Does your company regularly hire contractors, subcontractors, or suppliers? Are you actively vetting their health and safety programs and performances before onboarding them to perform work under your company’s name? Do you have a Subcontractor Management Plan in place? It is important you do if you are using subcontractors or contractors to perform work under your company name – not only is it a COR requirement, but a new SECOR requirement as of 2023, and without one, hiring contractors could be potentially pose a threat to your company.
A subcontractor management plan outlines a consistent method of information gathering from contractors and acts as a pre-qualifier, as it reviews the contractor’s:
• Health and Safety Management System, examining all programs, policies, and safe work procedures in place by the contractor.
• WCB account to ensure it is in good standing, reviewing the contractor’s injury statistics within recent years.
• Liability insurance coverage
• COR certificate or other similar certificates
This process helps to confirm that a contractor will adhere to the necessary safety standards and regulations set out by both Alberta legislation, and your own company’s health and safety standards. A well-crafted subcontractor management plan defines the roles and responsibilities of subcontractors, sets clear expectations for performance and quality, and ensures that all identified potential hazards and risks on site are communicated between contractors and Prime Contractors. This helps reduce the risk of workplace accidents and injuries; by outlining safety protocols and ensuring that all parties associated with your company are aware of and complying with them, therefore creating a safer work environment for everyone involved.
A contractor management plan would also ensure that onsite activities are running smoothly once work with them had commenced. It would outline that the contractor would be obliged to attend health and safety meetings or toolbox meetings held onsite by your company, guaranteeing that everyone onsite is involved, participating and aware of the existing and changing hazards present on the jobsite. Furthermore, a subcontractor management plan would encourage the contractor to participate in inspections, incident investigations, and hazard reporting as required.
It is the contractor’s responsibility report to and follow the requirements of the Prime Contractor or Contractor, through upholding their own health and safety program, reporting and hazardous or unsafe work conditions and cooperating with Health and Safety Representatives, all in accordance with the OH&S Act, Regulations and Code. This would be a required field of the subcontractor management plan.
Including your subcontractors and contractors in onsite activities; safety meetings, field level hazard assessments, inspections and so forth, is vital to you and your company to ensure hazards and safety concerns are being communicated between all parties. It is important to document these meetings and keep site-specific hazard assessments (field level hazard assessments) on file, as this is a requirement for both COR and SECOR audits. Including them in these onsite activities will help you monitor the contractors to ensure they are completing their onsite documentation. It is also important that you conduct performance reviews on your subcontractors and contractors,
as this will ensure you are assessing the quality of their work and their safety performance. Being
able to notice patterns of poor performance or non-compliance with your health and safety
program or OHS legislation will give you indicators on whether or not they should be re-hired, or
perhaps immediately let go if necessary. Or the flip side; contractors who can prove they are
willing to participate in all onsite meetings, hazard assessments and worksite inspections will gain
your company’s trust and respect, and allow for work to be continued with the contractor. Two-way
communication between subcontractors/contractors and Prime contractors is the end goal,
and a subcontractor management plan helps to facilitate this.
The significance of a subcontractor management plan goes beyond covering these basis’s –
without one you could be putting your client relationships at risk. Consider the risk of hiring on a
contractor without running a pre-qualification test on their health and safety system – let’s say they
cause considerable property damage to your Prime Contractors facility. During the incident
investigation, you determine that the contractor you hired has no insurance, no WCB coverage,
and your company is now on the line to pay for all damages. Not only are you out considerable
profits and have lost valuable work time – but your Prime Contractor no longer trusts your
company or the work that you do and has put an end to all future work with them. This could have
been prevented if you had vetted the contractor before hiring them to work for you.
In addition, if you or your company hires a contractor or subcontractor that does not have or may
not be eligible for a WCB account, you may be responsible for providing coverage and paying
premiums on their behalf – should an incident occur. Having WCB coverage not only protects
workers, but it also protects your company from any potential lawsuits. Administrative monetary
penalties should also be considered, as failure to comply with Alberta OHS legislation could lead
to fines up to $10,000 per day depending on the severity of the circumstance.
If you do not already have a subcontractor management plan in place or would like assistance in
ensuring yours meets the requirements, ask your Kasa Representative to guide you through the
process!