Northeast Roofing Insurance Company
Minimum Safety Operating Procedures (SOP’S)
As of 1-1-09
Hiring
Practices
Member Requirements
Auditing
Procedures
Expected
Results
Required Resources
Social
Security
Verification
SS# must be provided as part the I-9
Employment Forms by law. The employer is
only responsible to verify SS# thru 3 rd party if
it appears false at face value.
Upon audits, HC&A
will review recently
hired employee files
to ensure this is being
obtained.
I-9 forms, as well as HR &
administrative assistance to ensure they
are completed.
Mandatory
Post Offer
Physical
Examination
& Human
Performance
Evaluation
All employers would be required to
implement a Physical Examination & Human
Performance Evaluation program. A
functional test developed after the
measurement of a given position's essential
job functions; this test helps the employer
assess the applicant's/employee's ability to
perform the job and/or to return to work
following an injury. Due to some Union
Bargaining Agreement, all contactors may not
be able to perform this evaluation.
Unless the Employer can provide
documentation that pre-employment drug
screening is prohibited by State Employment
Laws, or by a Collective Bargaining
Agreement, all members shall be required to
conduct pre-employment drug testing for all
new applicants.
Upon audits, HC&A
will review recently
hired employee files
to ensure this is being
obtained.
Ensure that SS #
provided is valid.
Provides employers
with information in
making a good hiring
decision.
Ensure that the
employees hired can
performed the
required functions of
the position.
Members would have to locate a
facility who performs these
evaluations. A list of the essential job
functions must be created. Financial
resources will be necessary to cover the
cost of the examinations.
Recommended
A program must be developed. Due to
varying state laws, specific union
requirements, and legal concerns
HC&A recommends the captive utilize
a lawyer experienced in labor &
employment matters specific to the
states each contractor operates in.
Mandatory
Prof. reference checks are required for
supervisory level key positions, I.E.
foreman, superintendent, project manager,
office personnel of high level, etc. Prof.
Reference checks are not required for entry
level personnel.
Upon audits, HC&A
will review recently
hired employee files
to ensure this is being
obtained.
Reduce workers
comp. costs and
assist in making a
good hiring decision.
Statistically,
substance abusers
have 50% higher
worker comp. costs.
To provide
employers with
information in
making a good hiring
decision. Obtains
info about work ethic
& personality.
HR &/or administrative assistance will
be necessary to ensure background
information is completed on the
application and contact prior
employers. Screening services may
also be used to contact prior employers
though it requires financial resources.
Mandatory
Preemployment
Drug Screens
Professional
Reference
Checks Management
Upon audits, HC&A
will review recently
hired employee files
to ensure this is being
obtained.
1
Date
Required
10/1/07
7/1/07
10/01/07
Recommended
that this be
done for all
employees.
Hiring
Practices
Criminal
History
Checks
Post
Injury
Mgmt.
Return-toWork
Programs
First Report of
Incident to
Insurance
Carrier
Supervisor’s
Accident
Investigation
Member Requirements
Auditing
Procedures
Expected
Results
Required Resources
Criminal History Checks are required for
supervisory level positions, I.E. foreman,
superintendent, project manager, etc. Criminal
History Checks are not required for entry level
personnel.
Upon audits, HC&A
will review recently
hired employee files
to ensure this is being
obtained.
To provide
employers with
information in
making a good hiring
decision. Prevent
theft and other
criminal activities.
Members would be required to locate a
service to perform these background
checks. Financial resources to obtain
the information would be required.
Member Requirements
Auditing
Procedures
Expected
Results
A reduction in lost-work days is critical to the
overall success of the captive. Members shall
be required to accommodate restrictive duty,
as feasible, within the treating physician’s
restrictions.
HC&A will monitor
days away from work
thru benchmarking
submitted monthly.
In addition, during
audits HC&A shall
evaluate the
implementation of
this program when
reviewing losses.
RTW Programs
greatly reduce the
direct & indirect
costs that WC claims
can incur.
