Reimagining Contractor Qualification: How CQ Programs Can Better Ensure Compliance Down to the Employee Level
Run-of-the-mill CQ programs only qualify based on past factors and don't provide the ongoing management you need.
Contractor qualification (CQ) has been around for some time. Larger facilities are responsible for ensuring the safety compliance of employees that are not their own but are working on their job site. This poses some serious challenges. It would be nearly impossible for owners and operators to implement an all-encompassing safety management program for another company’s employees.
Enter CQ programs. They allow owners and operators to prequalify subcontractor companies to ensure adequate historical safety records and standards.
While most CQ programs do a decent job of making sure that subcontractors meet certain metrics of safety during the pre-qualification process, they stop short of ensuring that only qualified employees are performing tasks on their jobsites.
It doesn't have to be this way. By applying existing technologies, contractor qualification programs can be improved to track ongoing compliance, down to the specific tasks performed by individual employees.
Common CQ Program Requirements
Run-of-the-mill contractor qualification programs will enable users to do the following:
- Establish Risk Thresholds: The owner or operator sets various risk thresholds and tier standards that contractors, subcontractors, and vendors must meet in order to be able to perform work at their facility or jobsite.
- Total Recordable Incident Rate (typically must be under 4.0)
- Lost Workday Rate (typically must be under 1.0)
- Experience Modifier Rate (typically must be under 1.0)
- Supporting Documentation: The owner or operator requires various documents and records be uploaded during the pre-qualification process, including:
- Contractor licenses
- Tax ID
- Proof of incorporation
- OSHA 300A logs
- Various insurance documents
- Questionnaire: The owner or operator requires all subcontracting companies to complete a specific questionnaire that asks about company history, financial strengths, job size capabilities, jobsite safety, and more.
- Safety Policies: Based on answers to the questionnaire and the type of work the subcontracting company will be performing, the owner or operator requires the subcontractor to submit their company’s policies and manuals for the hazards they will encounter on the jobsite.
- Training Records: Based on answers to the questionnaire and the type of work the subcontracting company will be performing, the owner or operator requires the subcontractor to submit training records for the subjects relevant to the tasks their employees will be performing on the worksite.
CQ Program Limitations
The problem with the current CQ Program model is that it focuses on past performance when it is the safety performance of the company in the near future that owners and operators should truly care about. While past performances can be an indicator of future performance, there are better ways to ensure ongoing safety management.
Additionally, the current model relies on the honesty of the applying subcontractors. No contractor is going to make itself look bad while applying for a job. Even if the company looks great on paper, this may be through sheer luck or under-reporting of incidents over the past few years.
Finally, and perhaps most critically, the current CQ model’s focus is on the subcontracting companies and not on the subcontracting employees. Companies don’t get injured. Companies don’t drive forklifts, work in confined spaces, or on scaffolds. Employees do. Every effective safety program puts employees first; CQ programs should do the same.
Improving the Current CQ Program Model (Down to the Lowest Common Denominator)
Imagine you are the safety manager for a worksite with over 150 employees representing 15 different subcontracting companies present on the site today.
Sub employees are performing a myriad of hazardous tasks, including forklift operations, confined space work, and scaffold work. How do you ensure that any given employee is qualified to perform the task they are assigned?
By tracking subcontractor employees in a single database, owners and operators can add these elements to their CQ program and dramatically improve safety performance across their worksite, ultimately decreasing liability.
Features of a Superior CQ Program
- Auditing Employees in Real Time: Requiring subcontractor training to be uploaded to a cloud-based database allows owners and operators to check any subcontractor employee’s training records in real time on the jobsite.
- Ongoing Safety Management: Require subcontractors to submit proof of ongoing safety management to keep safety on everyone’s mind:
- Daily JSAs (check out these 4 Steps to Conducting Effective Job Safety Analyses)
- Weekly safety meetings
- Badging Employees: Require subcontracting employees to badge in at the gate. Add the following requirements to all subcontracting employees to standardize safety down to the employee level:
- Drug tests
- Background checks
- Training verification
- Site-specific orientation
- Badging also allows owners and operators to know who is on their site at any given time.
Making the Switch to Improve Compliance and Safety
At the end of the day, owners and operators and subcontracting companies are both responsible for the safety of employees on the worksite.
While the owner or operator shares this responsibility, subcontractors would do well to recognize the importance of safety, both for their employees’ wellbeing and for the potential of future work with the client.
Shifting contractor qualification programs so they focus on individual employee safety and emphasize continued safety monitoring increases overall compliance, reduces incidents, injuries, and contractor employee turnover, and ultimately achieves a significant return on investment for everyone involved.
Written by Rob Cowden | Chief Innovation Officer
Rob Cowden is the Chief Innovation Officer at Safety Plus, Inc. He holds a degree in Environmental
Science with an emphasis on Hazardous Material Management and spent years serving in the Army and
National Guard. Rob has been in the Safety Industry since 1990 and has been with Safety Plus since
1999. Rob was the chief architect behind the design of SafetyPlusWeb™, Safety Plus Inc’s proprietary
safety management software that is used by over 400 companies across the United States. Rob has held
multiple certifications in safety/environmental fields and has been a Guest Lecturer at several safety
consulting events in the last 5 years – most significantly dealing with technology applications in
construction. He is the father of 3 awesome children (Jake, Brooklyn, & Savannah) and husband to his
smoking-hot wife, Christie.
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