Procurement, Contractors and Outsourcing Under ISO 45001 - Occupational Health & Safety Management Systems

ISO 45001:2018 is the occupational health & safety management system standard published in March 2018.  It shares a high-level structure, known as the Annex SL, with other ISO management system standards, such as ISO 9001:2015 and ISO 14001:2015. In a nutshell, it’s a logical structure for all future development of ISO standards to follow, meaning that every ISO standard has the same structure.

Additionally, the ISO 45001 was purpose-designed to closely follow the ISO 14001. This is because it’s recognised that many organisations combine their occupational health & safety management and their environmental management functions internally.

But, what about external elements, like contractors and outsourcing?

Most businesses use contractors at some stage. In fact, they’re a growing feature of running a modern business. But there’s a potential minefield here. Why? Because contractors are outside of your management system, even though the outsourced function or process you’re using them for is firmly within your scope.

So, in this article, we’re taking a look at the controls you need when you’re outsourcing processes that impact your occupational health & safety management system.

Procurement

It’s essential to have a robust procurement process is for controlling product and service inputs into your business. 

To this end, you need to put a process in place to control the procurement of products and services and ensure their conformity to your occupational health & safety management system.

In order to do this effectively, your procurement processes need to –

1. Control potential hazards and reduce occupational health and safety risks associated with the purchase and introduction of:

• Products
• Hazardous substances
• Raw materials
• Equipment
• Services

2. Address the need for consultation and communication with all interested parties, such as your workers, contractors and/or visitors

In short, it’s your responsibility to ensure that the equipment, installation services and materials purchased are ultimately safe for your employees, by:

• Ensuring that equipment is tested and functioning as intended
• Carrying out risk assessments prior to equipment being used
• Making certain that materials are delivered in accordance to specifications
• Guaranteeing that all equipment is supplied in accordance with legal requirements
• Purchasing equipment with a technical specification, such as CE-marking or UKCA marking
• Confirming that any installations commissioned function as designed
• Communicating usage requirements, precautions and other proactive measures to employees, workers and/or contractors, and making them readily available, at all times, on an ongoing basis

Contractors and Outsourcing

It’s not unusual for businesses to use the services of contractors to plug gaps in processes and / or to complete tasks requiring specialist knowledge.  Examples of contractor activities and operations might include –

• Maintenance
• Construction
• Security
• Cleaning
• Facilities management
• Waste management

to name but a few.

In addition, contractors might also provide administrative consultancy or specialist services, in areas such as accountancy, HR, and marketing. 

Outsourcing or sub-contracting can include system processes, such as internal auditing of the management system, as well as operational procedures, for example, welding and scaffold building.

But it all comes down to the standard requiring you to assess contractors, including due diligence and company checks. And for this purpose, you might want to think about using contractor selection criteria to help ensure that services are within the scope of the task.

The outsourced process is an important element of your occupational health & safety management system. So, you need to have control of the outsourced functions AND the processes. This helps you to ensure that –

• Your outsourced arrangements are compliant with legal requirements
• The external provider understands what is required
• The work meets your expectations and also your occupational health & safety management system

But, bear in mind that the assignment of activities to contractors doesn’t reduce your responsibility in terms of their occupation health and safety. So, it’s down to you to ensure that your contractors, subcontractors and their workers meet the requirements of your occupational health & safety management system.

So, your procurement process needs to define and apply occupational health and safety criteria in the selection of contractors, ideally in contract documents or service level agreements (SLAs).

It all comes down to a holistic approach to occupational health & safety across your procurement process, in order to identify and mitigate hazards and control risks arising from:

• Contractor activities and operations that impact, or have the potential to impact your business - including external parties, such as visitors or members of the public
• As above, but in reverse, e.g. your business activities and operations that could have an impact on the contractor

Effective Ongoing Management of Contractors and Outsourcing

How you manage the complex relationships with contractors depends very much on the nature and extent to which services are provided. But it makes sense to clearly define as minimum –

• The responsibilities of the contractors
• The procedure for reporting hazards, risks and incidents between the contractor’s workers and your business
• The procedure to follow in the event of an emergency

In addition, you need to verify that the contractors have the relevant competency to perform the tasks, before you get them started. There are a number of different ways you can do this:

• Ascertaining if the contractor is certified to ISO 45001.
• Reviewing the contractor’s own occupational health & safety management documentation, such as risk assessments, safe systems of work and instruction manuals.
• Checking the contractor’s occupational health & safety performance in the workplace. For example, are there any HSE prosecutions, improvement notices, notifiable accidents or dangerous occurrences that might ring warning bells?
• Finding out about how the contractor consults with their employees. Do they have a formal process in place for communicating and engaging with their workforce and other interested parties?
• Determining the qualifications, competence and experience of their workers, through safety training and up-to-date certifications.
• Reviewing the contractor’s emergency and evacuation plans and procedures for evidence that they’re fit for purpose for the site and the work at hand.
• Going over their resources, equipment and work preparations with a fine-tooth comb ahead of work proceeding.

The importance of making the necessary checks and verifying contractor competence can’t be under-played. And it doesn’t end there, with completing the procurement process and appointing the best-matched contractor / sub-contractor.

Now, it’s best practise to support site activities with an induction programme. This provides the contractor’s workers with an understanding of site rules and specific requirements, such as –

• Hazards
• Authorised areas
• Safe walking routes
• Emergency action plans
• Permits to work
• Near miss reporting

A final word on this… Even when you’ve got to this point, it’s never a matter of leaving them to get on with it and paying them when they’re done. On the contrary, it’s your continued responsibility to monitor contractors when they’re conducting work on site.

After all, you want to know about it immediately if any contractors / sub-contractors aren’t working safely, within the parameters of risk assessments and safe working practises.

That said, nor does it have to be a case of breathing down anybody’s necks 24:7. As an overall rule of thumb, the amount of contact with the contractor should be related to the hazards and risks associated with the task at hand.

Documented Information

The standard requires you to maintain documented information about the procurement of products and services, including contractor arrangements.  This can include:

• Risk assessments and safe systems of work
• Material safety data sheets
• Certificates of conformity
• Contractor permits
• Completed external provider questionnaires
• Training records
• Email exchanges relating to safety aspects

At the end of the day, every business needs to purchase of goods and services in order to function. What the standard specifies is that you put controls in place to safeguard against introducing hazards or exposing workers to harm - including contractors - as a result of the products and services you purchase. And, if you’re using contractors, it supports you to stay in the driving seat when they’re working on your site.