Ensuring contractor competency - 4.4.2 Training, awareness, and competency

[jmp4429]

Maybe someone here can help me with this question. Our 14001 auditor is pretty hung up on 4.4.2 “Training, awareness, and competency.” In addition to making sure all contractors coming in have agreed to follow our environmental regulations and policies, we are supposed to have records that prove the contractors are competent to do their jobs.

This isn’t really a big deal for skilled contractors; we’re already working on getting copies of the individual license or certification for each member of our contract companies’ staffs. But can anybody suggest a way to handle non-skilled contractors. I’m thinking of people like the cafeteria employees, lawn care company, cleaning service, etc… How do we prove that they are qualified to do their jobs?

Also, we are trying to figure out how to handle vendors such as the guy who restocks our cleaning supply cabinet twice a week. Although he’s not technically a contractor, he could spill a big bottle of floor stripper in the parking lot. Other problem areas are delivery/freight truck drivers, and auditors. (Personally, I have a sick sense of humor so I’d love to require our external auditors to fill out environmental compliance forms and present “proof” that they are competent to do their jobs.)

Anybody dealt with a similar issue?

 

[Kevin H]

My prior employer, a major US producer of carbon, electrical, and stainless steels required contractor employees coming onto the site to complete an 8 hr training session on safety, environment, etc. before they were permitted in the plant. They represented enough business over all the plants they operated that most contractors grudgingly complied. I'm not certain how it affected cost for most services.

As a manager of a mechanical testing lab, the only personnel I interacted with who were affected by the rule were the companies supplying me calibration for test instruments. In that instance, we were not a large enough consumer of their services to force them to comply without paying for the additional day of training. So, the first year we instituted the requirement, my calibration budget shot up about 4 grand over the prior year.

 

[Sidney Vianna]

I am selling common sense on Ebay!!!!

It is incredible how common sense gets thrown out the door, sometimes.
When I read ISO 14001:2004, par. 4.4.2 "... The organization shall ensure that any person(s) performing tasks for it or on its behalf that have the potential to cause a significant environmental impacts(s) identified by the organization is (are) competent...."

If your cafeteria, landscaping, etc. contract personel can cause a SIGNIFICANT environmental impact, I would be surprised. One could make a case that the cook could "accidentaly" drop laxative in the food.

 

[Randy]

Sidney you kill me

To continue with Sid's line of thought...if you can show that folks don't have "significance" ask the auditor to do his worst. Significance is based upon you, not some ding-bat auditor.

I'm tied up around 4.4.2 also, but my thing is how organizations determine and evaluate, and achieve competence which is something that you can sink your teeth into, not some bogus interpretation.

 

[Wes Bucey]

If you believe there is a real probability (versus possibility) of an untrained person severely affecting your operation, you need to do something to reduce the probability. This means you can

1. use only folks trained by third parties
2. train folks yourself
3. give a competence exam

If the probability is not high - it is NOT necessary. If the probability is high, the competence exam may be all that's necessary in your case.

This is like FMEA (Failure Mode & Evaluation Analysis), folks. Don't get yourself tied up in knots kissing tails of auditors just because they hang mistletoe on their backs. Make an intelligent decision of what you really need.

Let the mantra always be when dealing with any auditor (customer or third party):
"Show me the shall!"

 

[Randy]

It's not so much as screwing up the operation as it is to effecting the environment...in this case we are referring to a negative effect upon the environment. Realistically a CEO who is not competent can create a significant impact through decision making or the lack thereof.

I'll bet the auditor didn't ask about the competence of the boss (related to EMS competence of course).

 

[jmp4429]

Regrettably, I’m not in a position to tell the auditor or anyone else what is and is not required under the ISO 14001 standards. I think that because some of our contractors do have the ability to create a significant impact, those above me feel that it would be easier to get all the records for all contract employees rather than trying to distinguish between “no significant impact,” “no significant impact this time, but maybe for future projects” and “potential significant impact.” Also, because this is a pretty environmentally friendly plant already, we define some things as significant that my last company would have just laughed at, like rainwater collecting oil and gasoline drips on the parking lot.

I suspect that what the auditor is after is something along the lines of this: Our HVAC contractor isn’t going to release a bunch of refrigerant into the air, our contract electricians aren’t going to create tons of smoke by causing an electrical fire, our exterminator isn’t going to spill 100 gallons of highly toxic pesticide down our storm drains, our cafeteria people aren’t going to dispose of old oil from the deep fryers by tossing it out the back door…

We already have an environmental and safety briefing that all our contractors sign before they may enter the plant; we just need some type of records to indicate that they have been trained to do their jobs without creating any environmental issues. The scope of this project keeps getting broader the more we think about it.

Whew! All that being said, I’m thinking that to supplement our records that our contractors have read and agreed to our environmental policies and procedures, I might request a letter from each of our non-skilled contractor companies saying something similar to the following:

“MaryAnn and Donald have been fully trained to perform their duties in housekeeping, are aware of the potential environmental impact of the chemicals they use in their duties, and have been trained to properly respond to any chemical spills or other environmental incidents that might occur while they are on duty at ABC Company.”

What do you think – should this cover us?

 

[Randy]

“MaryAnn and Donald have been fully trained to perform their duties in housekeeping, are aware of the potential environmental impact of the chemicals they use in their duties, and have been trained to properly respond to any chemical spills or other environmental incidents that might occur while they are on duty at ABC Company.”

What do you think – should this cover us?

Putting it the way you are...Nope! Where is the evidence that they are in fact capable of doing what you say? Having training and briefings does not make one competent...achieving desired results on a continual basis does. Where is your evidence?

Sounds crazy doesn't it? I agree, but just saying that people are competent is different than being able to prove that people are competent. As an auditor you need to show me the beef.

 

[jmp4429]

Putting it the way you are...Nope! Where is the evidence that they are in fact capable of doing what you say? Having training and briefings does not make one competent...achieving desired results on a continual basis does. Where is your evidence?

Sounds crazy doesn't it? I agree, but just saying that people are competent is different than being able to prove that people are competent. As an auditor you need to show me the beef.

I see what you're saying - then what WOULD cover us?

 

[Randy]

Something like a record where the person was observed performing their duties IAW requirements.

Evidence that there have been no deviations created by an employee error.

Some type of competency based exam (for my A&P I had to actually perform a repair of damage on an aircraft, attach fasteners, perform a weight & balance, etc...).

You can be creative......

You have defined what competency for specific tasks consists of haven't you?