PICS Safety Audit Symposium

12/14 PICS will be holding its first annual Safety Audit Symposium in Irvine, CA. Safety professionals will learn about regulatory updates, auditing manuals and records, as well as field audits, in a full-day seminar. PICS is the leading provider of contractor safety audits in the USA for the Oil & Gas Industry.

Jeff Jensen
The Contractor Qualification Expert

NCMS out of the game

As many of you probably have heard, National Compliance Management Services, Inc (NCMS) is no longer performing safety manual audits for OSHA and PSM compliance. This has left many operators scrambling to find a new safety manual auditor. This week, I just finished our new online safety manual auditing interface, built on the robust platform that we developed several months ago when we completely digitized the prequalification process. At PICS, we anticipate picking up several of NCMS' former clients, and are quite certain that once companies get used to using our easy-to-use online database to screen their contractors, it won't be long before they start asking themselves if a safety manual audit alone is sufficient to verify that their contractor are implementing their programs.

Recently my partner, John, presented to Conoco Phillips about how our auditors can actually go in and verify most of the data we collect in the pqf, and how they can then run reports based on any of those questions to see how many and what percentage of their preferred contractors are compliant. They have been somewhat lax in the past, but now with our tight system, they're going to start cracking down and enforcing a no exceptions policy to make sure they aren't exposing themselves to any unnecessary risk by not using PICS audited contractors.


Jeff Jensen
The Contractor Qualification Expert

Power-Gen

Last week the crew was in Las Vegas for Power-Gen. There were tons of people and exhibitors there. Unfortunately, we found that most of the decision makers were not there, so it wasn't as productive as we'd hoped for. But we did get lots of contacts that we are following up on this week

Jeff Jensen
The Contractor Qualification Expert

The value of PICS

Pacific Industrial Contractor Screening (PICS) has 2 main benefits:

The first involves OSHA. As I explained earlier, there are several things that OSHA could cite you for - insufficent training, lack of documentation, unsafe work environment, etc. The caveat is that you are also potentially liable for your contractors' actions and performance. If you don't take sufficient measures to verify the OSHA compliance of contractors working at your sites, you could be cited and fined too.

PICS helps filter those contractors out through our thorough reports and safety audits. We are well versed in the current regulatory environment, and have developed an expertise in identifying and evaluating potential non-compliance issues. We first collect extensive prequalification information, such as work history, references, past citations, financial ratings, OSHA logs, etc. Our online database automatically flags potential risks. We then send an auditor onsite to review manuals and programs, and most importantly, to VERIFY IMPLEMENTATION. A program or manual is of no value if all it does is sit on a shelf and collect dust. By going on site and seeing operations and documentation, something none of our competitors currently do, we ensure that you are not just relying on the contractor's statement that they are compliant.

This leads to the second main benefit of the PICS service - we reduce potential hazards and help enforce safe working conditions for your employees and contractors. Aside from government penalties, PICS helps reduce injuries, and all the negative consequences it entails - lost worker productivity, litigation by the injured, higher insurance and bonding rates, and reduced employee morale. If by using the PICS service you eliminate even one injury or fatality, the cost of the service has paid for itself many times over. Every year, 6,000 American workers are killed in on-the-job accidents. Our goal is to ensure that workers can go to work every day with no doubt about the safety of their work environment. And that's what really drives us at PICS.

Jeff Jensen
The Contractor Qualification Expert

American Petroleum Institute

For the next few days, my partners, Jared and John, will be at the American Petroleum Institute's 2005 Contractor Safety Management Conference in Austin, Texas. We are trying to get the word out about our contractor prequalification system. We were recently listed as a best practice affiliate company for British Petroleum and Conoco Phillips. We manage their contractor qualification information for a few of their refineries in California.

We recently added some new sections to our pre-qualifcation form (PQF) that the contractors in our database must fill out to join the PICS network. I added some sections on Process Safety Management, DOT pipeline operator qualification, marine vessels, and DOI minerals management. We're trying to make our information as general and universal as possible to allow contractors to only have to fill out our one qualification, thus reducing the redundancy often encounered at several different facilities.


Jeff Jensen
The Contractor Qualification Expert

SafetyManuals.com

Since the first part of OSHA regulations involves having up-to-date safety manuals and documentation, some associates and I are working on putting together a website that will provide these documents online for a minimal fee. SafetyManuals.com will provide digital word document templates for safety programs, training records, posters, etc. that can be easily downlowded and customized to ensure your company meets current OSHA regulations.

Jeff Jensen
The Contractor Qualification Expert

What are the consequences of non-compliance?

Companies found to be out of compliance face several important challenges. From an employee standpoint, a non-compliance action from OSHA, confirms original suspicions that their workplace was not necessarily safe and that management is not actively involved with safety. This may create more distrust and anxiety amongst your work force and can spark additional complaints.

Furthermore, OSHA violations are publicly available and can create a poor company image. Lastly, a range of potential citations and penalties is possible for violations identified during an OSHA inspection. The area director has some discretion in determining the nature of, and the penalty for, a violation.

Citation categories and associated penalties include:

1. De minimis, penalties unlikely
2. Other-than-serious, $1,000 to $7,000.
3. Serious, $1,500 to $7,000.
4. Failure to post, up to $7,000.
5. Willful, $5,000 to $70,000.
6. Criminal willful (determined after a finding of guilt in a criminal proceeding), up to 6 months' imprisonment and a $250,000 fine for an individual or a $500,000 fine if the employer is a corporation (for a first violation).
7. Repeated (determined in a follow-up inspection), up to $70,000.
8. Failure to abate, up to $7,000 per day.
9. Recordkeeping, typically an "other-than-serious" finding unless it involves falsification of records, which carries a potential 6-month imprisonment and a fine of up to $10,000.
10. Assaulting, interfering with or resisting an inspector in the performance of his or her duties, imprisonment for up to 3 years and a fine of up to $5,000.

Jeff Jensen
The Contractor Qualification Expert