What is the difference between OSHA Compliance and Contractor Management & Qualification? For the past 10+ years I have assisted clients with their contractor pre-qualification and maintenance on the various contractor management and qualification websites (i.e., ISNetworld, Veriforce, etc.). Over time, I have come to realize that there is an unfortunate misconception that many contractor companies possess. The Management of these companies often equate a client “A” letter grade or “Green” status on a contractor management and qualification website with being OSHA compliant, and with having a safe organization. This, unfortunately, is not necessarily always the case.
A client “A” letter grade or “Green” status is generally achieved by having written procedures and training based upon the type of work type or tasks that a contractor company will be providing for that specific client. For example, let’s consider a Contractor Company that has a fleet of vacuum trucks, tankers, roll-off trucks and frac tanks. In addition to CDL drivers, this company has a large garage on its property with diesel mechanics, a maintenance shop, and a building with offices for about 20 individuals in management to address dispatch, human resources, accounting, purchasing, etc. This company provides hazardous and non-hazardous waste hauling for a client operator in the oil and gas industry. Some of the typical safety procedure and training requirements that a contractor management website would require of that waste hauling company might be hazard communication, fire protection and prevention, emergency actions plan, defensive driving and vehicle safety, heat illness prevention, spill prevention and response, backing and spotting, stop work authority, H2S safety, etc. Provided the Contractor Company has these written procedures and provides training on those written procedures, along with good lagging indicators and the correct amount of insurance, the Contractor Company can generally achieve an “A” letter grade or “Green” status.
Since that Contractor Company does not perform any Permit Required Confined Space Entry tasks on the well site for that oil and gas operator, there would be no requirement for a confined space entry procedure with training to achieve an “A” letter grade or “Green” status. The reason is because it is not a service provided to the client that manages this Contractor Company’s qualifications through one of the contractor management and qualification websites. This is, in spite of the fact that the Contractor Company workers enter their own vacuum trucks, tankers and frac tanks on their own company property to perform maintenance and cleaning out of those tanks. Just because a procedure/training is not required by a client to achieve an “A” letter grade or “Green” status, does not mean that it isn’t required by OSHA and necessary for the safety of the company’s workers. However, Management of that Contractor Company will in some (many?) cases, believe that they do not need to have Confined Space Entry procedures/training for their workers because XYZ Operator doesn’t require it of them on the contractor management and qualification website. Not only is this not in compliance with OSHA it is also dangerous for the workers.
If a company has a forklift at their facility for material handling but doesn’t use it as part of the job tasks performed for a client, the contractor management website will not “require” a forklift program and training, but OSHA does. A company may not be an electrical contractor providing wiring on a new construction site for a client but that does not mean that their employees don’t do maintenance work and need to control hazardous energy through lockout/tagout procedures. A company may only provide excavating services for clients but utilize power tools or perform welding and cutting to maintain their own equipment. Contractor companies may utilize their workers in the “slow season” to do painting, roofing, or other building maintenance. These tasks may have nothing to do with the services that the contractor provides to clients and therefore the contractor management website does not “require” the applicable safety procedures and training to achieve an “A” letter grade or “Green” status. However, these “slow season” tasks could require fall protection, respiratory protection, aerial lift, and other safety procedures that would be necessary for OSHA compliance. Safety training for applicable workers regarding how to identify hazards and how the company is going to safely implement these procedures would also be required for OSHA compliance.
Complying with the applicable OSHA regulations is based on an assessment of all the possible hazards in terms of a company’s workplace, equipment, materials, and workers. Not just the work type(s) that are selected on a Contractor Management & Qualifications website. Written procedures, inspections, incident investigations, industrial hygiene monitoring, safety training that is specific to that organization, medical monitoring, and recordkeeping requirements are all part of OSHA compliance as well as being part of an overall safety and health management system.
Keep in mind that Compliance with OSHA regulations is just the first step in managing safety in an organization. OSHA standards are a minimum requirement, and they often don’t address critical safety issues specific to your company. Simply being OSHA Compliant means that if you had to give your company an overall Safety Grade, you’d give it a grade of “C”. Passable but not the best your company can do. If your company is managing safety by simply meeting contractor management and qualification website requirements, in most cases, your company would not actually be receiving a passing grade for managing safety, regardless of the Green status on the website.
For more information and/or assistance, contact:
Melissa Heike MS, CSP
RJR Safety Inc.