Timely reporting of injuries is critical. Each
Member shall forward the completed First
Report of Injury Form to the Insurance Carrier
by next business day after reported. This
includes FRI’s for all injuries and record only
cases.
Supervisor Accident Investigation’s must be
completed within 48-hours of notification of
the accident. Accident Investigation shall be
completed by the Safety Coordinator or the
onsite foreman. If completed by the onsite
foreman, the company Safety Coordinator
must review and sign the Investigation form.
During audits,
HC&A shall review
the date of injury and
date reported when
reviewing losses.
By reporting injuries
quickly, costs and
damages can be
minimized.
During audits,
HC&A shall review
the date of injury and
date the investigation
was completed.
HC&A shall evaluate
the quality of the
investigation reports.
By investigating
accidents fully, we
can determine root
causes which must be
eliminated to prevent
a reoccurrence.
2
Date
Required
Mandatory
10/01/07
Recommended
that this be
done for all
employees.
Required Resources
A written program is necessary.
HC&A has provided a model Returnto-work program in the NERI Safety
Manual. Employees & Supervisors
must be trained of the programs
requirements. Someone in the
organization must take on the
responsibility of overseeing the
programs implementation, and
checking in with those on modified
duty.
Each contractor must have an FRI for
their particular state. Administrative
assistance to send FRI’s to the carrier,
and oversight to ensure accidents are
reported immediately.
Investigation forms must be available
for Incident (GL/Property), Auto, and
WC investigations. (samples available
on NERI website) Those performing
the investigations must receive training.
Time must be allocated to allow for a
thorough investigation of all incidents
& accidents. A digital camera should
be available to those performing
investigations.
Date
Required
Mandatory
7/1/07
Mandatory
7/1/07
Mandatory
7/1/07
Committee
Structure
Member Requirements
Auditing
Procedures
Implementation
of a Safety
Committee.
Each contractor shall be required to
implement a safety committee which will
review the company safety policies, programs,
and accidents.
HC&A shall review
the Safety Committee
meeting minutes
during each visit.
-25 or more employees : quarterly
committee meetings.
-24 or less employees, quarterly safety
meetings with all employees.
Expected
Results
Set plan of action
each meeting to
address safety items
that arise, and set
forth programs that
reduce workplace
injuries, accidents,
near misses &
hazards.
Required Resources
Members must allocate time of
employees from various departments
including managerial & nonmanagerial employees to implement an
effective committee. Administrative
time in creation of meeting minutes.
HC&A has provided a Safety
Committee Program in the NERI
Safety Manual.
Employee
Drug &
Alcohol
Testing
Member Requirements
Auditing
Procedures
Expected
Results
Required Resources
Post Accident,
Random,
Reasonable
Suspicion drug
& alcohol
testing.
Each contractor shall be required to
implement a Drug & Alcohol Testing Program
that is the most stringent allowable under the
state laws which the company operates in.
HC&A shall review
each members policy
& compliance
individually based on
their state laws for
drug & alcohol
screening.
Reduce workers
comp. costs, reduce
turnover, and provide
a drug free
workplace.
Statistically,
substance abusers
have 50% higher
worker comp. costs
A program must be developed. Due to
varying state laws, specific union
requirements, and legal concerns
HC&A recommends the captive
members utilize a lawyer experienced
in labor & employment matters specific
to the states each contractor operates in.
Financial resources will be necessary to
cover the cost of the drug screens.
Each contractor shall have two employees
trained in reasonable suspicion.
3
Date
Required
Mandatory
1/01/08
Date
Required
Mandatory
1/1/08
Specific
Safety
Training
Member Requirements
Auditing
Procedures
Expected
Results
Required Resources
Documented
New Hire
Orientation
Documented new-hire orientation records
shall be kept for employees hired after (date to
be determined by LCC). Orientation shall
include all the elements provided by HC&A in
the Safety Orientation Outline. Each
employee shall take the Orientation test (to be
provided by HC&A) and the test shall be
corrected and reviewed with the employee
prior to hire. The employee shall sign the test
documentation stating he/she has reviewed the
test answers with the employer, and
understands each of the answers &
requirements.
