ISNetworld®: How to write a safety program

Writing a safety program designed to be approved by ISNetworld® can be difficult.  However, it is possible.  The first step is to read the additional comments section for each individual requirement.  You must also take one step further if that requirement cites a specific section of law.  The laws usually are OSHA (Occupational Safety and Health Association), ANSI (American National Standards Institute), EPA (Environmental Protection Agency), DOT (Department of Transportation) and API RP (American Petroleum Institute Recommended Practices).  Then you must look up the legal standard to determine what steps or specific conditions are necessary to meet the requirement.

Please remember, that becoming OSHA compliant is NOT the same as becoming ISNetworld® compliant.  This is because under the OSHA standards, OSHA may require sections 1-20 to be met to become OSHA compliant.  ISNetworld® may only require standard 1, 5-8, and 14 to become ISNetworld® complaint.  Therefore, just because the company is ISNetworld® compliant does not mean OSHA compliance.

After looking at each of the requirements, the additional guidance section and any legal standard your next step is to start writing the program.   First write a purpose or objective section.  These are easy.  For an example let’s use CPR as the required safety program.  The purpose would be something simple such as:  All employees shall receive training and know when to correctly use CPR.  The purpose should be short, simple and no more than one sentence.

The third step is to begin writing the requirements.  During this step you may not be able to write something as requirement one, two, three and four because it may not make sense.  You will most likely have additional sentences with the requirement imbedded within a paragraph.

For example:  If the requirement states each employee must receive training at the beginning of employment, annually thereafter and if something changes.  You may want to entitle a section as training and under the section write all the requirements your company will require, this can be in addition to the ISNetworld® requirements.  See below.

Training: Each employee shall receive the proper training to become a certified lay responder in CPR.  All employees shall receive the training before their first assignment and annually thereafter.  Each employee must also be retrained if any standard change.  Further, the training shall not be charged at the expense of the employee.  The training shall be conducted during normal business hours with a certified instructor.  

Continue onto each individual requirement and write out each standard as your company desires.  As long as it meets the individual requirements of ISNetworld® your company may expand as you deem necessary. Once all the sections are written accordingly, organize it in a logical manner.  Remember to keep like sections together, as long as it is in the safety program it does not have to be in any specific order. Next, it is time to submit your program.

Here are a few things to remember when uploading your program and submitting page numbers to ISNetworld®:

  1. Put page numbers on the safety program, it makes it easier to locate things later.
  2. Each requirement must be met.  Therefore, for each section you must select yes for the appropriate requirement.  If you select no, your program will be denied.
  3. If your program is a total of five pages do NOT write the requirement is contained in pages 1-5 as it is not specific enough and most likely will get denied.
  4. You can leave the comments section blank.  However, if your program was denied and the information is contained within the program bold that requirement and resubmit it.  Then, in the comments section write “see bold.”
  5. Do not be sarcastic in the comments section.  For example, if you are a sole proprietor and feel a program does not apply to you do not write a sarcastic comment.

Example: I am a sole proprietor.  This program does not apply to me because if I die or become unconscious I will not be able to administer CPR to myself. 

ISNetworld® will deny the program.   Therefore, write the program with all the elements needed.

Once your program is uploaded you have completed the process!  Now it’s just time to sit back and wait for approval.  Just to summarize the steps needed to write your own safety program:

  1. Read the ISNetworld® requirements.
  2. Read the additional guidance section for each requirement.
  3. Read any additional law ISNetworld® cites.
  4. Write a simple purpose or objective.
  5. Write out each requirement.  Use headings or specific subject areas if it is easier.
  6. Organize the program in a logical order.
  7. Submit the program.
  8. Wait for approval.
  9. If denied and you believe you have met the requirement, bold the section or language needed to meet the requirement and resubmit it.  In the comments section write, “see bold.”
  10. Resubmit.
  11. Wait for approval.
  12. If denied again and you still believe the language is contained in the program call ISNetworld®.  When on the phone with a customer service representative explain to them where you believe the required language is.  The representative may be able to help you.

Remember the language contained in this guide will not gain you compliance.  You must read all the requirements and put in the time to write the program to meet your company’s needs.  Good luck!

Markus Wesaw is in no way endorsed, sponsored, approved by, or otherwise affiliated with ISNetworld®. ISNetworld®, ISN®, ISNetworld®, and RAVS® are registered trademarks of ISN Software Corporation.

ISNetworld®: Finding answers to your questions

Many of you have called ISNetworld® at your wits end trying to figure out how to complete a questionnaire or what to do if certain provisions do not apply to your safety programs.  You believe they have answered your questions hit the submit button and a week or two later it comes back “Denied.”  Frustrated you call back, get a different department and they tell you something else.  You are not alone in your frustrations.

