There have been a number of prosecutions recently where the company prosecuted was not the company that caused the incident: it was one of their contractors. Most businesses employ contractors to complete work on their sites, but what can you do to try and prevent mistakes and prosecutions?
When you are employing subcontractors, it is important that you do your due diligence thoroughly to ensure you are using the right people for the job. This would include making sure they have the correct qualifications and experience to carry out the role you are asking of them. Further, you can ask if they have any environmental controls in place. Do they have ISO 14001? Are they aware of their legal obligations? Have they been prosecuted in the past? By asking these kinds of questions, you can get an idea of their environmental performance and make sure they have the means to identify and manage their risks.
It is very important that contractors are inducted onto your site so they know what to do and to make sure they are kept safe. Environmental awareness should also be part of this process. Contractors will need to be made aware of what to do with their waste, what to do in the event of an environmental incident and reporting procedures. One of the most important parts of this is making sure your contractors know who to contact if they are unsure or have any questions. Keeping an open line of communication helps to ensure contractors don’t do something wrong because they just weren’t aware of the correct procedures. Once contractors have been inducted, you will also want to consider how often they should go through a refresher.
While it is very important to note that your environmental responsibilities cannot be contracted away, the agreements you have with your contractors can be a good tool to ensure they are aware of their responsibilities. This can include obligations to follow your health, safety and environmental procedures, what they do with their waste or how to prevent pollution.
Once you have appointed your contractors, it is important to monitor them as things can change at any time. This might involve a contractor questionnaire issued annually or could include auditing of those contractors you use on a regular basis. Auditing could include visiting waste disposal sites to ensure they meet legal requirements or observing work carried out on your site to ensure they follow your controls and procedures.
Since the Sentencing Guidelines for environmental offences was introduced in 2014, fines have increased. More businesses are recognising the severity of breaking environmental law and the reputational repercussions this can have. As such, many organisations are evaluating their environmental risks and controls. An area of risk is employment of contractors to carry out work on your behalf. As such, it is very important that you revise your contractor controls to make sure you are reducing the risk of incidents occurring. What do you do to control contractors working on your site? Leave your comments below.