Contributed by Jeri Thrasher, CSP, MBA, Health and Safety Director, PPM Consultants
As the Health and Safety Director at PPM Consultants, Inc. (PPM), I am responsible for ensuring compliance with health and safety regulations across the organization. Our comprehensive Health and Safety Program is designed to protect our most valuable asset—our team of nearly 120 scientists, engineers, geologists, technicians, and support staff—who make PPM a great place to work and grow. By diligently tracking and documenting our health and safety protocols, PPM demonstrates our commitment to safety, not only for our employees but also to our clients.
Many of our clients—referred to as “host facilities”—operate in industries such as energy, manufacturing, commercial, government, and retail UST. These organizations rely on contractor management systems (CMS) to oversee the compliance and safety performance of their consultants. CMS platforms act as third-party verification systems, ensuring that environmental, health, and safety (EHS) programs meet the standards expected of consulting and contracting firms like PPM and our subcontractors. While ISNetworld and Avetta are among the most widely used CMS platforms, various other systems exist, each offering unique functionalities and compliance mechanisms. The fundamental purpose of these CMS platforms and associated services is to streamline the compliance processes set by subscribing host facilities, ensuring that contractors meet predefined regulatory and safety standards. In essence, these systems act as third-party auditors, meticulously evaluating the EHS practices and compliance records of contractors and consultants like PPM.
Functionality and Compliance Requirements
Contractors seeking to engage with host facilities through a CMS must first subscribe to the platform. Once enrolled, they receive guidance on the specific compliance actions required by each host facility. These requirements often include:
- Uploading safety programs, experience modification rates (EMR), and Occupational Safety and Health Administration (OSHA) logs.
- Submitting statistical safety data, training attendance records, and relevant certifications.
- Providing photo documentation of specific safety-related tasks, such as fire extinguisher inspections, vehicle inspections, and other regulatory compliance activities.
- Responding to auditor reviews and addressing compliance gaps as identified through the system.
As a participating contractor in multiple CMS platforms, PPM is required to maintain full compliance to gain site access and execute tasks at host facilities. Through this experience, PPM has recognized both significant benefits and notable challenges associated with the use of contractor management systems.
Benefits of Contractor Management Systems
- Centralized Data Management
One of the primary advantages of a CMS is the ability to input and upload compliance-related documents and safety data once, making them accessible to all participating host facilities. This eliminates the need to submit the same information multiple times to different companies. - User-Friendly Interface
The CMS platforms currently in use by PPM are generally intuitive and easy to navigate without requiring extensive training. Moreover, most CMS providers offer additional training sessions and support services to assist users in managing compliance tasks efficiently. - Automated Compliance Notifications
A CMS provides proactive notifications when action is required, ensuring that contractors remain aware of deadlines for document submissions, training renewals, and other compliance-related tasks. - Adequate Time for Compliance Actions
Most CMS platforms allow sufficient time to complete required action items, minimizing last-minute compliance issues that could impact work schedules. - Immediate Awareness of Policy Changes
The CMS enables contractors to stay informed about changes in host facility policies and requirements as they arise, ensuring continued compliance and reducing the risk of unexpected compliance failures.
Challenges Associated with Contractor Management Systems
- Multiple CMS Platforms with Varying Requirements
Host facilities have the discretion to select their preferred CMS provider, which often results in contractors needing to subscribe to multiple platforms. While these systems reduce redundancies to some extent, they do not eliminate them entirely, as different platforms may have distinct documentation and compliance requirements. - Cost Implications of CMS Subscriptions
The financial burden associated with maintaining subscriptions to multiple CMS platforms can be significant. Annual fees can add up quickly, particularly for contractors working across multiple host facilities that require different systems. - Expanding Scope of Compliance Requirements
Over time, host facilities have broadened the scope of compliance requirements within CMS platforms. Contractors are now expected to provide information on areas such as sustainability initiatives, labor policies, IT security protocols, and financial stability. These topics often fall outside the traditional purview of health and safety departments, requiring input from other areas of the organization. - Limited Industry-Specific Knowledge of CMS Auditors
CMS auditors, while well-versed in general compliance protocols, may lack in-depth knowledge of the specific business practices of individual contractors. This can result in instances where auditors impose regulatory requirements that are not applicable to a particular contractor, forcing them to document unnecessary policies or training programs simply to meet compliance criteria. - Challenges in Variance Approval Processes
Although CMS platforms allow for variance requests to address discrepancies in requirements, these requests must be approved by representatives of the host facility. However, obtaining timely responses to variance requests can be difficult, and in some cases, host facilities fail to act on them altogether. This results in contractors being flagged for non-compliance despite receiving verbal confirmation from the host facility that specific requirements do not apply to them. - Redundant Training Requirements
Many host facilities mandate contractor orientation training through the CMS but continue to require the same training upon site entry. This redundancy increases the time and resource commitments required to meet compliance expectations.
The Broader Impact of CMS on Contractor and Host Facility Relationships
The implementation of CMS platforms has significantly improved consistency in compliance oversight, particularly for organizations that manage multiple contractors. By ensuring that only qualified contractors with strong safety records gain site access, these systems enhance overall workplace safety.
However, one of the primary concerns for contractors is the limited recourse available when discrepancies arise. The oversight provided by host facilities varies from company to company, and the personnel responsible for CMS oversight are often different from the site representatives coordinating work assignments. This misalignment can lead to misunderstandings, unnecessary compliance hurdles, and potential delays in work schedules.
While these challenges exist, the benefits of using a CMS remain considerable from the host facility’s perspective. By outsourcing the compliance verification process to a third-party entity, facility managers can focus on broader EHS objectives, allowing for more efficient resource allocation. Even from a contractor’s standpoint, the streamlined approach to compliance and the ability to track requirements in a centralized system provide operational advantages.
Conclusion
Contractor management systems play a critical role in facilitating regulatory compliance and enhancing workplace safety across industries. These systems offer significant advantages in terms of efficiency, transparency, and standardization, benefiting both host facilities and contractors. However, the challenges associated with multiple subscriptions, increasing compliance demands, and administrative redundancies highlight the need for ongoing improvements in the way these systems operate.
Ultimately, the effectiveness of a CMS is contingent upon the collaboration of all stakeholders—host facilities, consultants, contractors, and CMS providers. When each party actively engages in the process, ensuring that compliance requirements are both relevant and enforceable, the overall benefits of these systems outweigh their challenges. Moving forward, refining CMS processes and addressing contractor concerns will be essential in optimizing their utility while maintaining the highest standards of safety and regulatory adherence. If you would like to learn more about our Health and Safety Program or how we can help you put together the framework for your own health and safety measures, feel free to me at jeri.thrasher@ppmco.com.