Many people have worked on their ISNetworld® accounts for various companies for months and sometimes years and still have not gained compliance.  However, ISNetworld® would like you to believe that you can fix the problems on your own and with great ease.  Most of the time this is not the case.

Here are a few tips for submitting your safety programs through ISNetworld®:

  • Do NOT answer any of the requirements “no,” it needs to state yes.
  • If your program gets denied because a requirement was not met, however, you believe you have met that requirement.  Resubmit it with that requirement bolded and in the comments section state, see bold.
  • Take the time to read the additional guidance section; sometimes it is helpful to determine what exactly needs to be included in your program.
  • Do not just copy and paste things off the internet and put your company name on the top.  Most of the time all of the elements are not included.  Some of the time the requirements may have changed and the program is now outdated.  Be sure to use your own program.
  • As tempting as it may be, do NOT write in the comment sections how this requirement or program does not apply to you and state the reason why.  For example: “Bloodborne Pathogens does not apply to XYZ Company because the company works only with computers.  The largest risk we have is obtaining a paper cut.  Therefore, this program does not apply.” ISNetworld® does not care if you believe the program or requirement applies or not, they just want it submitted.
  • If you have submitted 75% or more of the programs that were required, but you honestly believe that the remaining programs do not apply to you, you may ask for a variance.  A variance just means a waiver; therefore, you are asking ISNetworld® to waive the remainder of the programs.  This does not mean it is guaranteed, you are just hoping it will be waived!

If you have called ISNetworld® and have continuously tried to find answers to your questions and are getting nowhere, you are about to lose contracts, or are just irritated with the entire process do not be afraid to call around to a few ISNetworld® consultants for help.  We recommended calling a few people and asking them specific questions to your account.  Some companies will tell you they guarantee ISNetworld® compliance in 48 hours, do not believe them.  As you know once your information is submitted to ISNetworld® it can take them some time to approve or deny your submission.  Therefore, it is impossible for anyone to gain 100% compliance in 48 hours.  Be sure you are speaking with someone with knowledge of the procedure and process.

If your company is about to lose contracts because of not being in compliance with ISNetworld® be sure to ask if they can help you quickly, some consulting companies do not have the time to devote to your company immediately.

Do not believe you are alone in this process.  There are many of you that are highly educated, have years of experience or a combination of both that are still unable to get through the compliance process with ISNetworld®.  Each department will give you a different answer to your question, or attempt to help you but their attempts are futile.  Do not get angry and begin to write sarcastic comments in the comment sections, as you most likely will get the same result as before, “Denied.”  Be patient and call around for help because you can gain compliance!

Markus Wesaw is in no way endorsed, sponsored, approved by, or otherwise affiliated with ISNetworld®. ISNetworld®, ISN®, ISNetworld®, and RAVS® are registered trademarks of ISN Software Corporation.

A strategy for ISNetworld® compliance: Principles of business

For the purposes of this blog, we are going to assume that your company has already subscribed to ISNetworld®. We are also going to assume, like many small businesses, that your company has had a less than perfect safety track record. And, for this problem, we are going to offer an out-of-the-box solution using the principles of business and strategy.

As your company is probably aware, safety performance measures are becoming more and more of an evaluation tool. However, the process is not entirely fair since the way the OSHA incident rate is calculated favors larger businesses. See, OSHA assumes that a business will have 100 employees who work 2000 hours per year yielding a 200,000 hour constant. The number of OSHA recordable incidents will be multiplied by the constant of 200,000 hours and divided by the total number of hours worked by all employees at your company. Thus, if you have 10-20 employees, one or two OSHA recordable incidents will impact your company’s safety performance much greater.

The second major safety metric is the experience modification rating (EMR). If your company’s rating is less than 1.0, you are beating the industry average. If the EMR is greater than 1.0, your company is associated with much more risk.

With poor safety performance, your company is not likely to have a great EMR or OSHA incident rate. When this information is reported to ISNetworld® and ran through the verification process, your company could get dropped as a preferred vendor. So, what’s the solution? Firstly, get your company’s safety performance record on an improvement track or else your company faces significant long-term liabilities and losses.

Secondly, if your company has really awful safety metrics beyond repair, we recommend changing how your company does business. There are many shelf companies out there that can be purchased for under a $1,000 with a few years of legitimate business operations, tax returns, and some even come with their own domain names, interestingly enough.

Buying a shelf company is cheap and can be completed quickly. The next step would be to begin your new business enterprise by acquiring your old company. Either the shelf company and the current company can merge and form a new entity or the shelf company can acquire the other entity altogether. In the end, the result is one and the same.

During a merger or acquisition, the parent or surviving company (e.g. LLC, Corp) will assume operations and control of the old company, but can have the option of re-establishing an EMR and the previous safety metrics would belong to the old entity, not the newly formed corporation. Of course, you will have to run through the motions of getting a new Tax ID, but that only takes about 5 minutes online. If you need help with the merger and acquisition process, hire a corporate attorney who can help you.

