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SLC 2018 Q&A: Making the Case for Contractor Management

Sept. 14, 2018
A compliance-only approach to contractor management limits the success of a host employer's health and safety program.

Small- to medium-sized businesses face a myriad of challenges when it comes to finding and utilizing safety resources.

As a result, the National Safety Council (NSC) launched “The Journey to Safety Excellence” initiative in 2014 in an effort to provide free assessment tools and resource information for businesses with smaller budgets.

One part of this campaign involved an independent case study for contractor management in conjunction with BROWZ, a third-party qualification company.

Patrick Cunningham, BROWZ safety and auditing director, will speak about the study and contractor management along with Amy Harper, NSC director of workplace safety initiatives at the Safety Leadership Conference in Louisville, Nov. 6-8.

EHS Today recently conducted a Q&A with Cunningham about the session, titled "Making the Case for Contractor Management," which is part of the Safety and Risk Management track.

Register for the 2018 Safety Leadership Conference today so you don't miss this presentation!

EHS Today: Can you offer us a description of your presentation and how it relates to safety leadership?

Patrick Cunningham: The issue of managing contractor EHS performance is an ongoing concern among organizations of all industries, typically because contractors may be performing non-routine work at sites that are not directly supervised by an EHS manager, or any manager at all. The Campbell Institute has previously detailed a research study which identified five crucial stages of the contractor management lifecycle—prequalification, pre-job task and risk assessment, contractor training and orientation, job monitoring, and post-job evaluation (with contractor requalification). While much of the literature on managing contractor safety speaks to how worker safety is affected by the outsourcing of work to contractors, not much (or little) attention is paid to managing contractor safety, and outlining best practices. There is a lack of research to validate which of these best practices impact safety outcomes and to what extent.

The National Safety Council (NSC) independently analyzed a contractor database provided by BROWZ, LLC (a third-party prequalification company) to compare the performance of contractors in that database to the national performance of companies as reported by the Bureau of Labor Statistics from 2007 to 2015. Traditional outcome metrics for safety performance were used and included a study of total recordable rate (TRR), days away, restricted or transferred (DART) Rate, and lost work day rate (LWR). Eight unique industry analyses were performed. This presentation will summarize the results of five hypotheses tested in this study, explore the safety benefits of implementing a third-party contractor management system and the effect on participating contractors.

EHS Today: Why is the topic of your presentation of interest to you and why is it important to SLC attendees?

Cunningham: During my career, I have worked as a contractor, host employer managing contractors, and now work within the contractor management industry. I have been 'in the shoes’ of these stakeholders and have learned from success and failure. I would like to share what I’ve learned, and help others learn how to better address the host employer/contractor partnership. I am excited about recent efforts from OSHA, and other organizations, in publishing guidelines on how to implement sustainable safety and health (SH) programs – which includes the host employer/contractor partnership. 

EHS Today: Please share an example of a personal or professional experience you’ve had related to safety leadership or the topic of your presentation.

Cunningham: My belief that a compliance-alone approach to safety limits the potential for SH program success, was cemented in a very condensed and intensive setting. I was tasked by a well-known host employer to audit the SH of a contractor in which they used but had witnessed poor job-site safety performance. We reached an agreement with the host employer to conduct two sets of audit protocols of this contractor. The audits would be conducted at the contractor’s headquarters. Adding pressure to day, the host said they would accompany us for the contractor audit. One of the individuals from the host employer happened to be an auditor instructor – no pressure, right?

The first audit was a very detailed compliance audit that incorporated Federal OSHA standards, State OSHA standards, to two industry-specific consensus standards. The contractor passed the compliance audit with an excellent score. During the compliance audit, I happened to look across the table and saw a perplexed look on the host employer auditing instructor. I could just envision that what he knew of the contractor’s site performance, did not match-up with how well the contractor was performing on the compliance audit (cognitive dissonance).

When we switched audit protocols to the SH management systems assessment, it became quite clear that the contractor had very little depth within their safety program. The contractor did not invest time into things such as employee engagement, leadership training, hazard analysis and prevention control.  I looked over again at the auditing instructor, and he had what would be best described as a look of self-assurance. What he thought he knew about this contractor, was now validated in the second audit protocol.

I’ve heard before that the best way to learn something is to train others. It was during this audit experience I knew I made a believer of the host employer and solidified my conviction that if as a profession we only focus on matters of compliance (what), we will limit program growth potential by not showing others how to implement sustainable and integrated SH programs.

EHS Today: What are the takeaways you hope to leave with attendees?

Cunningham: I would like for them to learn that while there is no single source regulation from OSHA outlining their expectations for host employers to screen their contractors, OSHA’s expectations can be discovered across various regulations and publications. The second thing I’d like the audience to learn is that for those host employers that do a thorough and sincere assessment of their contractors; they will be rewarded with safer performing contractors who have an appetite to continually improve their SH programs.

EHS Today: What do you think are some of the most pressing EHS and risk management issues facing corporate leaders and safety professionals in 2018 and beyond?

Cunningham: As a profession, we need to provide vision to corporate leaders on ways to evolve their current SH improvement efforts for contractor risk management. Too many corporations have not transferred what they’ve learned about implementing employee SH, to their efforts in managing contractor safety. The sophistication of host employer contractor safety management lags significantly from their efforts in managing their own employees.

Unfortunately, contractor safety management is limited to compliance-alone efforts. Corporations know they wouldn’t get the results they want in employee safety, if they didn’t incorporate focus areas such as: employee engagement, leadership training, hazard prevention and control, program evaluation, etc. So, why don’t they incorporate these areas within their contractor management programs?

I believe this lag in program approach has to do with three factors:

  1. not knowing how to implement a SH management systems approach to contractor management;
  2. not believing their contractors would be ready to make the program shift
  3. fear of liability for directing contractors on how to better implement their safety programs.   

EHS Today: How will this session help attendees be a better resource for their employees and company?

Cunningham: By investing in attending a national SH conference, the audience has demonstrated a desire to learn new ways to implement safety/health within their own work environments. Our desire for the audience who attends the session Making the Case for Contractor Management, is that they visualize a path to improve their current contractor management efforts, and more deeply engage their contractor partners in the process.  

(EHS Today's 2018 Safety Leadership Conference and America’s Safest Companies Award Program will take place Nov. 6-8 in Louisville, KY at the Hyatt Regency Louisville. This event is designed to share best leadership, risk management, compliance and safety practices with EHS professionals hoping to achieve world-class safety at their companies. The conference features 24 sessions across four performance tracks; Safety & Risk Management, Compliance, Construction and Safety Technology.)

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