If you intermittently or frequently operate in a multi-employer work environment, this information may be of importance to you and your company’s day to day operations.  In this article, we wish to offer you guidance on how and when to implement strategies to effectively navigate safety and health situations that can and usually arise in a multi-employer worksite. There are many different types of multi-employer worksites. Some examples include construction, arts, and entertainment, retail stores, transportation, service (including lodging and health care facilities), mining, and communication. This article explores a few but does not address all circumstances that may occur.

What is a Multi-Employer Worksite?

Multi-Employer Worksites are defined as temporary or permanent worksites where two or more companies and their employees work at the same time and location.  Multi-employer worksites are common to many industries.  Typically, a multi-employer worksite’s hierarchy is a host-employer (which may be an owner, general contractor, or both) followed by contractors, subcontractors, or temporary staffing agencies. For the remainder of this article, we will refer to all non-host employers and employees as guest employers and employees.

Multi-Employer Worksite Activities

There are many great examples of multi-employer worksite activities. However, we chose to highlight the petroleum refinery industry. Mostly because petroleum refineries are both owners and host employers that periodically schedule rehabilitation projects, known throughout the petroleum refinery industry as a “turnaround.”

A turnaround requires an entire process unit to be taken offline for inspection, replacement, or repair of equipment including but not limited to exchangers, furnaces, vats, vessels, etc. A sizable workforce and a wide variety of skilled craftsmen are essential to return a processing unit to operational status. During a scheduled turnaround, a petroleum refinery contracts with a wide-ranging of companies skilled in various disciplines such as pipe fitting, welding, maintenance, industrial mechanics, scaffold building, and more. Large quantities of skill sets are needed to complete the project on time, on budget, and safely. Petroleum refineries have supervisory authority over the contracting companies.  Their contractual agreement allows them to legally control the work being done. They also have the authority to correct safety and health hazards or appoint others to correct them.

Prioritizing Safety

The host employer must ensure that each guest employer understands and agrees to follow the safety requirements at the multi-employer worksite. Such agreements may consist of conducting daily meetings between the host site safety managers and their guest counterparts, keeping established lines of communication open, implementing periodic safety inspections based on the hazard assessment level, and keeping everyone informed about changing worksite conditions and other potential problems and disseminating the host employer’s safety objectives to their employees.

How to accomplish it

We recommend setting high safety expectations early, for example, during the preconstruction phase; in the course of creating the host employer’s request for proposal (RFP). The inclusion of safety concerns in an RFP is an excellent time for the host employer to show safety is a priority now and going forward. Safety should always be considered whenever constructors submit their bids. Low bids should never be based upon sacrificing safety through inferior materials, equipment, and products or poorly trained personnel. Also, a company’s good standing safety history should be a qualifying requirement for proposals or bid submissions, and a copy of their injury and illness prevention program (IIPP) should be submitted with their proposal packet.  Also, contractual agreements should determine each contractor’s authority, responsibilities, and obligations concerning communicating safety and health concerns relating to hazardous conditions, as well as defining who has the authority and the expertise to mitigate hazards.

Now maybe an appropriate time to point out in some cases, a company that may have created a hazard, may not have the necessary authority, expertise, or certification to mitigate the hazard. In these instances, establishing a multi-employer hazard mitigation policy is essential to put in place suitable personnel and the appropriate resources responsible for addressing hazardous situations, immediately and effectively.

A multi-employer hazard mitigation policy should include but not be limited to:

  1. An established mechanism for communication between host, and guest employers. It should be a reliable source for reporting hazards. Preferably, to a central source that can record and dispatch appropriate personnel to investigate and mitigate the hazard if the dispatched person is qualified
  2. It should encourage all employees to report safety and health hazards immediately without fear of reprisal or negative connotations.
  3. It should identify at least one employee per company who is available daily to respond to reported hazards promptly and have the authority, expertise, and certification to mitigate them completely or temporarily until a permanent fix can be found.
  4. It should employ a mechanism for timely follow-ups so hazardous conditions do not exist for extended periods and successful mitigations are verified and recorded.

Multi-employer Worksite Hazard Assessment:

Before a full entourage of host and guest employees arrive at the worksite for their first day of work, OSHA requires the host employer to verify a multi-employer worksite hazard assessment has been done, via a written certification. The content of the certification will identify the workplace evaluated; the name of the person or persons certifying a completed evaluation; and the date the hazard assessment was done. Collectively, the aforementioned requirements serve to identify the document as a certification of hazard assessment.