The major benefit here is that your previously held contracts are likely to be transferred to the newly established entity and you will be able to continue business operations. Your safety metrics will need to re-evaluated to reflect these changes and you will have to work things out with whatever agency is handling your workers’ compensation.

The downside is that ISNetworld® will likely make you cancel the old account under the old business entity and create a new account, but make sure that your clients on your subscriber account are transferred. You may have some hoops to jump through, but in the end you can essentially reset your safety performance record with OSHA and ISNetworld®.

We cannot stress enough, however, that if you do not change how your company operates its safety program, you will in all likelihood suffer the woes associated with inadequate safety programs.

Markus Wesaw is in no way endorsed, sponsored, approved by, or otherwise affiliated with ISNetworld®. ISNetworld®, ISN®, ISNetworld®, and RAVS® are registered trademarks of ISN Software Corporation.

The future of ISNetworld®

This blog has been geared towards a discussion on ISNetworld®, which is a company that serves as an intermediary between suppliers and prime contractors. The subject matter herein aims to discuss the future of ISNetworld® and its growing popularity. That is, with more and more large, publicly traded companies moving towards utilizing the services of ISNetworld®, what is the impact on smaller businesses and contractors?

It would seem that since many larger companies are using ISNetworld® for review services, that the demand for smaller companies to acquire a subscription is greater than ever before. Take, for example, Marathon Oil and Hess–two very large oil companies–who have a very high demand for small businesses to fill in the gaps in their up-, down-, and mid-stream operations. In order to be considered to work for these companies, small businesses must subscribe to ISNetworld® and meet the criteria outlined in their account depending on industry type.

The demand for review and accuracy services appears to be quite high. That is, large businesses like Marathon and Hess usually have a limited environmental health and safety (EHS) team to monitor, track, review, and report the various safety metrics associated with their subcontractors. So what it essentially comes down to is many prime contractors are using ISNetworld® as a solution to review their vendors from a more risk management perspective. This is analogous to how many grocery chains implemented self-checkout stations where the customer bags his/her own groceries, checks out, and pays without the presence of an actual employee. ISNetworld® presents the requirements in each supplier’s account and makes them submit documents, answer questions, and provide other information–all of which is reviewed for accuracy by ISNetworld®.

The future, therefore, of ISNetworld® would seemingly be bright. The company provides a solution where larger prime contractors can reduce the number of manhours where employees must determine certain risk factors pertaining to subcontractors. The burden, like at the grocery store, then is on the backs, so to speak, of the smaller business entities to maintain compliance with ISNetworld®. Otherwise, they may lose their contract as a supplier, something that is usually held in a negative light.

Markus Wesaw is in no way endorsed, sponsored, approved by, or otherwise affiliated with ISNetworld®. ISNetworld®, ISN®, ISNetworld®, and RAVS® are registered trademarks of ISN Software Corporation.

ISNetworld® and OSHA: Separate entities and different Intentions

Many would say, incorrectly that is, that the Occupational Safety and Health Administration (OSHA) and ISNetworld® compliance are the same. After all, at a cursory glance one would likely place the two organizations in the same category. However, OSHA and ISNetworld® are two separate entities with very different intentions.

ISNetworld® provides their subscribers with an account where documents can be uploaded, reviewed, verified for accuracy, and put to various other tests. The organization is a privately owned company and does not serve any governmental function. Moreover, ISNetworld® does require that its subscribers (who are also suppliers) submit written health and safety programs for the review process.

The interesting part about this process is that ISNetworld® compliance does not, by any means, meet all of the OSHA compliance standards germane to specific health and safety programs. The best example we can provide by comparison is the Hazardous Waste Operations and Emergency Response (HAZWOPER) standards found in the Title 29 CFR part 1910.120 regulations and the emphasis ISNetworld® places on a mere portion of those standards.

That is, ISNetworld® requires suppliers to comply with paragraphs B, E, F, G, H, K, P, and Q. More specifically, the more precise HAZWOPER standards that ISNetworld® specifically requires are as follows:

  • Title 29 CFR part 1910.120(b)(1)
  • Title 29 CFR part 1910.120(e)(1)(i)
  • Title 29 CFR part 1910.120(f)(2)(i)
  • Title 29 CFR part 1910.120(f)(5)
  • Title 29 CFR part 1910.120(g)(1)(i)
  • Title 29 CFR part 1910.120(h)(1)(i)
  • Title 29 CFR part 1910.120(k)(2)
  • Title 29 CFR part 1910.120(k)(2)(iii)
  • Title 29 CFR part 1910.120(k)(2)(iv)
  • Title 29 CFR part 1910.120(k)(3)
  • Title 29 CFR part 1910.120(k)(5)
  • Title 29 CFR part 1910.120(k)(6)
  • Title 29 CFR part 1910.120(k)(8)
  • Title 29 CFR part 1910.120(p)(7)(iii)
  • Title 29 CFR part 1910.120(q)(1)
  • Title 29 CFR part 1910.120(q)(2)
  • Title 29 CFR part 1910.120(q)(3)
  • Title 29 CFR part 1910.120(q)(6)
  • Title 29 CFR part 1910.120(q)(6)(i)
  • Title 29 CFR part 1910.120(q)(8)
  • Title 29 CFR part 1910.120(q)(9)

It would seem as though other paragraphs of the HAZWOPER regulations are not considered. For example, paragraph C on Site Characterization and Analysis and paragraph D on Site control are not required yet the importance of these regulations is paramount to an effective HAZWOPER written health and safety program (HASP).

An OSHA compliant written health and safety program (HASP), on the other hand, would address all 17 paragraphs of the HAZWOPER regulations. Additionally, other related programs such as lockout/tagout or respiratory protection may be needed to supplement the written HASP. OSHA has presented us with a very comprehensive template on what a proper HAZWOPER HASP should look like. Granted, the template is geared towards the cleanup and removal of anthrax, a dangerous biological agent, but one could revise the sections offered by OSHA to create a more site-specific program manual.

The differences between an OSHA compliant and ISNetworld® compliant written safety program are vast. Firstly, OSHA regulations exist for worker protection with the aim of providing guidance to employers on how to create safer working conditions for employees. OSHA regulations are consistently amended to reflect improvements and a rapidly changing workforce. Secondly, the intentions of OSHA are clearly outlined in the Occupational Safety and Health Act of 1970 whereby the Administration’s very existence was geared towards regulating industry in a way that lowered the incident rates of worker fatalities, illnesses, and work-related injuries.

The intentions of ISNetworld® appear to be geared more towards a risk management perspective in which the company provides its services. However, even the risk management component can easily be challenged when one considers the requirements set forth by ISNetworld® in their safety program mandates. More to the point, the Title 29 CFR part 1910.120 HAZWOPER regulations are extremely complicated standards because emergency response and cleanup operations work is very dangerous. And, each organization must have a site-specific HASP that is oriented towards the relevant risks and hazards of that workplace, which means that no single program will work for every organization.

Further compounding this matter is the fact that many suppliers, who perhaps do not fully grasp the exceedingly complex nature of HAZWOPER regulations, become confident that their ISNetworld® HAZWOPER program is fully compliant with OSHA standards on hazardous waste operations and emergency response. It goes without saying that many companies perform work under the HAZWOPER scope and application without fully understanding the risks, without proper employee training, and without the necessary personal protective equipment. Coupled with the fact that many employers fail to abide by HAZWOPER standards in the first place, an ISNetworld® compliant program could convince some subscribers that the elements of proper safety protocol are satisfied when, in fact, they are not.

We argue that ISNetworld® seemingly selects OSHA standards at random and enforces only these OSHA standards during their review process for compliance. Furthermore, we have noticed that with respect to most OSHA mandated written programs like Hazard Communication standards found under Title 29 CFR part 1910.1200 and Respiratory Protection standards in accordance with Title 29 part 1910.134 among many others that only a mere seven to nine standards are selected for ISNetworld® compliance. Thus, many OSHA regulations are largely ignored by the ISNetworld® team during the review process of written safety manuals.

All in all, we can understand that ISNetworld® accepts and reviews written safety programs and tests them according to their selected OSHA standards. However, the most concerning issue with this process is that because so many OSHA standards are not required for ISNetworld® compliance, are employers then led to believe such standards are not as important or not to be adhered to? With the overwhelmingly fast pace ISNetworld® is growing, many suppliers may be more likely to adhere to the regulatory standards set forth by ISNetworld® than they are actual OSHA regulations—at least that is reasonable conjecture.

The major shortfall of the ISNetworld® review process is that not all OSHA standards are included, which can be confusing and deceptive to many without the requisite background in occupational health and safety. The review process is simply an evaluation of a company’s required contractual obligations with aim of reducing risk to the primary contractor by verifying the existence of documentation. However, this process of selecting specific OSHA standards, without objective reasoning or justification, only misleads employers by associating ISNetworld® compliance with that analogous to meeting the complete standards mandated by OSHA.

ISNetworld® has created a novel method of review of safety documents like written safety program manuals, but has in doing so, created an avenue of confusion, especially when we measure the ISNetworld® required standards against those in the various OSHA 1910 and 1926 subparts. Put plainly, safety manuals that satisfy the scrutiny of ISNetworld® are not necessarily compliant with OSHA standards. Employers who are relying upon their ISNetworld® written safety manuals as their primary means of reducing the likelihood of workplace illnesses and injuries should consider a more comprehensive approach.