Contractors would be required to ensure all
Safety Coordinators, Superintendents &
Foreman have completed the OSHA 10-Hour
Training. Any new supervisory level
employee would then have 12 months posthire to complete this training.
HC&A shall review
new-hire files to
ensure each new-hire
has completed the
orientation program
and documentation
prior to hire.
Provide new-hires
with an orientation
into the safety culture
of the NERI
company. Ensure
they are made aware
of the potential
hazards, and required
controls the company
has put in place.
Utilize the HC&A provided Orientation
Outline & Test that will be placed on
the NERI Website. A company officer
trained in OSHA regulations must be
made available to conduct the
orientation, and correct & review the
test answers with the employee.
Each Company shall ensure that a toolbox talk
is conducted with all employees on a weekly
basis. The TBT shall be specific to the
roofing industry.
HC&A shall review
the TBT
documentation
during each audit.
Provide supervisors
with OSHA
regulatory knowledge
to act as competent
persons, and
effectively recognize
and address hazards
in the workplace.
Provides a method of
refresher training on
various topics.
Specific regulations require comprehensive
training in addition to the Orientation & Tool
Box Talk Program. Each contractor shall be
required to provide this training on an annual
basis, and have documentation on file. These
shall include but are not limited to;
During audits,
HC&A shall request
to see documentation
when employees are
observed exposed to
these hazards.
Documentation must
be made available.
Each contractor must locate an OSHA
Outreach Trainer, or have an employee
become an OSHA Outreach Trainer so
they can train all employees. Financial
resources to obtain a trainer will be
necessary. HC&A to provide
information on pricing for them to
conduct training.
Employers must provide time each
week for all employees to attend these
meetings. HC&A has provided a Tool
Box Talk Program in the NERI Safety
Manual.
Time and financial resources in
provided training for all employees.
HC&A shall provide technical support
on the implementation of these
programs, and will post presentations
on the NERI Website.
Conduct OSHA
10-hour Training
for Safety
Coordinators,
Superintendents
& Foreman and
other lead
personnel.
Weekly Toolbox
Talks
Documented
Regulatory
Training
(OSHA)
- Comprehensive Fall Protection Training (1-2
hours)
- Scaffold User Training (all employees using
scaffolding) (1 hour)
- Ladder Training (30 minutes)
- Fire Protection/Prevention (30 minutes)
- Hazard Communication (30 minutes)
- Electrical (30 minutes)
HC&A shall ensure
all contractors
supervisory level
employees have
completed this
training during
audits.
4
Ensure employees
have knowledge &
understanding of
OSHA regulations
pertaining to these
specific high hazard
areas.
Date
Required
Mandatory
10/1/07
English &
Spanish.
10-hour OSHA card offsets
orientation if test is passed with 70%
or greater and wrong answers
reviewed.
(HC&A TO PROVIDE A MORE
DETAILED TRAINING MATRIX
AND ASSOCIATED COSTS TO
CONDUCT THE TRAINING)
Mandatory
5/1/08
Mandatory
10/1/07
Mandatory
5/1/08
Specific
Safety
Training
Member Requirements
Auditing
Procedures
Expected
Results
Required Resources
Annual Safety
Day
Each member of the Insurance Captive
Program shall send their Safety Coordinator to
the Annual Safety Day Meeting.
HC&A will ensure all
company’s are
represented at these
meetings.
Employers will have to allow their
Safety Coordinator to attend these
meetings. HC&A shall coordinate and
conduct these meetings. An agenda
will be created for each and approved
by the LCC.
Employers must make their employees
available for this training. Financial
costs are associated with the training.
CERTA Training shall be conducted for all
employees performing torch down roof
installations. It is not mandatory for members
who utilize torches for general purposes.
HC&A shall review
this documentation at
subsequent audits.
Provide safety
managers with
training to perform
effectively, share
experiences and
network.
Prevent fires
associated with torch
down applications.
Member Requirements
Auditing
Procedures
Expected
Results
Required Resources
Members shall be required to conduct random
job site safety evaluations for each foreman.
