2008-2009 Policy Year 2008-2009 Policy Year Yearly SSOP Compliance Audit Yearly SSOP Compliance Audit

SummarySummary

Presented by Hettrick, Cyr & Associates Inc.

Compliance Audit TimelineCompliance Audit Timeline

Audit period was from May 1, 2008 through October 15, 2008 Audit period was from May 1, 2008 through October 15, 2008 21 roofing members, and 1 paving member audited in the 5.5 21 roofing members, and 1 paving member audited in the 5.5

months since that May 1, date.months since that May 1, date.

In addition to compliance with SSOP’s, In addition to compliance with SSOP’s, 31 roofing jobsites roofing jobsites were inspected during this period. were inspected during this period.

Only member not included in this process was Pfister Roofing Only member not included in this process was Pfister Roofing who joined in the middle of this process. Metcalf Paving was who joined in the middle of this process. Metcalf Paving was audited but findings are not including in this presentation as audited but findings are not including in this presentation as their SSOP’s are not apples to apples.their SSOP’s are not apples to apples.

Initial Standard Safety Operating Initial Standard Safety Operating Procedures ComplianceProcedures Compliance

1

20

0

5

10

15

20

In Compliance withall SSOPs

Not in FullCompliance

Compliance Review 1 yr post SSOP Adoption

Full Compliance with SSOP’sFull Compliance with SSOP’s

MacDonald Sprague Roofing CompanyMacDonald Sprague Roofing Company

Follow-up phone-auditFollow-up phone-audit

20

1

0

5

10

15

20

In Compliance withall SSOPs

Not in FullCompliance

Compliance after 30-Day Phone Survey Period

- After October meeting, NERI Ownership gave all members an additional 30 days to come into full compliance with SSOP’s.

- After the 30-day grace HC&A began conducting phone audits, and requesting paperwork verifying adherence with the SSOP’s.

- Presently, all but one (1) NERI Member is found to be in full compliance with the SSOP’s.

Not in Full Compliance

Standard Safety Operating Procedures

3

1

1

1

2

1

1

1

1

2

3

4

4

6

7

8

10

11

11

12

0 5 10 15

O SHA 10-Hour

Criminal Rec.

FRI

Acc. Invest.

Council/Discipline

Pre-Existing Dam.

Tool Box Talks

Comp. Drug Test

Safety Comm.

New-Hire Training

MVR Checks

Site Inspection Program

Regulatory Training

Penalty Pt. System

Number of Companies

Jobsite FindingsJobsite Findings

BARRETT ROOFING

EAGLE CORNICE

EAGLE CORNICE

FUREY ROOFING

GILBERT & BECKER

MCKENNA

JERSEY PARTNERS

KLEIN

R&S CONSTRUCTION

Improvement neededImprovement needed

Random Inspection ProgramRandom Inspection Program Scorecard system implemented in the fall of 2007. In Scorecard system implemented in the fall of 2007. In

approximately one years time HC&A conducted approximately one years time HC&A conducted 96 NERI 96 NERI jobsite inspections. jobsite inspections.

NERI CAPTIVENERI CAPTIVERANDOM AUDIT AVERAGE SCORESRANDOM AUDIT AVERAGE SCORES

As of 10-17-08 (1 full year) with 96 Jobsite Inspections ConductedAs of 10-17-08 (1 full year) with 96 Jobsite Inspections Conducted

88 88

7883

87

0 0

8387

80

98

88 8793

95 9593

8488

9487

80

0

10

20

30

40

50

60

70

80

90

100

NERI Member Captive Average 86

1 Year Scorecard Critique1 Year Scorecard Critique Scorecards are heavily weighed towards Fall Protection. Scorecards are heavily weighed towards Fall Protection. Jobsites below a score of a 90 very often have some kind of fall Jobsites below a score of a 90 very often have some kind of fall

protection concern. While above 70 didn’t require a written protection concern. While above 70 didn’t require a written response, there could very well be significant fall issues.response, there could very well be significant fall issues.

- HC&A reviewed all 96 scorecards and focused solely on fall protection.

- Goal was determine what percentage of jobsites found had fall protection inadequacies.

- Minor issues such as damaged equipment not in use, or a hole cover secured but not painted were excluded.

- All jobsites with findings which HC&A believed would be found as ‘serious’ fall protection violations were listed as “non-compliant.”

Fall Protection ComplianceFall Protection ComplianceA review of 96 NERI Scorecard ReportsA review of 96 NERI Scorecard Reports

49 47

05

101520253035404550

Compliant Non-Compliant

- After one year of inspections, nearly 50% of all projects working in the captive are found non-compliant for fall protection.

