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Contractors on Campus. Tony Rey, Senior Vice President Marsh Cindy Smail, Loss Control Consultant Marsh Risk Consulting. SERIOUS EVENTS IN HIGHER EDUCATION – 2016 Marsh Risk Consulting. Why Contractor Safety?. Contractors are on campus often!
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Contractors on Campus Tony Rey, Senior Vice President Marsh Cindy Smail, Loss Control ConsultantMarsh Risk Consulting
SERIOUS EVENTS IN HIGHER EDUCATION – 2016Marsh Risk Consulting
Why Contractor Safety? • Contractors are on campus often! • Outside contractors pose serious risks to your workers, property, and the facility operations • Some laws require contractor safety practices • Safety performance is an indicator of work quality • It’s a good business practice
Today’s Focus 1. Safety Planning 2. OSHA 3. Safety Pre-qualification 4. Contractor Safety Orientation 5. Work Area Controls 6. Hazardous Work Permits 7. Supervision 8. Insurance
OSHA Construction Safety Standards The Occupational Safety and Health Administration (OSHA) requires contractors to have a safety program available at the work site covering the following: • Designation of qualified safety person • Safety instructions for employees regarding the tools and equipment they will use • Self-inspection program • Hazard recognition instructions • Chemical safety details • Confined space procedures The program will be available at the work site.
Avoid Multi-Employer Duty Issues More than one employer can be cited by OSHA on construction sites. As the owner you need to be sure you did not: • Create the hazard • Expose your employees to the hazard • Assume responsibility for correcting the hazard • Control employees on the site
OSHA’s Stance on “Host Employers” and Contractors When employees of an outside contractor come into your workplace, both your organization (what the OSHA calls the “host” employer) and the contractor share responsibility for the safety of the contractor’s employees. The dividing line between areas of responsibility is not always clear, but consider the following “rule of thumb” as a starting point: • The contractor is responsible for making sure that its employees know how to do their jobs safety. • The host employer is responsible for informing the contractor of any hazardous conditions that are specific to the host’s workplace and stipulating any special controls or work practices that the contractor must follow to protect all workers.
Safety Pre-qualification - Loss History • Loss History Sources: • Injury/illness rates compared to others in industry (OSHA logs) • Claims experience (workers’ compensation, auto liability, general liability, etc.) • Workers’ compensation experience MOD • Look for trends and key indicators • Establish minimum safety performance standards • Workers’ Compensation MOD less than 1.0 • OSHA incident/severity rate less below average for Standard Industry Classification (SIC)
Safety Pre-qualification - Safety Reference Checks Reference checks should consider: • Similar jobs - value and scope of work • Safety compliance/culture • Safety experience
Safety Pre-qualification - Prior History on Your Campus • Contractor’s compliance to their own safety requirements • Contractor's compliance to your campus safety requirements • Working relationship with campus safety and security teams • Adherence to safety paperwork needed • PPE use observed • Sanitation practices
Pre-Qualification – Contractor’s Safety Program Contractors safety program review: • Program in writing • Set schedule for toolbox meetings • Self-inspection program in place • Training plan – for orientation and ongoing training of new workers and foreman • Responsibilities are assigned • Enforcement policy • Traffic control • Emergency procedures • Accident investigation • High hazard tasks determined and addressed • Fire protection • Site safety and security • Sub-contractor requirements Resume of site safety person
Pre-job Meeting Safety Items • Agree upon job organization and procedures • General safety rules, university policies are communicated • High hazard areas are discussed • Control measures are reviewed • Other safety paperwork - inspections, accident procedures, disciplinary measures, etc. maintained • Site safety plans by contractors are reviewed
Contractor Safety Orientation • Contractor employees should know: • University’s safety program/rules • Reasons for dismissal from project • Hazards associated with operations • Emergency procedures • Orientation should be documented • Orientation is not a substitute for training
Work Area Controls • Contractor employee parking • Check-in procedures • Designation of work areas - include lunch, break and toilet areas as well as barricadesand signs used • Confirm material storage and office areas • Establish work shifts/hours
Hazardous Work Permits What to permit? Hot work, confined space, lockout/tagout, elevated work Permit process…
Other Safety Practices • Do not lend tools or equipment • Make safety costs visible in bids • Do not undertake supervision or direction of contractor’s employees. If there are issues, take them to contractor leadership • Maintain documentation such as a daily log, letters, safety program manuals, accident reports, meeting minutes, etc. • Complete periodic and final evaluation reports, review them in a scheduled sit-down meetings with the contractor
Supervision of Contractors Keeping Track… • Perform site evaluations whenever university personnel create or participate in construction activities • Participate in accident investigations involving university personnel, students and/or property • Require the construction manager or prime contractor to advise you in writing of all incidents and injuries involving their personnel and or operations
M.U.S.I.C. Coverage Insurance
Resources • OSHA Establishment Search - https://www.osha.gov/pls/imis/establishment.html • OSHA Standard Industry Classification List for Construction - https://www.osha.gov/pls/imis/sicsearch.html?p_sic=&p_search=construction • OSHA Worker Safety Series on Construction - https://www.osha.gov/Publications/OSHA3252/3252.html • National Safety Council Keeping Contractors Safe - http://www.nsc.org/Measure/Pages/contractorsafety.aspx • Contractor Safety and Environmental Guidebook from Georgetown University - https://safety.georgetown.edu/contractorguidebook2 • Construction Safety Guidelines from the University of Michigan- http://ehs.umich.edu/wp-content/uploads/sites/37/2016/08/ContractorSafetyGuidelines.pdf
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