The safety director, superintendent, or project
manager shall complete the documented
evaluations. Each project lasting more than
one week shall be inspected on a weekly
basis. Every company foreman shall have
their jobsite inspected at least once every two
weeks.
HC&A shall ensure
the completion of this
documentation and
frequency during
audits.
Improve the safety
culture by placing an
emphasis on Safety
Compliance. Assess
the implementation of
company programs.
Correct identified
hazards.
Time must be allocated for those
performing inspections. HC&A has
provided a Jobsite Safety Inspection
Program and forms in the NERI Safety
Manual.
Driver/
Auto-Safety
Member Requirements
Auditing
Procedures
Expected
Results
Required Resources
Driver Motor
Vehicle Records
Motor vehicle history reports shall be
reviewed upon initial hire for all employees
whom may drive a company vehicle and on an
annual basis thereafter for each driver listed
on the auto policy, or who are using personal
vehicles on company business.
HC&A shall
periodically review
company
documentation
ensuring that all
drivers on the auto
policy have had
annual MVR’s pulled.
HC&A shall review
the company’s
compliance with the
SSOP.
Allows members to
review the driving
history and make an
educated decision on
whether or not the
employee should
drive a company
vehicle.
Provide a structured
format to gauge an
employees driving
history by.
CERTA
(NRCA’s Torch
Training
Program)
Jobsite
Evaluations
Documented
Jobsite Safety
Inspections
Penalty Point
System
A standardized penalty point system should be
utilized when reviewing MVR’s to determine
if a driver shall be allowed to drive a company
vehicle.
5
Financial costs are associated with
obtaining these records. Time for
collecting and reviewing these records
by administrative personnel.
Date
Required
Mandatory
7/1/07
Recommended
HC&A to
develop a
Torch Training
Program
Date
Required
Mandatory
10/1/07
Date
Required
Mandatory
10/1/07
A program must be implemented, and
time to review must be allocated.
HC&A has provided two penalty point
systems in the NERI Safety Manual.
Mandatory
10/1/07
Driver/
Auto-Safety
Member Requirements
Auditing
Procedures
Expected
Results
Reduce automobile
claims by providing
employees with
defensive driving
techniques and
reducing
complacency while
behind wheel.
Provide employees
with a ‘to do’ list
should they be
involved in an
automobile accident.
Cameras allow for
pictures to be taken
which could provide
additional
information.
Provides a formal
structured notifying
employees of
expectations while
operating company
vehicles.
Defensive Driver
Training
Each contractor shall provide a DDC at least
once every two years. There are many
agencies which provide this service, each
contractor will be responsible for locating an
agency in their area to conduct this training.
HC&A shall review
company
documentation to
ensure this training is
completed once every
two years.
Vehicle Accident
Investigation
Kits
Liberty Mutual to provide a vehicle accident
investigation kit in each company
owned/leased vehicle. Accident Investigation
Kits shall include a document to record
involved party’s information & witness
statements. Members must provide disposable
cameras with the vehicle accident
investigation kits and place in each vehicle.
During HC&A
audits, random
vehicles will be
inspected to ensure
they have this kit.
Company
Vehicle Policy
All members shall have all drivers of
company vehicles sign the NERI Company
Vehicle Policy.
HC&A shall review
documentation to
ensure all listed
drivers have signed
the document.
Interactive
Safety
Manual
Written
Administrative
Programs
Written
Compliance
Programs
Required Resources
Financial resources must be made
available to hire a service or trainer to
conduct this training. HC&A shall
assist contractors in locating a suitable
agency for this training. There are
online training programs available as
well.
Liberty Mutual to provide all
company’s with Auto Incident Kits
which will be placed in each vehicle.
