Recently the SAFTENG team was hired to provide some safety services during a turn-around/shutdown at a PSM/RMP facility . While out and about we came across a very interesting find… a speciality contractor with facial hair. Now this was not just any speciality contractor and the reason we were so surprised was the facility had, what we thought, a very rigorous contractor safety program. The speciality contractor was the Confined Space Rescue Team… with facial hair…
These guys made it through several layers of safety to get where they were. They were approved through the contractor safety evaluation process, which by the way is managed by a 3rd party contractor which utilizes an on-line evaluation. The contractors then attended the site orientation, which is managed by a 3rd party security firm. They then met with a member of the facility safety team to discuss entry schedules. They then would meet with the entry supervisor of each entry they covered, dozens by the time we discovered the issue. HOWEVER, the facility could not provide an evaluation of this contractor as a PRCS Rescue Provider! The facility stated that their PSM evaluation was all they had; which brings up the question I wrote about several years ago…
Trick Question or legit question for PSM Compliance? Contractor Evaluations and PRCS Rescue Evaluations (Membership Required)
It is my opinion that a contractor who provides PRCS rescue service at a facility covered by PSM will go through two (2) separate and distinct evaluations: PSM Contractor and PRCS Rescue Evaluations
Needless to say I was shocked at what I came across; knowing all the layers these guys fell through to get into the plant to provide such a critical function. When we began to investigate the situation (I called it a PSM Incident/Failure) we found out that the contractors company policy/procedures for respirators should have NEVER passed the contractor evaluation. Even the host facility does not allow facial hair in their respirator program.
So when someone says… “Don’t sweat the small stuff” – THINK AGAIN! When we hire a contractor to do a CRITICAL TASK/FUNCTION the OSHA/EPA required PSM/RMP evaluation is just not going to cut it. Sure we may not be able to be cited by either agency, but merely asking a contractor what their OSHA rates are is barely scratching the surface. In this case, it would have done us some good to have a human read the rescue service provider’s respiratory protection program!
But more concerning is the “layers of protection” the facility assumed they had in place in regards to contractor safety. Sure there were multiple layers in the program, but all the layers were MANAGED by a contractor, who in most cases just does not have the same “skin in the game” as the host employer has. This situation should have never occurred at this facility, but it is a perfect example of how we should be sweating the small stuff.