All workers under the control of the organization
There are many gruesome stories related to a lack of control of contractors, where they get killed or cause a big spill. But I don’t want to get into the gruesome details. I want to focus on the day to day contractors, who come into your site. Some have been coming to your site for years, they almost feel like a regular employee. So much so that they don’t even sign in at the front reception any longer, they just pull their van up to the door closest to the maintenance department. Sometimes, they don’t even stop in and acknowledge their arrival to the maintenance supervisor, they just walk and start their work. In some cases, this may not cause any impact, but in other situations problems can arise. It is up to every organization to decide how they intend on controlling the workers under their control. And yes, as soon as a contractor comes onto your site, they become a worker under your control.
The expectations for the management of contractors has significantly increased with this new version of the standard. There are 3 specific areas that have to be considered when managing contractors: training, communication and controls.
Within the ISO 14001:2015 standard, contractors fall under 3 categories:
- Interested Parties
- Outsources Process
- Persons doing work under the organization’s control
Contractors are an interested party because they want to work with your organization, so you have influence over what they do while they are working for you. There are also specific requirements related to communicating the environmental policy (5.2) and emergency response procedures (8.2) as relevant. Additionally, contractors may be a group that your organization creates an external communication strategy for (7.4).
As an outsourced process, there is requirement for identifying requirements for the procurement of products and services, as well as communicating these requirements to external providers (8.1). (External providers is the new term used for suppliers.) As an organization, the expectation is to not outsource your environmental impact. You need to understand the impact to the environment by having another party perform the work required. Now, this can be an improvement to the environment, particularly if the contractor is a specialist in their field and manage the environmental impacts very effectively. The consideration of life cycle perspective can also be brought into the discussion and identification of environmental aspects when discussing contractors.
Finally, contractors are persons doing work under the organization’s control. There are now greater expectations with what is done with contractors. In the 2004 version of the standard, you could get away with just a letter sent to the contractor including the expectations or requirements with respect to the environment. However, now the expectation is much greater. For every contractor (or person working under the control of the organization), they must be made aware of the organization’s environmental policy, aspects and impacts, benefits of the EMS and consequences of not following it (7.3). Additionally, your organization needs to understand the required competencies for these contractors and keep records of their performance (7.2).
The “How To” is an area that we can discuss another day. It can be simple or complicated, completely dependent on the number and complexity of contractors coming onto your site. We have developed a simple table summarizing all of the elements that can be relevant to contractors.
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If you need further support with implementing sufficient contractor controls or any other part of your transition to the new ISO 14001, feel free to contact us to see we can help you.