Ensuring contractor competency - 4.4.2 Training, awareness, and competency

[jmp4429]

For our company employees in terms of TS16949, yes. Every X months, employees are observed performing their duties (operating workstations, etc..) and if anything is found to be lacking they are coached and re-examined. I don’t know if they do the same type of thing for say our maintenance guys that include observing them changing hydraulic fluid without allowing a spill and then properly disposing of it.

I have this alarming image of myself in a training room with a bunch of outside contractors, dumping a quart of green kool-aid on the floor and saying “Oh my god, a solvent spill! What are you gonna do now?” and then observing them as they run a “fire drill” before they are allowed to work in our plant.

Is that sort of what you have in mind?

I’m sorry I’m such a pain about all this, I’m sort of new to this concept as my last company was union and only hired a few contractors, most of which were themselves ISO 14001 compliant.

 

[jmurph01]

just so you know where I am comming from, this is what we do:

we send a contractor manual out to all contractors coming on to our site. it outlines all health and safety and environmental requirements and is accompanied by a letter that gives them a list of some of our more significant aspects. The contractor company is required to send back the sign-off sheet at the back of the manual, along with proof of insurance and WSIB coverage. For some contractors we request certain documents, for example:

air conditioning repair company - we request their technician's refrigerant licenses

waste haulers/disposal sites - we request their certificates of approval from the ministry of environment

Quote: (Originally Posted by jmp4429) “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?

now dealing with non-skilled contractors as you specifically mentioned, we have not really tackled that beyond the contractor manual sign-off. You could have them write a letter such as you mentioned, but would you require proof of training (i.e. training records) as well? I don't think having only the letter on file would prove competence. to truely make sure all contractor's are competent I would say you might need to require them to have ISO 14001 themselves. that might not (ok.. IS not) possible for all contractors but maybe something to look into for larger contractors who can impact more significant aspects.

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…

But are these SIGNIFICANT aspects for your organization? If not then you should look at which aspects your organization considers significant and which contractors can affect them. Those are the contractors that you should ensure competence. For the ones you mention above, i think having their refrigerant licenses, electrician licenses, license/permits to apply pesticides, etc. on file would be sufficient - i.e. they are competent through education/training. i wouldn't think an oil spill from your cafeteria is significant. if that is the least of your worries, I would love to work for your company! You should focus on ensuring ALL contractors are aware of your EMS and significant aspects (which it sounds like you do similar to what we do) but only need to ensure competence of contractors working on things that you consider significant. also maybe keep a log of any environmental issues with contractors....those working on site for a long period with no issues would be competent in my eyes.

i don't know...this is a difficult one. sorry i can't be of any more help.

 

[Randy]

I don’t know if they do the same type of thing for say our maintenance guys that include observing them changing hydraulic fluid without allowing a spill and then properly disposing of it.

I have this alarming image of myself in a training room with a bunch of outside contractors, dumping a quart of green kool-aid on the floor and saying “Oh my god, a solvent spill! What are you gonna do now?” and then observing them as they run a “fire drill” before they are allowed to work in our plant.

Is that sort of what you have in mind?

I’m sorry I’m such a pain about all this, I’m sort of new to this concept as my last company was union and only hired a few contractors, most of which were themselves ISO 14001 compliant.

1. If your maintenance folks can create a significant impact guess what?

2. As for the spill scenario...guess what, you're not that far off track. You actullly kill a couple of birds with this stone (4.4.2, 4.4.7, maybe a 4.4.6, 4.4.3 and so on)

3. YEP!!!

 

[Gusman - 2005]

we send a contractor manual out to all contractors coming on to our site. it outlines all health and safety and environmental requirements and is accompanied by a letter that gives them a list of some of our more significant aspects. The contractor company is required to send back the sign-off sheet at the back of the manual, along with proof of insurance and WSIB coverage. For some contractors we request certain documents, for example:

air conditioning repair company - we request their technician's refrigerant licenses

waste haulers/disposal sites - we request their certificates of approval from the ministry of environment

JMurph- Do you think you could send me or post a copy of your contractor manual. My company is in the process of developing an EMS and is interested in creating one for our contractors; I think it would be helpful to have one as a guide. No need to reinvent the wheel...
Thanks

 

[Caster]

Safe bet

....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).

Randy

There's a safe bet. I have noticed lately that auditors treat different levels much different. Woe be to a cal teck with a missing sticker, but they're all giggles and smiles with the man who writes their pay check.

Man that sounds cynical, but hey - that's the kind of day its been.

 

[jmurph01]

Gusman - I am attaching a copy of my contractors manual. It is for our 3 canadian divisions, all of which are in ontario. I have removed references to the company or specific people.

if anyone has any constructive criticism I would love to hear it, especially in relation to 14001:2004.

hope this helps

 

[jmurph01]

Quote: (Originally Posted by Randy) ....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).

Randy

There's a safe bet. I have noticed lately that auditors treat different levels much different. Woe be to a cal teck with a missing sticker, but they're all giggles and smiles with the man who writes their pay check.

Man that sounds cynical, but hey - that's the kind of day its been.

wow caster!!! that is cynical! hope your day improves!

when i do EMS training our director of operations is in there alongside union and office folks. I can say that I haven't really seen this with our auditors. our management team has gotten knocked on TS audits for various things. our auditors are equally mean...er nice....to everyone!!!

 

[Gusman - 2005]

Thanks much!
I think this is exactly the document we were looking for. I appreciate the help.

 

[Zuggy]

Hi,
That is a great document, especialy for the heath and safte aspects of contractors on site!! (here is the but) Where is the section for compentce (secton 4.4.2)? Do you ask for each contactor to supply you with certificates of compentce?


Tim

 

[Gusman - 2005]

I'm not sure competence needs to be ensured for ALL contractors. 4.4.2 states that "persons performing tasks for or on behalf THAT HAVE THE POTENTIAL TO CAUSE SIGNIFICANT ENVIRONMENTAL IMPACT are competent." The rest of 4.4.2, regarding knowledge of the policy, knowledge of personal work related environmental impacts, and roles and responsibilities within the EMS applies to all individuals working for or on behalf and I think the contractor EHS Manula covers that.
Correct me if I am wrong, though....it has happened before.