Those of us living within the realm of Process Safety Management know all too well the difficulty of controlling contractor work activities to a level that we are confident they are not increasing our process risks beyond our acceptable levels. Many contractors are offended by the fact that many PSM programs have multiple layers of protection regarding their presence and work practices in, on, or even adjacent to a process that contains a Highly Hazardous Chemical (or, as EPA refers to them… Extremely Hazardous Substances).
First, let’s examine why these multiple layers of protection for contractor work are necessary and not a “personal” reflection on any one individual or contractor company. First and foremost, our contractors are at a MAJOR disadvantage when remembering all the safe work practices, emergency procedures, etc. If we step back and think about this, imagine the contractor we trained in January, and now it is August.
This company’s contractors have worked at dozens of other facilities with extensive safety and emergency training. Do we think that when they return to our facility eight months later and dozens of safety orientations later, they will recall all of our emergency numbers, evacuation points, site alarms, safe work practice requirements, etc.? It is hard enough to have our employees be able to recall this, and they are at the facility at least five days a week, 50 weeks a year, to imagine that a visiting contractor who sat through our orientation eight months ago will accurately recall all they need to know. I hope we can all agree that this situation INCREASES RISKS and is NOT a reflection on any contractor but a reflection of our weakness in managing their presence and work. Thus, what can we do to better control these risks?
A contractor work permit will provide this critical safety and emergency information to every contractor working on-site daily. It acts as a DAILY REFRESHER training of the core safety and emergency information they need to know to work safely and respond properly should an emergency arise during their time on site. Keep in mind not only will this group of contractors work at different facilities that all have different safety and emergency requirements, but they may also be working in different processes within our own facility that have different hazards and different responses to process conditions. This is just piling on the information that they expect them to recall in a very timely manner. I personally came to the conclusion years ago that I would not be able to recall all of this information if I traveled to different facilities weekly, and if I could not do it, then it is not fair for me to expect more from anyone else – thus it was an easy decision for me to come to decide that this contractor work permit is a MUST HAVE, not a “Best Practice.”
The other advantage this permit will bring is that it will meet the regulatory requirements for OSHA’s PSM and EPA’s RMP to control non-essential personnel entry (and exit) to a process area. Now, remember that this permit will aid in improving safety for high-risk areas even if the process/ area does not fit into an OSHA/EPA “covered process.” However, in terms of compliance, this permit and the associated program will act as our “safe work practice” to control the entry and exit into and out of a covered process. I know the standard(s) do not mention controlling the “exiting” of non-essential personnel from your covered process, but this practice has HUGE benefits. First, in the event of an incident within the process, we will have 100% accountability of ALL personnel. When a facility conducts its headcount at its muster stations, and a contractor is missing, would it not save critical time if we could pull copies of the active contractor work permits and determine the process/area of the facility where he/she was assigned to work? Second, most operators and supervisors have received a not so rather pleasant confrontation with management about housekeeping in their process area, only to know that it was that “blasted contractor who did not pick up after their work”. Your process – Your responsibility! Having a “check-out” system for the contractors to exit the process allows for the personnel responsible for the process conditions to hold their contractors responsible for their housekeeping. It also aids the contractor company when they get blamed for all things wrong – they can point to the checkout system and state… “the operator checked us out, so it was not anything we did (or did not do).” But getting back to the control over entry into the process area, this permitting process ensures that ONLY trained contractors work in a process area and the permit acts as daily refresher training of all the critical safety and emergency response information those contractor workers must know to work safely and respond to emergency situations properly and timely.
Lastly, we can use this work permit as an audit form and evaluation tool regarding the contractor’s performance. Any safe work practice implemented SHOULD have an audit element embedded or at least a separate safe work practice audit procedure to ensure that critical safe work practices are being audited on a routine basis. Often, the workers being audited complain that they were unaware of “what the auditor expected of them”; using this work permit that each contractor employee signed eliminates this “unknown” excuse. Audit their work against the issued work permit, and all is fair. (e.g., if the permit requires hearing protection and half are not wearing it – the contractor company has no one to blame but their own management and supervision for not enforcing the work permit requirements) If you have ever done a field audit and get the excuse “no one told us” as the answer – the work permit eliminates this. Of course, plant personnel who issue the permits are ALSO AUDITED, and just like the contractor must respond to deficiencies noted in the audit, any weaknesses found in issuing the permit MUST BE addressed as well. I prefer to document my permit audits directly on the permit(s), using a colored highlighter to identify any deficiencies and then noting the details directly on the back of the permit. By the way, once a quarter, the results of these audits need to be trended to address any adverse trends. Frequently, in these trending exercises, we will find a common deficiency that turns out to be a “training issue” for our own employees as they do not understand what a specific requirement on the permit means. A quick refresher training in a safety talk the next week, and we have corrected our negative trend – BEFORE it results in an incident! When it comes time to do our annual contractors review, we now have FIRST-HAND data of contractors working on our site. And yes, I have, on more than one occasion, found the nice, shiny, glossy contractor response to our evaluation process did not match the work practices demonstrated in the field by the contractor crew. Regardless of their EMR, DART rate, and how nice and neat their safety manual is, I now have first-hand data that says this contractor is too risky to have in, on, or adjacent to one of my high-hazard areas.
We have just gone full circle on a contractor management system, using our contractor work permit to aid in the control of the risks posed by personnel doing high-risk work in high-hazard areas, as well as providing us with quantitative data that is ACCURATE and FAIR so that we may better evaluate the contractor’s actual work practices.