Note: OSHA doesn’t require the actual hazard assessment to be a written document, only the hazard assessment certification is required to be in writing and certifiable. However, host and guest employers alike will be well served by a comprehensive and well-documented hazard assessment. For example, photos, videos, and comprehensive notes are invaluable when brainstorming away from the worksite is necessary.

Hazard assessments are fundamental components of any effective safety and health program and often lead to opportunities to improve program performance. Hazard assessments yield the best results when performed by an experienced industrial hygienist or safety professional team. Once the hazard assessment team is assembled, a thorough examination is done of the entire worksite under the direction of the hazard assessment team leader.

A list is created categorizing and prioritizing identified hazards of all operations, equipment, work, and common areas, and facilities to be carefully evaluated. Identifying and controlling exposures to occupational hazards is the fundamental purpose of hazard assessment.

When executing a hazard assessment, typical hazards fall into several major categories such as chemical agents, biological agents, physical agents, general housekeeping, equipment operation, equipment maintenance, fire protection, fall protection, work and process flow, work practices, and lack of emergency procedures.

The hazard assessment team leader may assign one or more hazard assessment team members to each of the aforementioned major categories to determine how to implement feasible and effective control results. Successful hazard evaluations are dependent on selecting the most effective method of a hierarchy of controls

Hazard Control Plan

Now that your hazard assessment is completed, the next step is to create a hazard control plan. A hazard control plan will define comprehensive actions you will take to prevent and control hazards you have identified, including non-routine operations, such as foreseeable emergencies, including fires and explosions, chemical releases, hazardous material spills, unplanned equipment shutdowns, natural disasters, weather, and medical emergencies.

Note: Authorities such as local fire and emergency response departments, state agencies, the U.S. Environmental Protection Agency, and OSHA have regulations that require emergency planning

An effective hazard control plan will address the most serious hazards first. You should consider using temporary controls or combinations of controls when permanent controls are unavailable. Keep in mind the overall objective of the hazard control plan is to control hazards longterm and therefore periodic verification is needed.

How to accomplish it

Start by listing hazards and their controls in order of priority. Appoint specific employees to implement and install controls on relative hazards. Set completion dates or each hazard and track progress on completion. Defined how the hazard controls effectiveness will be measure after they are installed.

Create procedures to control non-routine operations, modify plans to control hazards that may arise in emergency situations, procure equipment to control emergency-related hazards, assign responsibilities for implementing the emergency plan, conduct emergency drills to test procedures and equipment. Once you have selected hazard prevention and control measures, implement them according to the hazard control plan.

Hierarchy of Controls:

A major component of an effective hazard assessment process and hazard control plan is determining which hierarchy control will be applied to hazards identified during the hazard assessment and hazard control evaluation.

Elimination and Substitution

Elimination and substitution are the most effective at reducing hazards. Conversely, however, they are also the most difficult to employ in an existing structure or process because they may require major changes in equipment and procedures to eliminate or substitute for a hazard. Elimination and substitution are most effective at the design or development stage and may be inexpensive and much simpler to implement.

Engineering Controls

Engineering controls are designed to eliminate the hazard at the source before employees are exposed. Well-designed engineering controls are highly effective in protecting employees and are usually independent of worker interactions while providing a high level of protection. The initial costs of engineering controls are generally higher than the cost of administrative controls. However, over-time, operating costs may provide cost savings in other areas of the process.

Administrative and Work Practice Controls

Administrative controls are policies, procedures, training, or work shift strategies that lessen the threat of a hazard to an individual and typically change the behavior of people rather than removing the actual hazard. Administrative controls are more effective than PPE because they involve some manner of prior planning and avoidance, whereas PPE only serves as a final barrier between the hazard and worker. The U.S. National Institute for Occupational Safety and Health (NIOSH) recommends administrative and safe work practice controls when hazards cannot be removed or changed, and engineering controls are not practical.

Work practice control, also known as safe work practice is a workplace practice meant to lessen the potential for harm by using the safest methods to perform a task. Work practice controls are implemented to ensure that employees follow determined best practices when performing a task. Some safe work practices can be as simple as pushing a handcart versus pulling, or more complex as implementing a confined space entry program.

Personal Protective Equipment

When engineering, administrative and work practice controls are not feasible or do not provide sufficient protection, the employer must implement a personal protective equipment (PPE) program. This program should address the hazards present; PPE selection, PPE maintenance, and usage of PPE; as-well-as training of employees; monitoring of the program, and program’s ongoing effectiveness.