OSHA mandates that an employer must maintain a workplace free from known and recognized hazards. The OSHA regulations were designed to guide employers towards this very purpose and that has remained the primary intention and mission of the agency. ISNetworld® provides its services not to necessarily reduce the risk of suppliers, but rather to reduce the risk of its primary contractor base or, as they are known, owner-clients. The primary strategy an employer should implement is to ensure that all written safety programs are fully compliant and meet all requisite OSHA standards.  If this is done correctly, ISNetworld® will likely approve such programs since those standards are also based on OSHA regulations. Remember the intention of OSHA regulations are rooted in the principles of injury prevention and ISNetworld® has intentions geared towards liability, risk management, and asset protection.

Markus Wesaw is in no way endorsed, sponsored, approved by, or otherwise affiliated with ISNetworld®. ISNetworld®, ISN®, ISNetworld®, and RAVS® are registered trademarks of ISN Software Corporation.

ISNetworld® and regulatory citations

ISNetworld has, for some time now, used the availability of establishment searches to the company’s benefit. That is, ISNetworld® uses the public information available on databases, especially the OSHA establishment search, as yet another reportable metric to their owner-client subscribers. The impact of this type of report can be quite a telling picture of your company’s safety record.

However, there is the occasional case where the citations associated your company’s ISNetworld® supplier account are incorrect. Take for example, Pajoric LLC, who acts as the parent company and has subsidiary company divisions that are separate business entities, but nonetheless owned by Pajoric, LLC. Many times, the parent company or one of its subsidiaries receives an OSHA citation. ISNetworld® may associate that OSHA citation with one or all of the ISNetworld® accounts operating under a similar name.

The solution is quite simple and ISNetworld® is very good at resolving these types of issues. Primarily, the issue becomes problematic when not addressed as soon as it is noticed. Keep in mind that some incorrect or inaccurate data may be imported to new or old accounts, so keep an eye out for a notification.

To effectively resolve the issue of being wrongly accused of an OSHA citation and having that reflected on your supplier ISNetworld® account, whomever is the declared primary account manager will have to fill out what is referred to as an “OSHA Citation Removal Request Form”. The form will need to be completed and returned via fax or email. (Please note that although we present the current link to the form above, the link may be subjected to change beyond our control. We’ll attempt to keep it updated.)

Now, a question we get a lot is how to remove an OSHA citation that ISNetworld® has associated with a supplier account that is indeed accurate. Well, if you are guilty as charged, there’s not a whole lot anyone can do since the OSHA establishment search is public knowledge. Our advice would be to improve your safety performance and take the OSHA citation as a lesson learned–a wakeup call for improvement. However, if your company is willing to try improving your safety performance and need a clean slate, so to speak, we present one method here.

Markus Wesaw is in no way endorsed, sponsored, approved by, or otherwise affiliated with ISNetworld®. ISNetworld®, ISN®, ISNetworld®, and RAVS® are registered trademarks of ISN Software Corporation.

Don’t fake ISNetworld® compliance

Recently we did some research into how people are achieving ISNetworld® compliance. We found that online safety companies provide packages to guarantee compliance in 24 to 72 hours and we were very surprised because, well, that’s a bit misleading.  In the society we live in today, if it sounds too good to be true it usually is. Becoming ISNetworld® compliant takes a little longer than 3 days. Actually, in our experience, it’s a lot more like three weeks from start to finish for new accounts.

Here are some things you will need to gather and if you do not keep good records, this can be the hardest part:

1.  OSHA 301, 300, and 300A forms for the last three years

2.  EMR letters for the last three years

3.  Any written safety programs that your company currently uses. NOTE: They will most likely require a bit of tweaking

4.  Training documentation for employees. This includes tailgate meetings, formal training, and all other informal safety training sessions.

5.  Insurance certificates from your broker. You can use these as a reference to help you get started. You will have to do some more work on these, but knowing what coverage you have is a great starting point.

6.  Owner client specific documents. If you have a Master Service Agreement (MSA), get this out because there may be some documents you may have to sign and upload. A lot of times, however, this will be done via ISNetworld, but not always.

7.  If you are a transportation company, compile your DOT records for inspection, travel logs, and related records. Prepare to input data from these files.

8.  Further documentation is needed if your company is in Canada or Australia.

So, you gather the needed documentation then comes the next step.  Answering the MSQTM Questionnaire. This is a bunch of questions all about your company.  This can take you a while to complete. Once you finish the MSQTM, you must update it quarterly or you will not remain ISNetworld® compliant.

