Regulatory responsibility 

Anytime a new hazardous chemical is introduced into the workplace, information about the hazards must be available to all workers who encounter them. If a contractor is enlisted, there is no min/max exemption to this rule. Contractor work activities may expose facility personnel to new hazards, such as unique chemicals hazards. One must also be aware that contractor activities onsite may unintentionally defeat or bypass facility safety controls.

Establish a contractor management program

The most effective teams implement robust contractor management programs as a part of contractual obligations. Company groups delegate roles and responsibilities to include operations, maintenance craft groups, facility/corporate safety and process safety groups. The contractor management program is often managed by procurement; however, certain internal company departments (operations, maintenance, facilities, corporate safety or process safety) typically oversee and audit to maintain a system of checks and balances during the process. 

• Contractor management should begin before the commencement of any project. 
• Pre-project safety assessments should include steps to obtain the necessary information before the project is approved. 
• Best practices leverage web-based chemical data management systems that include an easy and efficient way for contractors to submit safety data sheets (SDS) and related material information via an auditable chemical approval process. In addition, the leading industry chemical data management systems include labeling solutions that utilize SDS data. By requiring workers to generate labels from this system, managers can ensure that the material has passed the chemical approval workflow, the label contains the latest hazard information and the workplace is compliance with 1910.1200(e)(2)(iii) (see figure).

In addition to the OSHA requirements referenced referenced in the box to the left, many companies have adopted ANSI Z10-2012 standards and/or are certified under various ISO standards such as the 14001 environmental standard (14001:2015) and the new 45001 safety and health management system standard, both which require contractor safety programs. The primary elements of these safety programs are training, communication and controls, such as chemical approval. Once a contractor comes onto a site they become a worker, thus every organization must decide how they intend on managing the workers under their control. 

Continual improvement 

The most successful contractor management programs engage in periodic monitoring of contractor safety performance and auditing procedures (which also satisfy various ISO 14001 and 18001/45001 elements/requirements). In order to efficiently maintain critical chemical data throughout the process, many companies utilize a chemical management system that incorporates automated SDS versioning, updating and archiving (satisfying OSHA’s 30-year retention rule 1910.1020(d)(1)(i)) (see also figure). In addition to saving time and resources required to maintain chemical data, these systems typically store historical records of all activities leaving a well-defined and accessible audit trail. 

Establishing an operative chemical approval process enables workers to monitor and control exactly what materials arrive on site. However, not only do organizations have a responsibility to collect the data for new materials, they also have a responsibility to provide access to information about current materials already on site so contractors can adequately train and educate their workers before arriving. But what are the best practices for providing this information to visitors or contractors? 

The use of contractors can place personnel who are unfamiliar with the facility’s hazards and protective systems into potential hazardous chemical exposure scenarios. Employers should provide contractors with effective information and training on hazardous chemicals in their work area during the pre-project safety assessment and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets. 

Performance evaluation

At the end of each contract period, retrospective evaluation of a contractor’s safety performance should help determine whether the particular contractor is retained or considered for future work. Once the project is complete and all materials have been removed from the site(s), the same “30-year retention rule” applies for all hazardous chemicals in the workplace. The best SDS and chemical data management systems deliver a very cost-effective method of storing important hazardous chemical records and related exposure data, while providing access to this critical information at the click of a button. 

Contractors and the organizations for which they work must work together to protect all employees. Safety is a two-way street in every scenario. Leveraging the tools on the market today, these partnerships can create safer, smarter workplaces around the world.