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144 As an intelligent customer (in the nuclear industry), the management of the facility should
know what is required, should fully understand the need for a contractor’s services, should
specify requirements, should supervise the work and should technically review the output before,
during and after implementation. The concept of intelligent customer relates to the attributes
of an organisation rather than the capabilities of individual post holders. (See
Principles for the
assessment of a licensee’s intelligent customer capability
.)
145 CHIS7 extends this principle more widely to high hazard industries, stating that, if you
contract out safety-critical work, you need to remain an ‘intelligent customer’.
146 An organisation that does not have intelligent customer capability runs the risk of:
not understanding its safety report, and operating unsafely;
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not having appropriate staff to adequately deal with emergencies;
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procuring poor safety advice, or wrongly implementing advice received;
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not recognising that significant plant degradation or safety critical events are arising, or not
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addressing them correctly;
not identifying the requirements for safety-critical projects, modifications or maintenance, or
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carrying them out inadequately;
employing inadequate contractors or agency staff.
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147 A dutyholder who proposes to contractorise should have organisational change arrangements
in place to review the proposal and demonstrate that safety will not be jeopardised. Choices
between sourcing work in-house or from contractors should be informed by a clear policy that
takes due account of the potential major accident implications of those choices. The approach
to identifying and managing core competencies and sustaining an intelligent customer capability
should be set out in the safety management system.
148 The guidance (
Principles for the assessment of a licensee’s intelligent customer capability
and
Contractorisation
) makes no reference to the concept of ‘contracting-in’ an intelligent customer
resource eg for the evaluation of other contractors. Wherever practicable, this resource should be
in-house.
149
Managing contractors
HSG159 is aimed at small to medium sized chemicals businesses.
It primarily focuses on ensuring safe working practices of contractors when on site to do
specific jobs. A weakness of this guidance is that it does not deal specifically with the principle
of contracting out of core business on major hazard sites, or of intelligent customer capability.
However, it does contain a checklist to help dutyholders to gain an overview of health and safety
in managing contractors, and this contains statements that would infer some requirement for
intelligent customer capability, such as:
staff know their responsibilities for managing contractors on site;
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staff responsible have enough knowledge about the risks and preventative measures for all
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jobs involving contractors; and
staff responsible know what to look for when checking that contractors are working safely,
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and know what action to take if they find problems.
150 A report by the Health and Safety Commission (HSC) in 2002 into the use of contractors in
the maintenance of the mainline railway infrastructure came to the conclusion that:
contractorisation is a feature of all industrial sectors worldwide;
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it is entirely possible to run a safe operation using contractors so long as management
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systems are good; and
it is not invariably true that an in-house operation is better managed.
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