PPE is the last barrier of protection from exposure to hazards that cause serious injuries and illnesses, such as chemical, radiological, physical, electrical, mechanical, or other workplace hazards. Some examples of PPE are hard-hats, safety glasses, face-shields, gloves, reflective safety-vest, workboots, earplugs and earmuffs, respirators, self-contain air-breathing apparatus, coveralls, rain-suits, and more.

Employers are required to train their employees in the usage of personal protective equipment to know: when it is necessary, what kind is necessary, how to properly put it on, adjust, wear and take it off.  All PPE should be safely designed and constructed and maintained cleanly and reliably. It should fit comfortably, encouraging worker use.

Inclusion At Multiemployer Worksites:

All multi-employer worksite employers must establish mechanisms to coordinate their employees and communicate information to ensure that every employee at the worksite and their representatives can participate in efforts to prevent and control injuries and illnesses and that workers are afforded equal protection against hazards.  Communication and coordination are crucial to consistent operation cohesion.

In a multi-employer work environment, all employers must be invested in a program that will provide a consistent level of safety and health protection for their employees.  The safety and health programs at multi-employer worksites must ensure that all workers, whether permanent or temporary, host or guest employees, receive the same information and are afforded the same opportunities to participate in program activities. Inconsistent safety policies may cause workers to question the credibility of safety and health programs, resulting in less meaningful employee engagement and participation.

For example, if different employers have varying requirements for their employee’s personal protective equipment (PPE), some workers may incorrectly believe that PPE is optional or not needed, leading to preventable injuries or illnesses. It is the host employer’s responsibility, however, to establish uniformed safety policies for the day to day operation of the entire worksite, including PPE requirements.

The policy should include but not be limited to:

  1. Recording and reporting any injuries, illnesses or life-threatening hazardous condition
  2. Conducting daily safety meeting sitewide
  3. Provide copies of the safety and health policy to all personnel
  4. Enforce standard PPE requirements
  5. Encourage and enforcing good housekeeping
  6. Encourage using Job Safety Analysis when initiating a job

Employee participation

The success of a safety and health program can be measured by the wellbeing and fitness outcome of the employees it is intended to serve. In many situations, host and guest employees work alongside each other and need equal access to relevant safety and health information regardless of their skill level, education, or language. Employee’s safety and health needs are best served when allowed to fully participate in every aspect of the safety and health program. This will allow every employee at the multi-employer worksite to benefit from the program and to contribute their insights to make the program more effective. Meaningful participation in the program requires employees to believe that their input is welcome and their voices will be heard.

A host employer should provide every opportunity for all employees to participate in their safety and health program.  A great place to start is to signal to all personnel employed at the worksite that their input is valued and their participation is welcome. This can be accomplished simply by maintaining an open-door policy that invites employees to talk to managers about safety and health. Also, acknowledging employees who actively participate in the program. Set policies that authorize sufficient resources to ensure employee participation; for example, hold safety and health meetings during employee’s regular working hours.

The safety and health program should provide a method for employees to report injuries, illnesses, near misses, and other safety and health concerns. The reporting process should have an anonymous element to reduce any fear of reprisal.  The safety and health policies should emphasize reporting safety and health concerns will not result in retaliation. If employees are fearful of retaliation, participation in the safety and health program is likely to be suppressed. For example, if an investigation is seeking to blame individuals instead of focusing on underlying conditions that led to the incident.

Employee’s input should be included at every step of program design and implementation. It will improve their ability to identify the presence and causes of workplace hazards, create a sense of program ownership, and enhance employee’s understanding of how the program works.  Employees are best situated to recognize safety and health concerns and program defects that may initiate workplace hazards.  A prompt follow-up on employees’ reported concerns may prevent potential injuries or illnesses in the workplace.

Empower all employees with stop-work authority to temporarily suspend work activity or operation they believe may be unsafe or unhealthy.  Encourage host and guest employees alike to raise safety and health concerns. Including how and to whom the employee should report hazardous conditions, incidents, near misses, injuries, and illnesses.  The safety and health program should analyze hazards in each step of routine and non-routine jobs, tasks, and processes. Safe work practices should be defined, developed, documented, and revised as needed.

OSHA requires employers to provide their employees with specific safety and health information such as Safety Data Sheets (SDS), Injury and illness data, environmental exposure monitoring result, workplace job hazard analyses, equipment manufacturer safety recommendations, inspection reports, and Incident investigation reports

Note: OSHA seeks to discourage employers from creating incentive programs for workers or managers that link performance evaluations, compensation, or rewards to low injury, and illness, as rates can discourage injury and illness reporting, or point systems that penalize workers for reporting injuries, illnesses, or other safety or health concerns.  OSHA has compared these actions to have a negative effect as do mandatory drug testing after reporting injuries.

