Over the past nine months, the Energy Chamber has received a total of 46 applications for Safe To Work (STOW) certification. Out of these, 26 companies have completed audits and 14 have received final certification. A number of the companies who have now been certified were originally rejected and had to make improvements and be re-certified. This data indicates that the system has indeed set a high standard and that certification is a robust process. This experience has also allowed us to notice certain trends in the companies that did or did not achieve certification. In this article, the Energy Chamber will share what seems to be the major hurdles that prevent contractors from being STOW certified and provide some guidance to contractors.
Evidence of practice is more than paperwork. The first thing that comes to mind is contractors' inability to provide proof that the STOW health, safety and environmental (HSE) management system is in effect and functioning as it should. Many contractors seem to believe that having an HSE manual is the most important thing and concentrate on producing (or sometimes purchasing) impressive looking manuals. While there is a fair amount of paperwork involved in implementing STOW, in terms of documenting policies and procedures, these mean little if what is documented is not put into practice and there is little or no evidence to present to an assessor as proof that it is functional. Therefore, one rule of thumb should be, if it is included in the company's HSE manual or policies and procedures, there should be evidence to support that it is actually done and works well for the organisation.
Take your time
The Energy Chamber is aware that operating companies have started imposing deadlines for STOW certification of contractors, which if not met, leaves the contractor's ability to get future contracts hanging in the balance. The situation has caused contractors to hurriedly implement paper based HSE management systems that cannot be verified as functional and effective by the assessor because of the newness of the system. Another piece of advice is, therefore, is to test the system for at least three months and gather evidence that it works, before seeking certification.
Leadership is crucial
In terms of the technical aspects of the STOW requirements: Element 1: management, leadership and accountability; Element 3: risk assessment and management of change; and Element 8: environment; seem to be giving contractors the most problems to implement. It is not by chance that the first element of the STOW requirements focuses on leadership and accountability. The leaders of the organisation set the tone for the safety culture and it is appropriate that they be held accountable for the organisation's safety performance. We have seen a marked difference in the implementation of STOW when it is left up to the HSE manager and other employees in comparison to when the effort is driven by the top executives of a company. When the top executives take charge, all other things being equal, implementation is smoother and, based on what we have seen, takes place at a faster rate. In terms of implementing the requirement for leadership and accountability, senior executives, managers and supervisors are expected to be familiar with the HSE performance of their operations and able to discuss it with assessors. The company is expected to provide proof of adequate allocation of human and financial resources to implement and sustain the HSE management system. Additionally, contractors must have systems in place to evaluate their HSE performance through feedback from and discussion with clients.
Risk assessments are key
For risk assessment, all contractors are expected to have a suitable and sufficient risk assessment process which starts with the identification of critical activities. The STOW Implementation Board pays particular attention to the assessor's findings when it comes to risk assessment, especially for higher risk companies.
Risk assessments must be documented, effected
Many service companies do have an environmental impact. Meeting the STOW requirements for environmental management seems to be particularly troublesome for contractors. In instances where the operations do not fit the typical bill for significant environmental impact, for example, drilling operations, contractors seem to believe that they have no impact on the environment. They therefore place little or no emphasis on the STOW environmental requirements because they are of the opinion that this area of the STOW requirements is not applicable to them. This is not necessarily the case. The STOW board expects contractors to evaluate all the possible risks their operations pose to the environment. If there are significant risks, the STOW board expects to see a separate environmental management plan to address the risks. If, however, the risks are minimal, a separate plan is not required, but measures must still be put in place to reduce the risk.
We need to see your system, not the client's
The final shortcoming that we want to mention is contractors' complacency about having their own HSE management systems and the frequency with which we see the statement "adopt client's system." We have noticed this trend, especially when contractors have projects on their client's site. The board is firm that contractors must have their own HSE management systems and not rely solely on their client.
Status: May 2011
At the time of writing this article, 13 contractors and one operating company (Atlantic) have been certified as having HSE management systems that conform to STOW. Some were certified on the first attempt and some on their second attempt. The secret to achieving STOW certification is not in "buying an HSE manual," though this may be tempting and may seem like a cheaper option. This will only provide a paper based system, which, when tested-and our assessors will test the system by looking for evidence, interviewing employees and conducting site visits to see employees while at work-will reveal the loopholes of a system that is non functional. Companies taking this route will not be certified and will have wasted their money. Our assessors are available to walk contractors through implementation and get them over the hurdles outlined. The chamber highly recommends them because we trained them, we have set rates for their services and we hold them strictly accountable for upholding the code of ethics that they signed upon becoming an assessor.
The Energy Chamber is also here to point contractors on the way forward. We invite contractors to visit our Web site at http://stowtt.energy.tt for more information on STOW and on achieving certification.
What is STOW: STOW is an HSE certification scheme to prequalify contractors for work in the energy sector. The programme is being implemented by the Energy Chamber, in collaboration with the major energy sector companies and is funded by a generous grant from the Inter-American Development Bank.
List of STOW-certified companies
Neal & Massy Wood Group Ltd
RBG T&T Ltd
Harsco Infrastructure West Indies Ltd
Scaffolding Manufacturers Trinidad Ltd
Tucker Energy Services Ltd
D Rampersad and Company Ltd
Kennicon Engineering Ltd
ANSA Technologies Ltd
TOSL Engineering Ltd
Special Consultants, Oilfield Rentals Equipment Ltd
M-I Trinidad Ltd
Halliburton Trinidad Ltd
CS Air Conditioning Refrigeration Sales and Services Ltd
Atlantic