Confined Space Safety: Contractor Operations

by

R. Craig Schroll, CSP, CET

President
PO Box 231, East Earl, PA 17519, USA
US & Canada 800-222-8841
Office 717-354-2411 Fax 717-354-7233
E-mail Craig@FIRECON.com

Contractor Operations

Working with outside contractors often presents special challenges within a confined space safety program. Contractors are a valuable resource for most organizations and there are many advantages to their use. There can also be significant disadvantages.

The difficulty begins with selecting contractors. There is a large disparity between the best and the worst of outside contractor organizations when it comes to safety performance.

Many contractors are available that will do specialized confined space work more safely than you could. For example, some of the organizations that specialize in tank cleaning operations have made the investment in the necessary equipment, training, and programs so that they are able to do a better, safer job than your own people could. The fact that they specialize in this type of operation also means they have had the opportunity to develop a great deal of experience and expertise that your people probably lack.

Unfortunately, there are many examples of the opposite end of the spectrum as well. You may encounter the contractor who has no idea how to conduct confined space operations and yet has received the contract to clean a tank at your facility. For example, one of my clients had two individuals show up to do confined space work at their facility and did not even understand that it was necessary to monitor the atmosphere before they entered the space.

When to Use Contractors

Contractor involvement in confined space work may be required when your own people either do not have the specific task expertise or specialized equipment required. For example, if a vacuum truck is required to complete a pit clean out operation it may make the most sense to contract out the entire project. Contractors are also an excellent option if you seldom or never need to have your own personnel enter confined spaces. By contracting out infrequent entries you can avoid many aspects of dealing with confined space issues in-house. In this case leaving this type of work to a contractor that has the opportunity to develop more expertise makes sense.

Contractor Qualification and Selection

The most effective way to insure the safety of our contractor operations is to use a qualification and selection process. The qualification portion of this process should establish the competence of the contractor for confined space work prior to allowing them to bid on work involving confined spaces. Several key elements should be obtained from the contractor and reviewed by your organizations safety personnel. This process should be a one time evaluation with periodic reviews for updated material. It is a significant time commitment but, can save enormous time and trouble later. Do not just get the information and fail to do a thorough review and evaluation. Do not wait to conduct this process until a confined space project is on the horizon. The best place to begin is often with organizations that already do contract operations at your facility. Explain to them that due the hazards of confined space operations you have a special program in this area and as an existing contractor you would like to offer them the first opportunity to participate in the process. Obtain the following from the contractor: I know this may seem excessive but, the majority of difficulties I have seen develop concerning the safety of contractor operations could have been completely avoided with the use of an effective selection system. The goal is to pre-qualify a small list of reliable contractors that you use as your bid list for confined space work. All of the above is completed prior to allowing the contractor to bid on work involving confined spaces.

Once this process is completed there are job specific items that must be handled. OSHA requires that an exchange of information take place with outside contractors. OSHA specifically requires host employers to provide certain information [1910.146(c)(8)] and outside contractors to obtain the information [1910.146(c)(9)].

You must inform the contractor that the work will or may involve confined space entry. You must provide copies of:

All of the contractors who have successfully completed the process just discussed are then eligible to bid on confined space work at your facility.

Contractor Agreement

Once a qualified contractor has been selected you will need an agreement between you and the contractor. The agreement should make clear to the contractor that you expect adherence to your organizations safety standards even if they exceed minimum OSHA requirements.

This agreement should specify that the contractor will be required to handle safety issues concerning their own employees. This should include the provision of all necessary safety equipment and supplies. While you can provide specialized equipment for contractor use this increases the complexity of the project and opens you up to additional liability. Any equipment you provide will require that you train the contractor employees on the safe use of that equipment. For example, if you lend a contractor an item of atmospheric monitoring equipment you cannot assume that their personnel will know how to operate it effectively. You must provide training. If this monitoring equipment or the contractor employees lack of ability to use it effectively later leads to an injury or fatality in the confined space you are liable.

The agreement should also specify how joint entry operations involving your employees and contractor personnel will be coordinated. Do not put yourself in the position of having your employees depend on contractor personnel for safety issues. I would also encourage you not to allow your people to assume responsibility for the safety of contractor employees.

A statement signed by the contractor indicating that they assume primary responsibility for compliance with local, state, and federal regulations concerning employee safety and health and environmental issues.

A statement signed by the contractor that they have received and understand the items mentioned above that must be provided to the contractor.

Project Planning

Effective planning can minimize the opportunity for unexpected occurrences during the project. This planning should include clear communications about the scope of the project and project schedule. The schedule should be designed to minimize the number of entries needed and their duration. Part of the planning process should insure that all items such as, tools, supplies, and equipment required during the confined space entry are available prior to starting the work. This may not be possible on an emergency repair but should be done whenever possible.

At the beginning of the project a brief meeting should be conducted among the contractor personnel and all individuals within your organization that may have a role in the safety of the work.

From the contractor organization I would expect the project supervisor, safety manager, and individual that will be acting in the role of entry supervisor.

From your organization I would expect the safety manager, the area supervisor where the work will occur, and your entry supervisor if it will be a joint entry operation. You may also want to consider individuals with specific topic expertise such as knowledge on a specific chemical the contractor may encounter. Your maintenance supervisor/manager may also provide useful information on isolation issues.

This meetings main purpose is to clarify that all essential information has been exchanged and that everyone is clear on the various roles and responsibilities of all the people involved.

During Work

If the project will involve joint operations with your personnel and the contractor these operations must be coordinated. How this will be handled should have been established in the agreement mentioned previously.

You should inspect the job site and discuss safety issues with the contractors personnel on the first day of the project.

Repeat visits should be part of the monitoring process of the job. The timing will be determined by contractor performance and hazards of the work. If the contractor is performing as agreed fewer visits will be necessary. If safety performance seems less than expected more frequent visits may be needed to insure that safety issues are properly addressed.

You may also plan to visit the job site during any operations that involving significantly increased risk. For example, if part of the project will involve cutting operations in the confined space a visit during the beginning of that phase would be prudent.

During job site visits talk with the contractor supervisor and employees to determine that the project is progressing as planned from a safety perspective. Observe operations to insure that the agreed upon safety procedures are in fact being used. Some key items to look for include:

You should also review the permit during your visit and compare it to actual operations. Question the contractor about any discrepancies.

Using the preparations we have discussed to this point it is less likely that you will discover major problems on these site visits. If you do though, the job must be stopped immediately and the critical safety issues handled before resuming work.

After Work

Meet with the contractor to review safety issues that were involved with the job. This meeting should be viewed as primarily a learning experience for both you and the contractor. Any difficulties encountered during the work should be documented. If procedures, training, or other aspects of your or the contractors confined space program are identified as needing revised these revisions should be completed.

Conclusion

Contractor operations involving confined spaces do not have to be terrible experiences for us or the contractor. Proper preparation can save much time and trouble. Investing in this preparation is essential to safety during these operations. Identify a few key contractors that are willing to work with your organization over the long term and work together to insure the safety of your operations. Confined space entry done well should present little if any increased risk to personnel. Confined space entry done poorly can be fatal.