This document discusses OSHA's recommended best practices for contractor management based on its guidelines for safety and health management systems. It outlines OSHA's 7 core elements for an effective safety program: management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, program evaluation and improvement, and communication. The presentation argues that these elements can be used as protocols for contractor vetting to assess safety performance, culture, and management systems beyond mere compliance. Examples of assessment questions are provided for each element to illustrate how the guidelines could inform evaluations of supply chain contractors.

1. Contractor Safety Beyond Compliance
Modeling OSHA’s recommended best practices for
contractor management

2. Your Presenter
Pat Cunningham, MS
BROWZ, Director, Safety & Auditing Services
pat.cunningham@browz.com

3. Contractor Safety Beyond Compliance
Modeling OSHA’s recommended best practices for
contractor management

4. • Third-party contractor
qualification provider
• Patented, configurable
technology
• Support teams for both clients
and contractors
• Providing assurance of a safer
work environment
Who is BROWZ?

5. Agenda
Why OSHA published new guidelines
Safety/Health Management Systems
Breakdown of OSHA’s 7 core elements
How OSHA’s recommendations are applicable to contractor vetting
Example of a best practice approach for supply chain qualification, using OSHA’s
new criteria

6. Needed to reflect changing workplace realities
Targeted to small and medium sized businesses
Lessons learned from VPP and SHARP
Proactive vs reactive – beyond compliance
Addressing the ‘how to’ of safety
S/H Management Systems - integration
Why did OSHA publish new guidelines?

7. “A systematic, explicit and comprehensive process for
managing safety risks that provides for goal setting, planning
and measurement of performance against defined criteria.”
What is a S/H Management System?

8. OSHA: A safety and health management system (also known as an injury and illness prevention
program) is a proven, flexible framework for finding and fixing hazards before they cause injuries and
illnesses.
ISO 45001: Providing a framework for managing the prevention of death, work related injury and ill
health, with the intended outcome of improving and providing and providing a safety and healthy
workplace for workers and persons under an organization’s control
ANSI Z-10: Management tool to reduce risks of occupational injury, illnesses and fatalities
National Safety Council: A systematic, explicit and comprehensive process for managing safety
risks that provides for goal setting, planning and measurement of performance against defined criteria.
OHSAS 18001: A network of interrelated elements. These elements include responsibilities,
authorities, relationships, functions, activities, processes, practices, procedures, and resources. A
management system uses these elements to establish policies, plans, programs, and objectives and to
develop ways of implementing these policies, plans, and programs, and achieving these objectives.
Other Definitions of a Safety Management System

9. Safety/Health Management Systems
Structure: flexible framework, network of interrelated elements, risk management
Scope: injury and illness prevention, workers and persons under an organization’s
control
Process: goal setting, planning and measurement of performance against defined
criteria.
Objectives: develop ways of implementing these policies, plans, and programs, and
achieving these objectives
Common Features

10. S/H Management System
Policy, Procedure
Training, Education
Hazard Analysis & Reduction
Metrics & Performance
Measurement
Leadership, Engagement &
Communication
Budget, Resources

11. OSHA Recommended Practices for S/H Programs:
1. Management leadership
2. Worker participation
3. Hazard ID/assessment
4. Hazard prevention/control
5. Education/training
6. Program evaluation/improvement
7. Communication & coordination for all workers
OSHA’s 7 Core Elements

12. 1. Management Leadership

13. 1. Management Leadership
• Make worker S/H a core organizational value
• Fully committed to eliminating hazards, protecting workers, and
continuously improving workplace S/H
• Provide sufficient resources to implement & maintain the S/H program
• Visibly demonstrate and communicate their S/H commitment to workers
and others
• Set an example through their own actions

14. 2. Worker Participation
Encouraged to participate in the program and feel comfortable providing
input and reporting S/H concerns
Access to information they need to participate effectively in the program
Opportunities to participate in all phases of program design and
implementation
Do not experience retaliation when they raise S/H concerns; report
injuries, illnesses, and hazards; participate in the program; or exercise
S/H rights

15. 2. Worker Participation
• Encouraged to participate in the program and feel comfortable providing
input and reporting S/H concerns
• Access to information they need to participate effectively in the program
• Opportunities to participate in all phases of program design and
implementation
• Do not experience retaliation when they raise S/H concerns; report injuries,
illnesses, and hazards; participate in the program; or exercise S/H rights

16. 3. Hazard Identification & Assessment

17. 3. Hazard Identification & Assessment
• Collect and review information about likely or present hazards in the workplace
• Conduct initial/periodic workplace inspections to identify new or recurring
hazards
• Investigate incidents, and close calls to determine the underlying hazards, their
causes, and S/H program shortcomings
• Group similar incidents and identify trends reported
• Consider hazards associated with emergency or non-routine situations
• Determine the severity and likelihood of incidents that could result for each
hazard identified - use this information to prioritize corrective actions

18. 4. Hazard Prevention & Control
Elimination
Substitution
Engineering
Admin
PPE

19. Elimination
Substitution
Engineering
Admin
PPE
4. Hazard Prevention & Control
• Involve workers who understand the conditions that create hazards, and can provide
insight on how they can be controlled
• Evaluate options for controlling hazards, using a "hierarchy of controls"
• Use a hazard control plan to guide the selection and implementation of controls,
and implement controls according to the plan
• Develop plans with measures to protect workers during emergencies and non-
routine activities
• Evaluate the effectiveness of existing controls to determine whether they continue to
provide protection. Review new technologies for their potential to be more
protective, more reliable, or less costly

