near misses etc. Sign in required for each attendeefor each of these,
5. Say annually have a one on one review of EHS for that individual contractor company.

You may not appreciate much of the above, however all important stuff. Contractors are a high risk group!

Agree though with many of the previous comments, after completing the Cert course your own breadth and depth on understanding of this area will expand.
jde  
#11 Posted : 29 July 2016 11:00:25(UTC)
Rank: Forum user
jde

1. draw up a list of prefered contractors
2. send them all a "contractors evaluation form" to ascertain their status in regards to Insurances, health and safety, whether plc, ltd llp or 1 man bands; membership of SSIP etc
3. Obtain sample RAMS from them and enquire if they have their own safety advisors or access to safety advice.
4. maintain the database as required - adding to or deleting contractors who are non compliant
5. provide your site rules that must be adhered to and get confirmation signatures that they will comply.
SJP  
#12 Posted : 29 July 2016 11:21:52(UTC)
Rank: Forum user
SJP

Plus some of the companies have already said they won't provide paperwork..

Some paperwork may be a legal requirement (Risk Assessments if employing over 5 persons), and if they will not supply, then it's time to look for a new contractor - easier said than done especially if they are 'favourites' with the management.
Xavier123  
#13 Posted : 29 July 2016 11:23:46(UTC)
Rank: Super forum user
Xavier123

With regard to collecting paperwork, it's worthwhile thinking about who you're collecting it for.

The criminal law is generally reasonable and proportionate. The law wouldn't generally expect a one man band to provide you with a documented evaluation of the risks - it would still require you to be coordinating and communicating with them though and exercise a degree of control.

However, an insurance company might take a different view regarding your ability to demonstrate cooperation and communication etc. in the event of an accident - if you didn't have a bit of paper to prove it happened. Similarly, for external/internal audit, it's much easier to prove an event if there is some record to assist.


Be careful about how you break your contractors down into groups though. For example, window cleaners could be expected to work at height and the level of risk will vary based upon the building, window, facade and specifics of the task - NOT on the description of the profession. e.g. cleaning a ground floor window vs hanging out of a sixth floor sash window - to draw an extreme comparison. That adds a whole extra layer to an already complicated, thankless but essential task of contractor management.
sadlass  
#14 Posted : 29 July 2016 18:47:46(UTC)
Rank: Forum user
sadlass

Client duties: (HSWA).
Do not create a risk to contractor (s3) and ensure H&S of own workers (s2).
Key actions to achieve:
1) select competent contractor (protects your staff)
2) Inform contractor of your special known hazards, especially ones they may not be familiar with.
3) Review own RA to check if conflict or additional measures needed by you, in your undertaking.

Contractor duties:
Ensure H&S of own workers (s2). Do not create a risk to others (eg client staff - s3) from your undertaking of being a builder, electrician, surveyor, window cleaner etc.
Key actions to achieve:
a) Fulfill all legal duties as employer - be competent, in essence
b) From client information, ensure adequate RCMs (via RA). Monitoring H&S compliance is also a key part of that.

Method statement may be simplest approach to combine a contractor RA with client's own site hazards / rules, but there is no legal requirement or standard.

Many large clients now seem to have a complete raft of their own rules, regardless of and beyond the legal requirements and then impose these on contractors. That means contractors just have to tick all the client boxes, and not take ownership of H&S decisions, even though they remain an employer. They will be told what to do and how to record it on what form. Hmmm.

If you run a library, the contractor brings all the risks to you - and you probably have to trust their expertise. So even if an electrician shows you a 'risk assessment' what are you going to do with it? A discussion and agreement on the safety aspects of 'interface' of contractor and staff / customers is the most practical and informative use of time. Minute it.

If you run an LPG plant, you own a significant yet hazardous asset, into which you are introducing an unaware builder or welder. You would want to take more of an interest, and dictate clear rules, otherwise the contractor, your staff, and possibly the public at large may be massively at risk.

So horses for courses. As this thread shows there are many practical systems and processes out there which can be adopted, but understanding the principles will make sense of these and what will work best for your company.

www.hse.gov.uk/pubns/indg368.pdf is a good starting point, at 7 pages.
HSG159 Managing contractors is a guide for small to medium companies in the chemical industry, but is also a good learning resource for anyone.

S2 duty is to ensure the HS&W of your employees.
S3 duty is not to create risk to others NOT your employees.
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