Safety and Health Training

Education and training are extremely important methods for communicating useful information on the requirements of efficient safety and health protection to all employees. Without such knowledge, managers, supervisors, and other employees could not carry out their duties for safety and health protection.

Safety and health professionals have long acknowledged stand-alone safety and health programs can be too narrow in scope and not meet companies’ individual needs. Many prefer integrating safety and health protection considerations into organizational activities.  Safety and health information is most effective when incorporated into other training such as management training, performance evaluation, problem-solving, managing change; and supervisors’ training.

The act of training itself is not enough to develop a useful understanding. employers must make sure employees, supervisors, and managers understand safety and health information.  Employers should consider formal testing, oral questioning, and observation as ways to determine comprehension. Safety and health management should apply the same diligence concerning safety and health protection as is applied to ensuring an understanding of other operational requirements, such as time and attendance, production schedules, and job skills.

Employers should make sure that all employees recognize the hazards to which they may be exposed. and utilize established methods that have demonstrated harm prevention to themselves and others from exposure to these hazards, so that employees accept and follow established safety and health protections.”

The employee’s commitment and cooperation are critical for preventing and controlling exposure to hazards, not only for their own safety and health but for others as well.  That commitment and cooperation are based on their understanding of the hazards they may be exposed to, why the hazards pose a threat, and how they can protect themselves and others.

Education and training in safety and health protection are especially critical for employees who are assuming new duties. Employees have a higher disproportionate rate of injury when they are assigned new work tasks. While a few of these injuries may be attributable to other causes, a significant amount remain directly linked to the inadequate experience of work hazards and safe work practices.

The amount of hazard information which is required by employees will vary, but should include:

  1. The general hazards and safety rules of the worksite
  2. Specific hazards, safety rules, and practices related to particular work assignments, and
  3. The employee’s role in emergency situations, such information is particularly relevant to hazards that may not be readily apparent within the ordinary experience and knowledge of the employee.

Ensure that supervisors understand their responsibilities and the reasons for them, so that they will carry out their safety and health duties effectively.

  1. analyzing the work under their supervision to identify unrecognized potential hazards,
  2. maintaining physical protections in their work areas, and
  3. reinforcing employee training on the nature of potential hazards in their work and on needed protective measures, through continual performance feedback and enforcement of safe work practices.

First-line supervisors have an essential obligation in the safety and health protection of their employees and for the job being done. Appropriately trained supervisors will focus on their safety and health management responsibilities as well as hazard prevention and response to emergencies.

Ensure that managers understand their safety and health responsibilities so that the managers will effectively execute them. Managers who understand the way and the extent to which effective safety and health protection impact the overall effectiveness of the business itself are more likely to ensure that necessary safety and health management systems operate as needed.

Multi-Employer Program Evaluation and Improvement

Once the initial safety and health program is established, evaluate the program to verify that it has been implemented as intended, and continue to evaluate it regularly.  Whenever opportunities arise make adjustments to improve the program and monitor the results.  Share the result of your monitoring and evaluation with others to help make further improvements. Establish metrics to indicate the program’s effectiveness track and report your findings.

Define an applicable method of indicators to measure performance and establish procedures to collect, analyze, and review performance data. Performance indicators should include both leading and lagging indicators. Lagging indicators track worker exposures and injuries. Leading indicators indicate the potential for injuries and illnesses.

Develop and track progressive indicators to improved safety and health objectives. Lagging indicators should include the number of severities of injuries and illnesses, results of worker exposure monitoring, and amounts paid to workers’ compensation claims.

Safety and health leading indicators should track the degree of an employee’s participation in the program, the number of employees who have completed required safety and health training, the number of hazards and near misses reported, management response time to reported incidents and hazard mitigation, frequency of management walk-throughs, number of hazards identified during inspections, number of days needed for a correction after identifying a hazard or before an incident occurs, conformity to planned preventive maintenance schedules, and worker opinions about program effectiveness.

Indicators can be either quantitative or qualitative. Select indicators that are measurable and that reflect the program goals and identified areas of concern. the entire safety and health program should be evaluated at least once a year to ensure that controls are operating as intended, hazards are identified effectively and progress is driven toward defined objectives

How to accomplish it

Determine whether changes in equipment, facilities, materials, key personnel, or work practices trigger any need for changes in the program. Determine whether the metrics and goals are still relevant and how you could change them to more effectively drive improvements in workplace safety and health.

Note: The scope and frequency of program evaluations will vary depending on the scope, complexity, and maturity of the program and on the types of hazards it must control.