Competence (4.4.2) Records - Contractors who carry out skilled maintenance tasks

The 2004 std states that persons working on behalf of the company (not necessarily employees) that have potential to cause significant environmental impact must be competent on the basis of education, training or experience and shall retain associated records.

Where contractors come in and carry out skilled maintenance tasks it is easy to get records as the personnel usually have to be qualified engineers etc, but where the tasks are less skilled this is not so easy.

I need to have records for the guy who is coming to say knock down a wall or do the gardening or put down rat bait, these guys may have no relevant qualification or education and possibly little experience.

How should these be addressed?

Thanks

Spanner

I am not entirely sure that you have to do anything more than request some paperwork. In CA, I would think that a Contractor's licence would suffice for the guy knocking down walls. If he doesn't have one, then look for someone who does as that could open up a completely new can of worms. For the guy with rat bait, if you utilize a recognized company (i.e. Orkin, Terminix) then they have training records they can forward to you.

I would think that should satisfy your training and competence requirement.

For contractors coming on site, they are required to provide us with a copy of their ticket indicating that they are qualified to do the work that they will be doing. They also undergo a pre-work orientation for safety and environment to make them aware their actions may impact our location.

outside contractors

Spanner said:

The 2004 std states that persons working on behalf of the company (not necessarily employees) that have potential to cause significant environmental impact must be competent on the basis of education, training or experience and shall retain associated records.

Where contractors come in and carry out skilled maintenance tasks it is easy to get records as the personnel usually have to be qualified engineers etc, but where the tasks are less skilled this is not so easy.

I need to have records for the guy who is coming to say knock down a wall or do the gardening or put down rat bait, these guys may have no relevant qualification or education and possibly little experience.

How should these be addressed?

Thanks

Spanner

Click to expand...

I must be getting quite old as subjects like these make me sick! (This is not intended as a slam on Spanner) But how far do we carry this silliness? Outside contractors are paid for their skills. In fact most of them are licensed. As long as we do our diligence and have a paid in full receipt for work performed why must we do any more? Do we really need a copy of their license or their training? Oh Please, give me a break! What is the quality profession becoming? Let's return to some good old fashion common sense and move on!

RCBeyette said:

They also undergo a pre-work orientation for safety and environment to make them aware their actions may impact our location.

Click to expand...

I had a similar understanding regarding how to address the subject requirement. Not such a bad idea, IMO.

An outside contractor might be skilled, but does the contractor know YOUR aspects, and how the contracted work affect them? "...that have the potential to cause a significant environmental impact(s) identified by the organization..." The competence issue here deals with your significant aspects. How you train, educate, make aware, etc., your contractors as to how they impact your EMS.

You guys are good, but out in left field

1st, contractors and suppliers need to be evaluated for the aspects revolving around what they supply or what the may do. (Remember to evaluate potential aspect related to abnormal and emergency type situations as well as normal day-to-day things)

2nd, utilizing the same methodology for suppliers and contactors that is used by the organization internally, the identified aspects need to be evaluated for their significance. If there is no significance, continue to march. If significance is identified then all the same necessary steps for management and control must take place for the affected suppliers and contractors that the organization takes for itself.

Simple.....

Thanks for the input.

To meet the requirements of the std I need to select competent sub contractors (obviously) and get some evidence of their competence particularly where their work can impact the environment. Is a statement from the contractor company "Only trained and competent staff will be used to carry out ...." adequate or would it need to be specific to the people that come on site?

When the contractor comes on site we should give them some instruction with particular reference to the environmental aspects on our site, this could be a standard checklist that covers the majority of cases with some space for specific aspects the particular contractor may be involved in. If the contractor signs the checklist this will be my record that the they have received relevant training.

Is this the simplest way?

To a degree you are right, but you must also evaluate the aspects directly related to the contractors themselves. You also should look into how the contractor defines compentence...training alone isn't enough, can they actually show that necessary work can be performed by their personnel in such a fashion that significant impact to the environment can be avoided? Many times this would entail professional licensing or certification.

Of course all of the above is dependent on what your contractor is doing and that is why thier aspects and the significance of them is important. If they have no potential to create a significant impact the approach you've stated would be adequate, if they do have the potential for S/A then you need to take a more refined and managed approach similar to what I have stated in this post and the earlier one.