If you thought that wasn’t enough ISNetworld® reviews and verifies everything. They call it RAVS® for a reason. So, you self report everything and they check it for accuracy.

Now does that seem like it can be done in 3 days? If you say yes you need a reality check!

Now you have all the information, lets go back to the required documentation. What if you didn’t keep good records. A common example is not having training documentation. If you call any OSHA instructor and ask, “I have a guy that had an OSHA 10 and he lost his card can I have another?” The answer is no. Replacement OSHA 10 cards, for example, can only be replaced by the original instructor…if he/she kept those records and OSHA requires a fee of $25. You must contact the original instructor and ask them. If the instructor doesn’t have that information, then the employee must take the class over.

Another common problem is buying a cookie cutter safety program online, but never implementing them. It’s not a good idea to focus merely on ISNetworld® compliance because there are regulations that mandate the existence of these safety programs. The idea behind this is: My company will get ISNetworld® compliant and just start working.  Let’s say your one of your safety programs pertains to hazard communication. You have your program. Employees don’t have a copy nor do they know what hazard communication means. Hmmm, see where we are going with this…could be problematic down the road.

There can also be other liabilities than just losing your contract.  If you have a contract with a big company and in the contract it states you are to remain ISNetworld® compliant and you don’t, then the company can sue you for breach of contract (your MSA).  They will most likely win in court.  This means they can sue you for any money they lost on the contract, the cost of hiring another company, the cost of putting off the job, legal fees, attorney fees, and any punitive damages the court feels is appropriate.  Punitive damages are a form of punishment from the court and it can be from $1.00 to millions.

The point is that ISNetworld® simply reviews the material you submit. That’s it. It’s your company’s responsibility to ensure accuracy in what is submitted and that your company implements the requirements set forth by OSHA and your primary contractor. Many people do not realize that ISNetworld® is a “middle man” company whose business model is built around saving big companies time by making sure every body follows certain regulatory requirements. ISNetworld® also provides some metrics services that assist in risk management, but they do not interpret the metrics.

What does all of this mean to you.  The few seconds it took you to check a box and state your company instituted a program and never followed through can cost you more in the end.  In this economy, every job counts and so does your company’s reputation.  Once people find out your company may be a liability, they may not do business with you, especially if you cost them money.  Word of mouth in the oilfield industry (and most other industries) is a big deal.  When other companies find out your company is not a liability and cares about employee safety, they are more willing to hire your organization.  But just like the girl who cheats on her boyfriend with his brother, you will no longer be wanted by anyone.

When your company is trying to be ISNetworld® compliant, it is a lot easier to gather the information first.  Find out what your company is missing and work towards taking corrective action.  Do not make up documents or certifications.  What’s the worst that can happen, your employees get a little more training?  Maybe this time something will take, at the very least they will not misplace their certification again!  Next, if you state your company is implementing a safety program, do it!  It’s just that easy!  Not only will your company keep ISNetworld® compliance, keep a contract, but also your reputation and court fees.  Next, if you have a problem or trouble with something ask someone!  There are people out there that love this stuff and its easy for them.  Lastly, don’t believe it will take 3 days to become ISNetworld® compliant.  Follow the steps and do it right.  It will cost you more in headaches and sleepless nights in the end.

And, if you would prefer to not be bothered by all of this, contact us to speak with an ISNetworld® consultant that can help. After all, we know you’re busy, and this is sure to help.

Markus Wesaw is in no way endorsed, sponsored, approved by, or otherwise affiliated with ISNetworld®. ISNetworld®, ISN®, ISNetworld®, and RAVS® are registered trademarks of ISN Software Corporation.

How to get ISNetworld® compliant

As more and more large companies require the services and products of small businesses, we have seen a substantial growth in the use of ISNetworld®. ISNetworld® is a company that offers verification services for what they call “owner-clients” (the people you want to do business with) and suppliers (your company). The organization reviews documents for specific requirements and issues a report card called the “Dashboard Grade” to the owner-client. This Dashboard Grade is extremely important because that is really what is meant by ISNetworld® compliance. The following tips and advice will guide the beginner on how to work towards getting compliant with ISNetworld®.

Company Information

Prepare by gathering your company documents together. That is, you’ll need OSHA 300 and 300A forms, experience modification rating (EMR) letters from your workers’ compensation, employee hours worked including overtime, and the average number of employees–all for the last three years. This information will really assist in the startup process since it will be readily available to you.

Identify your NAICS number from one of the documents you have gathered. Be sure to input this into your company profile as accurately as possible. ISNetworld® will ask that you identify your industry type and, although imperfect, you will have to identify the industry that most closely suits the work your company performs. This is an extremely important task because getting this wrong could mean that your company will be subject to irrelevant employee safety training and/or written safety programs. My advice: Get this right from the start!

