There’s a reason why both OSHA and EPA have requirements to CONTROL the entry of contractors into our covered process(s), their presence, and their exit from the process. It is so IMPORTANT, we find two (2) places in the standards that require this kind of CONTROL over contractors who wish to work ON, IN, or ADJACENT to our covered process…
(f) Operating procedures
…
(4) The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tag out; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.
and
(h) Contractors
…
(2) Employer responsibilities
(iv) The employer shall develop and implement safe work practices consistent with paragraph (f)(4) of this section, to control the entrance, presence and exit of contract employers and contract employees in covered process areas.
This story is 100% real and I am NOT exaggerating any aspect of it; the names have been left out to protect the company and contractor, but this actually happened in 2015!
A client was in the middle of a serious release. The release was NOT that big, but the location of the leak was as about as bad as it can get. So the facility personnel was doing all they could to remedy the situation. Meantime, a contractor, who was NOT a PSM approved contractor, was needing access to the covered process. This access is controlled via a security access door. The vast majority of this contractor’s work was OUTSIDE the room that contained the covered process; however, to finish the project they needed access to this room.
A key point to be made here is that this contractor was NOT working for the group of workers who manage, maintain, or operate the covered process. They were hired by a person within the company who manages the “facilities” across a broad range of company assets. So the work outside the room, although it involved modifying the wall, it did NOT have any impact on the covered process, its safety systems or facilities. It was merely “cosmetic” for the building.
So during the “active leak”, the operators were going in and out of the security door so often they decided to prop it open rather than having to enter their security code each time. After the team of operators and engineers established where the leak was originating from they regrouped back in the maintenance shop, erroneously leaving the security door propped open. Along comes the construction contractor who needs access to the room to finish their project. They notice the door is propped open, but as they enter the room they immediately smell the HHC/EHS. This particular HHC/EHS has really good warning properties and the level of their exposure was estimated to be around 25-50 ppm. As with this exposure, the operators, and engineers who were accessing the situation had donned their full face APR’s and upon leaving the area they had removed them and set them down to be cleaned.
Now this contractor company does NOT have any type of respirators – not even filtering face pieces. And of course, they have no written program, no training, no medical evaluation, and no fit testing to be wearing these full face APRs. But because it was so stinky in the room and I am sure their eyes and nose were burning they decided to don these full face APRs and begin to do work in the room. Yes, you are picturing this correctly… the contractor picked up a respirator that was not his, had been worn by an operator, was NOT cleaned, and the contractor had NO IDEA what he was doing with the respirator!
Upon returning to the room you can imagine the surprise of the operators and engineers to find a UNTRAINED contractor in a PSM process, wearing their full face APRs (which had not been cleaned), doing work in the middle of about 25 ppm of the HHC. The kicker, when asked by the engineering manager what the H_LL they were doing, the supervisor of the crew says… “XXXXXXX said we could do this work”. XXXXXXXX was the person he made the statement too! OOOOPPPSSSS!
But this situation tells us one thing… without CONTROL over those who are NOT trained to be in our process, they will do what they need to do to get their job done. It is OUR RESPONSIBILITY to ensure ONLY those personnel who have been evaluated AND trained have access to our process areas (including those adjacent to our process). This was a contractor who had done business with this company for nearly 30 years, but NEVER anywhere near the covered process, so they thought it was “business as usual”, even with the stinky and stinging conditions they were working in.
So imagine if a neighbor had gotten a whiff of this release and called some authorities and the authorities show up to inquire about it and during the course of their inquiry they discovered this situation – what do you think would have come of this scenario?
Moral of the story, to CONTROL the entrance, presence and exit of contract employers and contract employees in covered process areas it all starts with who can HIRE contractors and who can issue work instructions to contractors. Having a fancy purchase order system allows many to RESTRICT who can approve POs that involve anything IN, ON, or ADJACENT to a covered process. If we are not so advanced in our purchasing systems, then we have to go back to the basics and implement a CONTRACTOR SAFE WORK PERMIT system. Of course, not propping open the security access door during a quasi-release of your HHC is always a good idea! But when you think you have seen/heard it all, remember this – Contractors have a job to do and if we do not place boundaries upon them and their work, we should not be surprised when something goes awry.