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Houston Business Roundtable

Third Party PSM Audits

PSM Third Party Reciprocal Audits

Basis

OSHA 1910.119 (h)(2)(v) The employer shall periodically evaluate the performance of contractor employees in fulfilling their obligation or specified in paragraph (h)(3) (contractor responsibilities) of their section.

Concept

Contractor member companies (and others) will be able to utilize a 3rd party contractor to conduct non-site specific audits of their safety programs therefore reducing redundancy and cost.

Benefits

  • Provides Standardized Industry Audit Process that is “OSHA Tested”
  • Improves compliance and raises the performance standard
  • Provides a foundation document for owner companies to do site specific audits
  • "Frees-up" Owner resources to concentrate on site specific audits
  • Eliminates redundant audits therefore reducing resources and costs for both owners and contractors
  • Use of third party consultant would add consistency - leading to industry standardization
  • Provides a corrective action feedback loop as well as deficiency tracking
  • Audit process raises the base level safety process for all contractors particularly the smaller contractor

Overview

  • HBR and GBRIA manage the process
  • Audits cover contractor programs, processes and results, but will not cover site specific programs or requirements
  • Contractor pays for 3rd party auditor to review their safety program
  • Satisfactory audit reports qualify contractors as “Active” and are good for 3 years from date of completed report
  • Audit is accepted by participating owner companies
  • Audit reports are issued within 2 weeks of audit completion
  • Contractor is responsible for remaining in “Active” status by completing and passing the audit with a satisfactory rating every 3 years. “Active” contractors are those that have a current audit report on file at HBR and GBRIA without deficiencies and those with deficiencies that have submitted a corrective action plan and not failed to meet required timing for completing corrections.
  • Contractor has 14 days from audit completion to issue corrective action plan for deficiencies when needed

Cost

  • There is no cost to the owner requesting audit. Contractor pays a fee of $1000 for the audit before the audit is performed.

Audit Process

  • Contractor schedules audit with 3rd party auditor. Contractor should schedule audits threemonths in advance of due date.
  • Contractor sends audit fee payment to HBR or GBRIA as appropriate for their business location.
  • 3rd party auditor provides contractor with standardized self evaluation questionnaire and performance data to be completed and returned a minimum of one week prior to the audit date
  • 3rd party auditor confirms audit time and date with contractor
  • 3rd party auditor performs audit with contractor at a participating owner company facility whenever possible (if no work is being performed at a participating owner facility, audit will take place at the contractor's work location).
  • 3rd party auditor sends final report to contractor and HBR or GBRIA within 14 days of audit completion. HBR or GBRIA will maintain the audit reports in a master file and upload file into XNET.
  • HBR or GBRIA Owner Companies may obtain a copy of the last audit report from HBR or GBRIA.

Corrective Action Plans

  • During the closing conference of the audit the contractor will be notified if any significant deficiencies must be addressed with a Corrective Action Plan (CAP)
  • Corrective Action Plan must be submitted to the 3rd party auditor by the contractor within 14 days of receiving audit report
  • The corrective actions must be completed within 90 days and documentation submitted to the 3rd party consultant for auditing. Upon satisfactory audit completion the 3rd party auditor will submit completed CAP report to HBR or GBRIA. HBR or GBRIA will maintain master file
  • HBR will upload CAP into XNET

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