MSQ (Management Safety Questionnaire)

The MSQTM  questionnaire is a very important next step towards achieving ISNetworld® compliance. Prepare to take some time to complete the MSQTM because this process can sometimes take a few hours depending upon what information is being requested. There are really two categories of MSQTM questionnaires that you need to know about. The first is just the General or United States type, which is the basic information about your company. You’ll be asked to input data about your company such as what personal protective equipment is required by employees and some other questions about your general policies. Be sure to answer every question truthfully and as accurately as possible. The second type of MSQTM is going to be owner-client specific. More to the point, some owner-clients have devised their very own MSQTM questionnaire for you to complete, but don’t worry, these are usually very specific and can be completed in about 30 minutes or less.

HINT: Make sure that the information you input into the MSQTM matches the documents you gathered in the beginning. Discrepancies will be noticed by ISNetworld® and they will ask that these be resolved. Save yourself some time and get this right the first time!

I-RAVS

What is an I-RAVS®? Many people ask that question and it’s just ISNetworld® lingo for insurance (I) review and verification services (RAVS®). This section pertains to your company’s professional liability insurance. Each owner-client will have specific and required insurance coverages that they want your company to carry. Owner-clients use ISNetworld® to review these certificates for accuracy and to ensure that every requirement is met. Don’t mess around here. The team at ISNetworld® looking over these certificates will go over them with a fine tooth comb and if the exact verbiage is not on the insurance certificate…you best believe it’s getting rejected!

So, the process is really simple. You need to call or email your insurance broker. Print or save a copy of the insurance requirements for each owner-client. Pay special attention to the word “required” and make sure that your insurance broker meets every “required” coverage type (i.e. umbrella, excess, general comp., etc.). Other setbacks are usually related to clauses like the cancellation policy. For example, if the requirements mandate a written 30 days notice policy on cancellation, this had better be on the insurance certificate or it will be rejected. Make sure that the address on the owner-client requirements matches the certificate or that will be another reason ISNetworld® will reject the document. One of the most common reasons for insurance certificate rejection by ISNetworld® has to do with verbiage, which must be verbatim. We’re not kidding about that either. See the example below of a standard insurance requirement:

  • A Waiver of Subrogation must be listed in favor of “[Insert Owner-Client here], it’s Indemnified Parties as defined in the master service agreement, and each of their respective insurers” on all policies as required by Written Contract.

Many insurance brokers would simply check the Waiver of Subrogration box on the certificate and call it good. But…this won’t be acceptable. The waiver of subrogation, in this example, has specific verbiage that must be verbatim on the insurance certificate. Otherwise, look to repeat this process until it’s satisfactory.

Once you have a satisfactory professional liability insurance certificate in hand, you’re not done yet. Your company will still have to submit valid proof of workers’ compensation insurance in addition to the professional liability insurance certificate. If your company is working in Wyoming, North Dakota, Ohio, or Washington, then your company is operating in a monopolistic State. Workers’ compensation in most States is an open market economy and companies can shop around for the best rates. However, in monopolistic States, workers’ compensation is offered only through the State.

Why is this information important? Well, say you’re taking advantage of the oil and gas boom in North Dakota and you have employees working throughout the State. Your company will have established a workers’ compensation tax nexus in North Dakota and will have to, by law, pay the State of North Dakota for offering workers’ compensation insurance benefits to your employees who work in that State. As such, a certificate of good standing must be requested from the State and submitted to ISNetworld® along with your professional liability insurance coverage.

Occasionally, we see companies self-insured for workers’ compensation and, in this case, there must be a valid certificate of self-insured status from the State in which the company is operating in and this would be submitted in addition to the professional liability insurance certificate. Expect ISNetworld® to take three to seven days to review these documents.

EMR

The experience modification rating (EMR) letters are issued on an annual basis by the agency handling your company’s workers’ compensation. There’s not a whole to this except that these letters must be submitted in the appropriate EMR dropbox for the previous three years. Most rejected EMR letters stem from submissions outside the desired effective dates. For example, a 2012 EMR effective date may begin from November 1, 2011 to October 31, 2012. So, in this example, if the date is November 2, 2012, that EMR letter would be outdated for 2012 and would be rejected. This the most common error regarding the EMR. EMR letters are usually reviewed by ISNetworld® within a week.

OSHA 300 Forms

The OSHA 300 forms are also quite simple in terms of what is needed. The biggest setback we see here is that many companies have not met this OSHA mandatory recordkeeping requirement and have to draft these documents post hoc. At any rate, these documents must be filled out correctly. Pay special attention to the year in the upper right hand corner of the OSHA 300 forms and make sure that the appropriate year is filled in. We honestly miss that sometimes too! ISNetworld® will reject the document if there are any missing sections, so be sure to accurately and correctly fill out the information. Also, be sure to remain consistent with what has been inputted into the MSQTM questionnaire because if you’re not, you will have to go in and rectify those discrepancies. Like the EMR process, you can expect about a week or so for ISNetworld® to review the OSHA 300 forms.

