Should project managers know what basic regulatory requirements are?

K

kgott

#1
I did an audit of one of our projects regarding their project's compliance to our organisations requirements, the cleints requirements and legislation applicable to the project, in recent days.

The project manager did not know what some basic regulatory requirements are for some basic hazards our staff face on most projects. E,g working in the heat, PPE requirements, working alone and fatigue management.

For this reason I have raised a CAR saying that project managers need to learn what these basic regulatory requirements are.

It was put to me that a project manager has access to the safety advisor who knows this stuff, they have project safety management plan and for so long as they are working to that (implementing it) then they don't need to know what the regulations relating to these basic hazards are.

It was also put to me that the company also has safety management procedures which should spell out the actions the project manager needs to take to ensure compliance and therefore, again, they don't need to know what the regulations require.

It was my view that if I was working for the cleint and I asked a project manager what the regulations require for some basic hazards and they could not tell me then I would regard this as a cause for concern and take it futher.

Was I justified in reaching the conclusion I did?

thanks
 
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qusys

Trusted Information Resource
#2
In my understanding this was a second party audit vs a supplier of yours , isn't it?
I think you use the requirements that you have agreed with your supplier. What did you establish for the competence of the personnel?

If there is a specific requirement for project mgr, it has to be specified.
In my mind, the project mgr shall be accountable for the tasks of the project and he/she can also be not competent in all matters and use competent resources that are responsible of specific tasks completion of the project.
Pls, let us know more but I think your supplier is right if there is no specific requirement on the competence of the project mgr.:bigwave:
 
Last edited:

sagai

Quite Involved in Discussions
#3
Hi There!

Well, i have a slightly different view.

There is only one role, the "Management Representative" in regulatory that shall be knowledgeable about regulatory.
However this still not 100% true, because the one named as "Management Representative" can delegate all of his duties in an extreme case to others, and as such, even the appointed Management Representative should not be necessary to be knowledgeable about regulatory.

So, sum it up, in your case I see a well founded case, only in case the Project Manager is the Management Representative in its organization, or the Project Manager appointed to be a delegate of some of the Management Representative responsibilities.

Cheers!
 

qusys

Trusted Information Resource
#4
Hi There!

Well, i have a slightly different view.

There is only one role, the "Management Representative" in regulatory that shall be knowledgeable about regulatory.
However this still not 100% true, because the one named as "Management Representative" can delegate all of his duties in an extreme case to others, and as such, even the appointed Management Representative should not be necessary to be knowledgeable about regulatory.

So, sum it up, in your case I see a well founded case, only in case the Project Manager is the Management Representative in its organization, or the Project Manager appointed to be a delegate of some of the Management Representative responsibilities.

Cheers!
Hi sagai,
only my idea on this.
I think that mgmt Representative is a specific ISO 9001 requirement that is not linked with the project manager role in this specific case, neither if there is delegation to another resource.
I intend project mgr as a role to lead a project with a beginning and an ending, with the project mgr role that is not relevant to ISO 9001 requirements but only to the requirements agreed between customer and supplier on the work to be provided.
I think we need more details from the original poster kgott.:bigwave:
 
Last edited:

qusys

Trusted Information Resource
#6
I had not a different on yours, but the original posters I guess :)
Yes, understood:yes:
I think it is a question of agreed requirements for this service and subscribed in P.O./contract.
My guessing is also if this supplier is ISO 14001/OHSAS 18001 certified.
We will see:bigwave:
 

Paul Simpson

Trusted Information Resource
#7
Interesting series of questions. Here's my :2cents:

I did an audit of one of our projects regarding their project's compliance to our organisations requirements, the cleints requirements and legislation applicable to the project, in recent days.

The project manager did not know what some basic regulatory requirements are for some basic hazards our staff face on most projects. E,g working in the heat, PPE requirements, working alone and fatigue management.

For this reason I have raised a CAR saying that project managers need to learn what these basic regulatory requirements are.
Looks like you are raising a CAR on the auditee not following your potential solution! :)

Seriously the issue has to be better defined:
  • How does your organisation describe how it satisfies its legal obligations? Is there a documented procedure and what does it require?
  • If your procedure or the client requires that PMs know legal requirements then the CAR is clear cut.
If neither requirement exists then further digging is needed.
It was put to me that a project manager has access to the safety advisor who knows this stuff, they have project safety management plan and for so long as they are working to that (implementing it) then they don't need to know what the regulations relating to these basic hazards are.
So when they say 'has access to' - what does that mean exactly. Are they a visible part of the project team and are they evident in the planning of this project? You may need to speak to the advisor privately about how they see it.

Also the project safety management plan - has this been developed specifically for this project or is it 'off the shelf'.

Does the plan address all the legal obligations?

Depending on what you find here you may decide whether the risk mitigation plan is suitable or not.
It was also put to me that the company also has safety management procedures which should spell out the actions the project manager needs to take to ensure compliance and therefore, again, they don't need to know what the regulations require.
Again the question becomes: 'Are the procedures adequate in addressing the legal obligations? If the PM knows the procedures (does s/he?) and the procedures meet the legal requirements then it may be OK (if they are effectively implemented). The implementation should also be checked.

If there are gaps in any of this audit trail then a CAR exists.
It was my view that if I was working for the cleint and I asked a project manager what the regulations require for some basic hazards and they could not tell me then I would regard this as a cause for concern and take it futher.

Was I justified in reaching the conclusion I did?

thanks
Your last point is a good one and relates to how we want our organisations to look in front of the client. Even if no CAR exists I would raise an observation that your organisation will look much better in front of the client if the PM (who is or should be a senior individual) has a good grasp of the dangers they are asking people to work with - and a small part of that is knowing the legal framework.
 
T

TamTom

#8
I did an audit of one of our projects regarding their project's compliance to our organisations requirements, the cleints requirements and legislation applicable to the project, in recent days.

The project manager did not know what some basic regulatory requirements are for some basic hazards our staff face on most projects. E,g working in the heat, PPE requirements, working alone and fatigue management.

For this reason I have raised a CAR saying that project managers need to learn what these basic regulatory requirements are.

It was put to me that a project manager has access to the safety advisor who knows this stuff, they have project safety management plan and for so long as they are working to that (implementing it) then they don't need to know what the regulations relating to these basic hazards are.

It was also put to me that the company also has safety management procedures which should spell out the actions the project manager needs to take to ensure compliance and therefore, again, they don't need to know what the regulations require.

It was my view that if I was working for the cleint and I asked a project manager what the regulations require for some basic hazards and they could not tell me then I would regard this as a cause for concern and take it futher.

Was I justified in reaching the conclusion I did?

thanks
Not reading all answers, for me it is a question of organisation level, if the project manager is only in a matrix organisation responsible for the personell than there shall be a boss who have to care for his personell. If the project manager has also the personell responsibiltiy (agrees on holidays etc.) than he must know about the regulation.
I'm not familiar with Australian la, but in Germany this responibility must be delegated, but once deligated the person in responibilty are could be blamed on.

Greetings

TamTom
 
P

plantengineer

#10
It really depends on the structure of the Project. If the EH&S representative is part of the managing team for that project and is involved in reviews, then the Project Manger should not be required to know regulation. If there is no EH&S representative as part of the managing project team, then it is the responsibility of the PM to know regulation, since in that instance he would be "assuming" to role of SME.
 
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