20. 5. Education & Training

21. 5. Education & Training
• Knowledge and skills needed to do their work safely and avoid
creating hazards that could place themselves or others at risk
• Awareness and understanding of workplace hazards and how
to identify, report, and control them
• Specialized training, when their work involves unique hazards

22. 6. Program Evaluation & Improvement

23. 6. Program Evaluation & Improvement
• Establishing, reporting, and tracking goals and targets that
indicate whether the program is making progress
• Evaluating the program initially and periodically thereafter to
identify shortcomings and opportunities for improvement
• Providing ways for workers to participate in program evaluation
and improvement

24. 7. Communication (all site workers)

25. 7. Communication (all site workers)
Pre-work effective communication and coordination among employers means that
contractors and staffing agencies and their workers are aware of:
• The types of hazards that may be present
• Procedures or measures they need to use to avoid or control their exposure to these hazards
• How to contact the host employer to report an incident, or if they have a safety concern
Host employers and their workers are aware of:
• Types of hazards that may arise from the work being done on site by workers employed by contractors or
staffing agencies
• Procedures or measures needed to avoid or control exposure to these hazards, including emergency
response
• How to contact the contract or staffing firm if they have a safety concern

26. Point of View
The elements within the new OSHA
best practice guidelines can be used as
protocols for contractor vetting.

27. Considerations
• Speak with your supply chain companies on an annual basis – about their safety performance,
safety goals and objectives
• Safety performance and culture is dynamic, be able to assess the trends of companies within
your supply chain
• Ensure supply chain data: current, verified & readily available to all internal stakeholders
Assessment Considerations

28. Assessments should…
• Use a leading indicator metric to evaluate your supply chain – standard process, regardless
of business type
• Help improve the safety performance of your supply chain
• Establish a common language & metric that is able to frame-up a conversation about safety
• Provide readily available data to help make good decisions for supply chain contract awards
Best Practice – Management Systems

29. 1. Management Leadership
- Example assessment question -
Does the company integrate planning for safety and
health with its overall management planning process
(dedicated budget, resource allocation & employee
training plan)?
OSHA Guidance
Provide sufficient resources to implement
and maintain the safety and health program

30. 2. Worker Participation
- Example assessment question -
Do all employees have the opportunity to participate in
periodic 'perception' or 'engagement' surveys? If so, do
the results get communicated back to employees, and
are action plans created based on results?
OSHA Guidance
Encouraged to participate in the program and feel
comfortable providing input and reporting safety or health
concerns

31. 3. Hazard Identification & Assessment
- Example assessment question -
Does the company have a documented sampling strategy to
identify health hazards and assess employees' exposure
(including duration, route, and frequency of exposure), and the
number of exposed employees?
OSHA Guidance Collect and review information about the hazards
present or likely to be present in the workplace

32. 4. Hazard Prevention & Control
- Example assessment question -
When the company selects hazard controls, does it
follow the preferred hierarchy (Elimination, Substitution,
Engineering, Administrative & Personal Protective
Equipment) to eliminate or control hazards?
OSHA Guidance Identify and evaluate options for controlling
hazards, using a "hierarchy of controls"

33. 5. Education & Training
- Example assessment question -
Are there specific SH training requirements for
managers, supervisors, employees, sub-contractors,
and temporary staffing agency workers?
OSHA Guidance
Knowledge and skills needed to do their work
safely and avoid creating hazards that could
place themselves or others at risk

34. 6. Program Evaluation & Improvement
- Example assessment question -
Does performance tracking include using both
lagging and leading indicators?
OSHA Guidance
Establishing, reporting, and tracking goals and
targets that indicate whether the program is
making progress

35. 7. Communication (all site workers)
- Example assessment question -
Before working on site, does the company have evidence of
agreement with the host employer regarding which parts of the
safety program they will have responsibility (this includes the
company accounting for it's subs, and/or temporary staffing
agencies)?
OSHA Guidance
Pre-work, effective coordination amongst
employers - host, contractors, staffing agencies
& their workers are aware of individual and joint
responsibilities

36. "Host employers need to treat temporary workers as they treat existing employees.
Temporary staffing agencies and host employers share control over the employee,
and are therefore jointly responsible for temp employee's safety and health. It is
essential that both employers comply with all relevant OSHA requirements."
- David Michaels, PhD, MPH, Assistant Secretary of Labor for Occupational Safety and Health (2009-2017)
Protecting Temporary Workers

37. Supplier Feedback
“We hope competitor companies are participating in the BROWZ
assessment system, so their safety efforts are also measured.”
“This review will help us be a better safety performing company.”
“…is glad to see industry is doing more to evaluate supplier’s safety
programs, which is heading industry in a positive direction.”

38. What We Covered
• Appreciation for why OSHA would issue new guidelines
• Understanding of why a safety/health management system approach would be helpful to
industry
• Awareness of OSHA 7 Core Elements
• Example of how the guideline content could provide useful information for vetting contractors
Summary

39. Upcoming Webinars > www.browz.com/webinar

40. Questions & Contact Info
OSHA Guidelines: https://www.osha.gov/shpguidelines/management-leadership.html
Request a Demo
www.BROWZ.com/demo
Pat Cunningham, MS
BROWZ, Director, Safety & Auditing Services
pat.cunningham@browz.com