It pays to know who and what you’re dealing with before the work begins.
If you’re a general contractor, you want your subcontractors to work as safely as possible. To make that happen—especially for subs you don’t know or haven’t worked with before—you need to manage their safety performance, says Charles (Lewis) Raymond, a certified safety professional. He is the loss prevention manager for Gray Insurance Co. in Metairie, LA, and spoke on the subject at the Construction Safety Council meeting last February in Rosemont, IL.
The low-bidding process can work against construction safety, because a general contractor (GC) usually awards the work to the low-bidding subs, who may cut back on safety to win the job. “A general contractor, or a subcontractor, who works safely will include money in his bid for safety,” says Raymond. “But one who works at risk may not include money for safety.
“As general contractors we generally don’t do a good job of monitoring subcontractors while they’re on the job. Sometimes we’ll put up with a substandard safety performance just to get the sub finished and get him off the project.”
It’s advisable for the GC to use a safety prequalification questionnaire for new subcontractors. Such a form will ask subs for the following:
- The experience modification ratio for the past three years
- The OSHA Recordable Incident Rate for the past three years
- Results of any OSHA inspections in the past three years
- Accident investigation procedures and communications
- Degree of participation by management and supervisors
- Frequency of supervisors’ safety meetings
- Written safety program
- Employee orientation practices
- Frequency of toolbox safety meetings
Before subs bid on the work, the general contractor should provide them with a checklist of requirements for safety. “That checklist should be part of the contract,” says Raymond. “In addition to the boilerplate paragraph about following all state and federal regulations, the GC should tell the subs the specific things he expects—like 100% fall protection, drug testing, how to do accident reporting, what qualifications the competent person should have, attendance at safety meetings, project audits and inspections, and so forth.
“The general can dictate what he wants,” Raymond says. “He can require that the subs’ competent person have 30-hour OSHA training. If I’m a general with a checklist, I want to see an accident prevention plan. I want to require that the subs do Job Hazard Analyses. And if I am a sub, I can develop a general accident prevention plan, put it on my computer, and then just tweak it for each specific new project.”
At a pre-bid meeting, the GC should emphasize that the subs’ bids will be evaluated for safety funding. “It works,” says Raymond. “You can review a bid for safety funding, or ask a sub what percentage of his bid covers safety practices.”
Prior to the award, the GC should review the checklist—the project-specific safety requirement checklist—with the subcontractors. Review the accident prevention plan. Who will be the onsite safety representative, and what are his or her qualifications?
And the GC should explain to subs the consequences of not following safe work practices. The GC can halt work for imminent danger or failure to comply with safe practices; workers can be removed for repeated or flagrant violations. There may be penalties.
At a preconstruction meeting, the GC should meet with subcontractor management, supervisors and the safety rep. The GC will:
- emphasize stakeholders’ commitment to common goals;
- reiterate expectations and communications policies;
- review the scope of work for understanding;
- review the accident prevention plan;
- explain the GC’s multi-employer policy for hazards;
- explain responsibility, accountability, and consequences; and
- issue a notice to proceed.
Measuring Performance
“If it gets measured, it gets done,” says Raymond. He recommends measuring subcontractors’ safety performances as the job progresses. You can develop a continuous rating system. It would measure the results of safety inspections, or audits. Do the subs wear personal protective equipment? Do they perform job-hazard analyses? How often are they doing toolbox talks?
If you measure subcontractors’ performance over time, you can tell if they’re getting better at safety, staying the same, or getting worse. “It’s a behavioral-based process,” says Raymond. “You can go through the project with a sub and grade them. Then you give them praise or corrections. But you need to provide subs with opportunities for improvement during the course of work.”
By doing all this, you help a subcontractor to build his safety program onsite, Raymond says.
At regular progress meetings, the project manager, site supervisors, and office personnel for the GC should attend—as well as management, site supervisors and the safety rep for the subcontractors.
“You really need the site supervisors at the progress meeting,” says Raymond. “Make safety the first order of business. You can discuss the results of inspections. A GC may want copies of subcontractors’ job-hazard analyses, and copies of the material safety data sheets if any new chemicals have been introduced since the job started.”
When it’s time to pay the subcontractors, the GC can solicit their feedback on their performance relative to their safety scores. Has their safety performance improved? Did they abate the hazards on the job?
“As a general contractor, you tell the sub, ‘Here’s what you’ve got to do to improve,’” says Raymond. “Or sometimes you can put up with them and guide them along.”
Finally, the GC can use his written scores to evaluate whether subs should be hired again. “Was there evidence that safety performance improved as the project progressed?” asks Raymond. “What was the response of the subcontractor to the required reporting, compliance practices, and abatement methods? What must that sub do in order to be hired in the future?”