When developing a contractor Health, Safety, and Environment (HSE) corrective action plan, it is important to address the specific areas of concern and develop a comprehensive strategy for improvement. Here are some guidelines to consider when creating a contractor HSE corrective action plan:
Identify the Root Causes:
Begin by identifying the root causes of the HSE issues or incidents. Conduct a thorough investigation to determine the underlying factors that contributed to the problem.
Set Clear Objectives:
Clearly define the objectives and goals of the corrective action plan. These goals should be specific, measurable, achievable, relevant, and time-bound (SMART).
Involve Stakeholders:
Engage all relevant stakeholders in the corrective action plan. This includes contractors, employees, management, HSE professionals, and any other individuals or groups affected by or involved in HSE matters.
Allocate Resources:
Ensure that adequate resources, including personnel, equipment, and financial support, are allocated to implement the corrective actions effectively. This may involve budgeting for training programs, equipment upgrades, or process improvements.
Prioritize Actions:
Prioritize the corrective actions based on their potential impact and feasibility. Address the most critical issues first to mitigate immediate risks and ensure the plan's effectiveness.
Develop Action Plans:
Create detailed action plans for each identified issue. Clearly outline the steps, responsibilities, and timelines for implementing the corrective actions. Assign ownership to individuals or teams responsible for executing each action.
Training and Awareness:
Provide appropriate training and awareness programs to employees and contractors involved in the corrective action plan. Ensure that everyone understands the importance of HSE and their roles in maintaining a safe working environment.
Monitor and Evaluate:
Establish a system for monitoring and evaluating the progress of the corrective actions. Regularly review and measure the effectiveness of the implemented measures. This may involve key performance indicators (KPIs), audits, inspections, and incident reporting.
Continuous Improvement:
Foster a culture of continuous improvement by encouraging feedback, suggestions, and lessons learned. Incorporate feedback from employees, contractors, and stakeholders into the ongoing refinement of the corrective action plan.
Communication and Reporting:
Maintain open and transparent communication channels throughout the implementation of the corrective action plan. Regularly report progress, milestones, and any updates to all relevant stakeholders.
Compliance and Documentation:
Ensure that the corrective action plan aligns with applicable laws, regulations, and industry standards. Maintain accurate documentation of all actions taken, including incident reports, training records, and compliance documentation.
Review and Update:
Periodically review and update the corrective action plan to address new risks, emerging issues, or changes in regulations. Incorporate lessons learned from previous incidents or HSE improvements to refine the plan further.
Remember, every corrective action plan should be tailored to the specific needs and circumstances of the contractor and the project at hand. It's crucial to involve HSE professionals or consultants to provide expert guidance and support throughout the process.
1.0 procedure
Contractors will identify and list the nature or type of
injuries, from their previous years' OSHA 300 Logs that have driven their
incidence rates above the Bureau of Labor Statistics (BLS) industry averages
for construction.
Examples:
We have identified that X percent of our ’03 and ’02
DART-L cases/recordable were related to hand lacerations, muscle sprains, etc.
- Or
We have determined that X percent of our injuries
occurred while handling drywall, welding piping, cutting ductwork, etc.
2.0 Job SAFETY Analysis
Subcontractors must develop a job safety analysis (JSA)
for the XYZ Project as part of the corrective action plan.
A JSA should list the steps that will be performed in the
execution of the subcontractor’s work, the specific hazards associated with these
steps, and the controls to be implemented to prevent these hazards (authorities
must address the significant sources of injury experienced from the
subcontractors’ formal records).
Example: Our
scope of work will involve receiving, hoisting, and installing [drywall,
siding, ductwork, piping, etc.] on various floors and around shafts in the XYZ
building.
Safe Work Methods
Specific Task
- Off-loading material from trailers
- Install material in the shaft
- Welding/Cutting/Grinding
Specific Hazards
- Loss of control of load
- Lacerations/punctures
- Slips/trips
- Struck-by
- Loss of control of load
- Back; muscle strains
- Punctures/lacerations
- Fires
- Flash; burns; objects in the eye
Safe Methods to be Used
- Loads to be determined; rigged by licensed riggers; rigging inspected; band palletized material; certified forklift operators used; approved boom attachments used; loads secured with taglines; rigging equipment inspected and certified annually.
- Employees will wear Kevlar gloves; nails to be removed from crating material and stacked and disposed of; metal bands disposed of immediately.
- Use of ladders or stairs ascending trailers; packing disposed of properly; aisles maintained clear and unobstructed.
- Suspended loads secured with taglines; material stacked and blocked to prevent displacement; employees instructed to stay away from pinch points; swing radius barricaded and spotters placed.
- Guardrails used or employees wear personal fall arrest system (harness and lanyard) secured to an anchorage point of 5,000 lb (2268 kilograms); 100 percent of the time above 6 feet (1.8 meters)
- Area to be flagged below and spotter placed to restrict access; 3-point contact on ladders maintained; ladders adequately positioned.
- Mechanical means (dolly; chain fall; genie lift; etc.) of adequate capacity to support the load.
- Sufficient employees for tasks; manually handled loads limited; proper lifting techniques and body mechanics employed.
- Gloves are to be worn at all times; sharp edges are taped.
- Remove or protect combustibles; place adequate fire extinguishers with trained fire watch; barricade/spotters below; separate oxygen and acetylene tanks and shut off equipment not in use; inspect leads and hoses/gauges regularly.
- Welding helmets worn with safety glasses; flame-resistant clothing worn; flash screens used to protect others.
3.0 IMPLEMENTATION PLAN
- In addition, briefly address how you will implement the following HSE management items:
- Additional supervisory employees to manage the workforce
- The ratio of supervisors to workers is to be discussed at the contractor alignment kickoff meeting
- Safety personnel/staffing – One full-time person during the onset of activities plus one additional for each increment of 50 workers
- Personnel approved by client and Fluor HSE
- Employee training
- Daily/weekly safety communication to employees
- Incident investigation
- Injury management/return-to-work
- Safety incentives and recognition
- Discipline
Also, subcontractors will provide the latest EMR, number
of OSHA recordable, DART L cases, and all employee hours worked to date in the
current year and the most recent full year for review at this meeting.
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