Safety Program-RAVS

Different owner-clients will require a certain amount of written safety programs. Some owner-clients won’t require any, while others will ask you to have safety programs that don’t even apply to your company. Frequently, we see engineering companies are asked to have a Process Safety Management written program from the Title 29 CFR Part 1910.119 regulations despite the fact that these standards don’t apply to every engineering company. (NOTE: If this happened to your company, submit a “variance request”.)

The purpose of this article is not to delineate every single safety program in the ISNetworld® queue because that would be ridiculous since there are hundreds. Rather, we will show you how to write these written safety policies and will outline how to maintain the ISNetworld® requirements for compliance.

Each written safety program will have predetermined, required components. Please see the required components of the ISNetworld® Hazard Communication below:

  1. The program must meet the 1910.1200(h) standard on employee training
  2. The program must meet the 1910.1200(e)(1) standard on written hazard communication program requirements
  3. The program must meet the 1910.1200(e)(1)(i) standard on listing all chemicals used in the workplace
  4. The program must meet the 1910.1200(e)(1)(ii) standard on non-routine tasks and associated chemicals
  5. The program must meet the 1910.1200(e)(2), (e)(4), & (e)(5) standards on multiple job sites
  6. The program must meet the 1910.1200(f)(8) standard on chemical labeling
  7. The program must meet the 1910.1200(g)(1) standard on material safety data sheets
  8. The program must meet the 1910.1200(g)(8) standard on the availability of material safety data sheets to employees

So, clearly you can see how each ISNetworld® safety program requires certain provisions to be included in the document. Please note that not all of these written safety programs will be regulatory in nature as some will be owner-client specific, but you get the point. When these requirements are listed as such, your written safety program must contain each provision to be ISNetworld® compliant. Now, if you have your policies in place already, simply review them for the clauses and amend them as needed. If you don’t have these written policies, use the ISNetworld® provided guidelines and start writing away.

There are some companies online that offer downloadable safety programs that meet the ISNetworld® requirements. However, we don’t recommend that your entire safety program be modeled after boiler-plate safety policies. Remember, employees should be aware of the company’s safety policies and are entitled to a copy. The boiler-plate programs are largely inadequate to meet many requirements outside of ISNetworld®, especially training requirements. Please be beware.

Once you have written or compiled your safety programs required by all owner-clients, then ISNetworld® will need about three weeks or so to review them all. If you have missed a requirement, ISNetworld® will deduct a percentage from your score (e.g. 75%). However, if you follow the ISNetworld® guidelines and ensure that every required component is contained somewhere in the program, your company will most likely see 100% compliance on the safety program RAVS® section.

T-RAVS

Now, T-RAVS® is reserved for the employee training that your organization must conduct (or have conducted) by owner-client requirements. ISNetworld® does not conduct any training, but merely reviews training records to ensure compliance with the associated requirements. Training records are simple to maintain and keep once the training is conducted. Your company can have employees attend formal training or the training can be conducted in-house–it really doesn’t matter how, it matters that it was done. Here’s what ISNetworld® will require for an acceptable training record submission and for compliance:

  • Date of training
  • Signature of employees in attendance
  • Subject matter of training or type of training
  • Signature of trainer

Training records are usually reviewed by ISNetworld® staff within a week or so.

Miscellaneous

Be prepared to meet some miscellaneous requirements from time to time. Examples include site tracker requirements, site identification cards, contractor documents that must be signed, etc. These requirements do not really hold much weight on your overall dashboard grade, but then again, they don’t generally require too much effort to complete either. We recommend that you complete all miscellaneous requirements as needed. ISNetworld® will usually review this stuff within a few days.

Overview and Summary

So, now that you understand that there is a lot more to ISNetworld® compliance than what you previously thought, be aware of those organizations offering overnight or prompt ISNetworld® compliance because it doesn’t happen that quickly. Firstly, ISNetworld® needs a certain amount of time to review the documents you’re going to be submitting and this will vary with what the documents are. Safety programs will take three weeks on average, but possibly more time than that if there are many programs to review. Remember that all of your files must be submitted as scanned .pdf documents  or you can save your Word documents as that file type.

Once your company has earned the ISNetworld® stamp of approval noted by the dashboard grade, the account will need to be updated every quarter or when you acquire a new owner-client on the account. Good luck and remember that safety is more about people and less about liability!

Markus Wesaw is in no way endorsed, sponsored, approved by, or otherwise affiliated with ISNetworld®. ISNetworld®, ISN®, ISNetworld®, and RAVS® are registered trademarks of ISN Software Corporation.