- Reducing this percentage should be our #1 loss prevention goal.

Recommendations to reduce fall protection Recommendations to reduce fall protection non-compliance findingsnon-compliance findings

1. Fully Implement SSOP’s.

2. Aggressive ‘consistent’ approach towards Jobsite Safety Inspections & corrective actions should be implemented.

3. All companies need to internally evaluate the effectiveness of their programs. Safety Representative Roles are critical!! SSOP’s are specifically designed to reduce these findings if effectively implemented;

Developed Program & Procedures Trained Employees Management Evaluation through Inspections Disciplinary Action / Counseling / Re-training for non-compliance.

4. HC&A to implement scorecard adjustments to develop a strict zero-tolerance policy.

Compliant / Non-Compliant black & white fall protection rating now given on all scorecards. All ‘Non-Compliant’ projects will require a written response to HC&A by the company owner

detailing what was done as a result of the finding. Three consecutive ‘Non-Compliant” projects will require company officials to attend a Loss

Control Committee meeting to discuss plan of action to assist the member towards improvement.

Scorecard ChangesScorecard ChangesFALL PROTECTION COMPLIANT / NON-COMPLIANT

Our NERI goal is 100% compliance. Fall violations are not acceptable and zero tolerance will be permitted for serious violations. Any item within the

fall protection module of this scorecard which incurs a point deduction AND the inspector believes it to be a serious violation shall relegate the job as NON-COMPLIANT. Examples where pts may be taken off for

COMPLIANT sites include; well secured hole covers not painted ‘hole or cover’; a small amount of damaged fall protection equipment not in use

and doesn’t appear to have been in use; less than 10% of the warning line or guardrail system with flaws in areas which are not in close proximity to

employees; etc.

Circle One: COMPLIANT NON-COMPLIANT

Scorecard ChangesScorecard Changes

Loss Control Committee has decided to raise the level in which a written Loss Control Committee has decided to raise the level in which a written response is requires from a 70 to an 80. response is requires from a 70 to an 80.

All projects will be evaluated with zero-tolerance for fall protection. A All projects will be evaluated with zero-tolerance for fall protection. A

‘non-compliant’ fall protection inspection will also require a written ‘non-compliant’ fall protection inspection will also require a written response.response.

Three consecutive ‘non-compliant’ fall protection inspections will require Three consecutive ‘non-compliant’ fall protection inspections will require owner attendance at the next Loss Control Committee meeting.owner attendance at the next Loss Control Committee meeting.

The Loss Control Committee will review scores below an 80 in which The Loss Control Committee will review scores below an 80 in which HC&A believed there to be egregious findings. These will be submitted to HC&A believed there to be egregious findings. These will be submitted to the committee for review without the name of the company involved. The the committee for review without the name of the company involved. The committee will make a determination on a course of action, and may committee will make a determination on a course of action, and may propose an additional follow-up inspection at the owners expense. propose an additional follow-up inspection at the owners expense.

Random Inspection Program Random Inspection Program Year 2Year 2

HC&A has conducted 15 random inspections from November 2008, through HC&A has conducted 15 random inspections from November 2008, through February 2009.February 2009.

Of the 15 inspections, five (5) have had “non-compliant” fall protection items.Of the 15 inspections, five (5) have had “non-compliant” fall protection items.

10

5

0

5

10

Compliant Non-Compliant

NERI CAPTIVENERI CAPTIVERANDOM AUDIT AVERAGE SCORESRANDOM AUDIT AVERAGE SCORES

Year 2 of Scorecard Program, November 08 – February 09 Year 2 of Scorecard Program, November 08 – February 09 15 Jobsite Inspections Conducted15 Jobsite Inspections Conducted

97100

95 95

69

9893

90

78

99 100

0

10

20

30

40

50

60

70

80

90

100

NERI Member Captive Average 92

SUMMARYSUMMARY Captive members need to continue working towards Captive members need to continue working towards

full compliance with SSOP’s. full compliance with SSOP’s. Fall protection needs additional emphasis and a zero-Fall protection needs additional emphasis and a zero-

tolerance attitude. Too large of a percentage of tolerance attitude. Too large of a percentage of projects are being found ‘non-compliant’ with fall projects are being found ‘non-compliant’ with fall protection. Scorecard changes to reflect this item is protection. Scorecard changes to reflect this item is being implemented.being implemented.

Year two random inspections are going well. Keep Year two random inspections are going well. Keep up the good work!!up the good work!!