Contractor Health and Safety: The inadequacy of data collection and the breakdown of health and safety policy enforcement where contractors at fixed facilities are concerned

Current occupational health data sources are limited in depicting a true picture of occupational injuries and fatalities at industrial facilities. Contractors provide significant contributions to the work force needs and technical assistance in chemical plants, refineries and other fixed facilities. Contract workers often assume the most dangerous jobs, but are undercounted in injury and fatality rates nationally for the facilities where they work. Occupational health data compiled from a variety of sources including the Department of Labor's Bureau of Labor statistics and occupational health surveys administered by the Center for Disease Control do not adequately collect data on contractor injury/fatalities. Additionally, under OSHA's Process Safety Management guidelines, health and safety policies at a fixed facility should be extended to contractors brought in to provide a variety services at that facility, but examples from the US Chemical Safety Board's investigations prove otherwise. Using various investigations conducted by US Chemical Safety Board as examples, this paper looks at the inadequacy of data collection and the breakdown of health and safety policy oversight where contractors are concerned, highlighting specific safety system deficiencies such as the lack of training concerning site specific hazards. Through a comparison of health and safety policies among unions, industrial facilities, industry good practice guidelines and contracting organizations this paper hopes to demonstrate how data gaps and inadequate policy enforcement stymie the development of more protective polices for contractors at fixed facilities.