HEALTH & SAFETY OPINION

Health & safety: contractor competence in food factories

By Craig Foyle

- Last updated on GMT

Foyle: 'Where you use a third party you still have a responsibility to monitor what they do'
Foyle: 'Where you use a third party you still have a responsibility to monitor what they do'

Related tags: Regulation

Food manufacturers rely heavily on contractors for engineering design, installation, maintenance and construction work, so it's important they have robust processes to ensure that the contractors they appoint are competent.

Self-assessment

Initial questions to ask include: 

  • Does your organisation have a process for assuring contractor competence?
  • Is a nominated individual or function accountable for the process?
  • When was the last time the process was audited and reviewed?
  • If you use a third party to check competence, when did you last review their performance?
  • How are the findings from audits communicated throughout your organisation?
  • Does your organisation check that the work you want a contractor to do has been specifically checked? 

If you cannot answer all of these points positively then this article aims to point you in the right direction. 

Requirements​ 

You have a legal requirement to check competence and manage your contractors. The Health & Safety Executive may ask you to demonstrate how you do this, following an incident. ISO 45001 (Occupational Health and Safety Management Systems) places a requirement to establish, organise, implement and maintain a process to control the procurement of goods and services, and to control risks for the organisation, contractors and third parties. Whether your organisation is assessed against ISO 45001 is irrelevant, as it will be expected that you comply with the principle. 

Procurement / Pre-qualification​ 

Those involved in the procurement process should understand the importance of completing this activity correctly – it can ultimately save time and a considerable amount of money later on.

There should be two stages to a contractor approval process.

Step one​ can be a document review where you check core information such as health and safety policy, competent persons, training records, equipment maintenance and certification, risk assessment and method statements and insurances. 

Step two​ should include a review of contractor performance on your site or, if it is a new contractor, it would be good to see how they operate on another site. 

Some companies use third parties to conduct the pre-qualification or contractor assessment process. Where you use a third party you still have a responsibility to monitor what they do and I suggest that you audit them periodically. The appointment of a competent contractor is still your responsibility, whether you check them in-house or use an external provider. 

Operational control​ 

You should consider how you will engage with contractors once they are on-site for production, maintenance, project work or even for unplanned work to deal with an emergency situation. This will include obtaining the following information, although this list is not exhaustive: 

  • supervision levels
  • risk assessments and method statements
  • training records
  • work equipment records of examination. 

Construction (Design & Management)​ 

It is important to consider how you manage construction work on your site. The CDM Regulations apply to all construction work, irrespective of the size. You should have a process in place to manage CDM and specifically check the competence of a principal designer and principal contractor if you appoint more than one contractor. If you take on the role yourself you must consider your own organisation’s competence and resources to conduct the roles – this includes competency and resources (time, equipment, number of personnel) available. 

Craig Foyle is chair of the Institution of Occupational Safety & Health (IOSH) Food & Drink Industries Group and a past president of IOSH.

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