Contracts training requirements

The toller needs to be familiar with all raw materials, intermediate materials, products and wastes, used, produced or generated, respectively, while operating the process. Tollers in the U.S. should comply with the Federal OSHA Hazard Communication Standard, codified as 29 CFR. 1910.1200 and any similar state right-to-know laws that are currently in force or may be enacted during the term of the contract. This is often stated in the contract. The contract may require the toller to inform its employees of the chemical hazards associated with products or chemicals and may also be responsible for training its employees in the proper handling methods. The toller has an obligation when in doubt about a product or chemical, to seek further information from the product s manufacturer. 

Companies employing or using contract representatives are responsible for their conduct and must ensure that they comply with the provisions of this and all other relevant clauses in the Code, and in particular the training requirements under Clauses 15.1,16.1,16.2 and 16.3. 

CFR1910.119(h)(3)(iii) 4.S.4.3 document that eaeh contract employee has received and understood the training required by this paragraph. The contract employer shall prepare a record, which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training. 

The OTA (1988, pg. 131) points out that imion contracts or initiatives often address issues not covered by Federal policy, or impose more stringent requirements (e.g., more restrictive duty-time limits for pilots, more intensive training requirements). Thus, Nance (1986, pg. 80, footnote 3) notes that restrictions on the amount of time a pilot can be allowed to fly... became part of the general airline system only because they became federal regulations, or were incorporated into union contracts negotiated for the pilots by ALFA. Similarly, Hopkins (1982) notes that ALFA took the lead that management... 

Turn-Key Contract- The contract is concluded after the technology has been selected. This is a firm price contract (with a possible price escalation formula) for all deliveries and services including civil works, startup, and guaranteed test runs of the complete fertilizer plant. The contract preparation requires a large volume of work and time to define the scope and specifics of deDveries and services. The investor has little involvement in the construction process primarily the investor concentrates on training the labor and staff for plant operation and maintenance. 

Contractors Contractor employees working at company facilities need training in safety as much as company employees. The contracting company should establish training requirements including safety for contractors and their employees. A contract should have clauses that cover training requirements for safety and which mles, policies, and standards apply to the contractor and its employees. 

Contract labor requirements for informing, training, and documenting... 

Contract labor requirements (contract labor must inform, train, and document that training)... 

When a contract is let, it is necessary to determine tt e extent of training required for contractor personnel. The plant owner must establish ... 

In addition to the plant workers, others may benefit from some special training related to the toll. It may be advantageous or required to consider laboratory personnel, technical support staff, management and others when planning training. Again, the contract may be the way to define this and document responsibility. 

Requirement for provision of on-the-job training in any new or modified job affecting quality that includes supplier and contract personnel... 

Regardless of the approach your company selects, what s important is the assurance that contract personnel, by whatever means, are as conversant as your own employees with those aspects of your PSM system with which they interact. For this reason, you may wish to consider meeting with your key contractors to discuss the system and how it may affect their persoimel. As part of this discussion, you will want to review whatever training the contractor provides to determine if it meets your needs and is appropriate for the PSM system. If the system requires additional contractor training, you can then work out (either as a global policy or on a case-by-case basis) how best to provide it. 

Many of the technical requirements of the Standard are covered in Chapters 4 to 7. The analytical requirements, including choosing a method and method validation, are covered in Chapter 4. The other measurement requirements, such as calibration, traceability and equipment qualification, are dealt with in Chapter 5. Some of the general issues not covered elsewhere are mentioned in the following sections. It has already been mentioned that staff should be trained and proven to be competent to carry out the testing. This applies to permanent and contracted staff. The laboratory should have a job description for all members of staff. There are more stringent requirements on staff who are also able to provide customers with opinions or interpretation of the results. 

The need for the use of safety procedures by contract personnel will require additonal training and higher priorities in procedural reviews. 

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