HC&A shall provide the Company
Vehicle Policy on the NERI Website
Member Requirements
Auditing
Procedures
Expected
Results
Required Resources
Each contractor shall ensure they have Written
Administrative Programs as a part of their
overall Safety Manual. Administrative
Programs include Commitment to Safety,
Return-to-Work, Injury Reporting Procedures,
Employee Rules & Responsibilities, &
Disciplinary Procedures
Each contractor shall ensure they have Written
Compliance Programs as a part of their overall
Safety Manual. Compliance Programs include
Fall Protection, Scaffolding, Material
Handling, Fire Prevention, Ladders, Electrical
Safety, Aerial Lifts, and Jobsite Setup
HC&A will review
each contractors
written programs
during future audits.
Ensure administrative
programs and
policies are in writing
for purposes of
consistency.
HC&A has provided these programs in
the NERI Safety Manual.
HC&A will review
each contractors
written programs
during future audits.
Ensure Compliance
programs and
policies are in writing
for purposes of
consistency.
HC&A has provided these programs in
the NERI Safety Manual.
6
Date
Required
Recommended
Mandatory
10/1/07
Mandatory
Date
Required
Mandatory
1/1/08
Mandatory
1/1/08
Employee
Accountability
Safety
Counseling
Program
Progressive
Disciplinary
Program
Member Requirements
Contractors shall be required to implement a
Safety Counseling Program consistent with
the program provided in the NERI Safety
Manual.
Auditing
Procedures
HC&A shall review
company
documentation
during subsequent
audits.
Contractors shall be required to implement a
Progressive Disciplinary Program consistent
with the program provided in the NERI Safety
Manual.
HC&A has provided
this program in the
NERI Safety Manual.
HC&A shall review
company
documentation
during subsequent
audits.
General
Liability
Member Requirements
Auditing
Procedures
Subcontractor
Requirements
General Liability minimum for
subcontractors: $1M per occurrence with a
$2M aggregate. There may be circumstances
where the scope of work within the contract
may not warrant $1M/2M, in which case an
exception may be made for the small specialty
subcontractor. This would require approval
from underwriting committee
The subcontractor should provide the NERI
member with an Insurance certificate naming
the NERI member as additional insured using
forms CG20 33 07 04 and CG20 37 07 04
together
Additional
Insured
requirements
HC&A will review
during future audits
Expected
Results
Required Resources
Counseling is a nonconfrontation
approach towards
eliminating unsafe
acts through
retraining.
After retraining has
been completed,
crewmembers shall
be held accountable
for future violations
of the company’s
safety program.
Accountability is one
of the key
components in
developing a safety
culture.
Implementation of a program, and time
must be allowed to administer the
program. HC&A has provided this
program in the NERI Safety Manual.
Expected
Results
Required Resources
Ensure
subcontractors have
acceptable insurance
limits.
Date
Required
Mandatory
5/1/08
Implementation of a program, and time
must be allocated to administer the
program. HC&A has provided this
program in the NERI Safety Manual.
Mandatory
5/1/08
Date
Required
To be determined.
Mandatory
7/1/07
HC&A will review
during future audits
Mandatory
7-1-07
7
General
Liability
Member Requirements
Auditing
Procedures
Expected
Results
Subcontractor’s
Insurer
Requirements
Subcontractors insurance should be
primary and noncontributory. Carrier Rating
of AVIII or better
HC&A will review
during future audits
Waiver of
Subrogation
Waiver of Subrogation in favor of the NERI
member should be requested for each line of
insurance whenever possible. (Auto, WC, and
GL)
Members shall endevour to document
whenever feasible the pre-existing conditions
for all projects that are not new construction.
Documentation would include photos or
video, and would require signature of the
projects primary contract.
HC&A will review
during future audits
HC&A shall review
recent job files to
determine if preexisting damages
have been evaluated.
Protect the member
from fraudulent
claims.
A subcommittee would be developed to create
a tie-in / Roof Penetration training procedures
with pictures and examples of proper and
improper tie-ins. The program will emphasize
the importance by giving examples of poor
tie-ins and some disastrous outcomes. This
training program will then be required for all
employees on an annual basis.
To be determined.
Minimize the
possibility of water
damage resulting
from improper tieins.
Documented
Pre-Existing
Damages
Tie-In / Roof
Penetration
Training
Program.
Required Resources
Date
Required
Mandatory
7-1-07
Mandatory
7-1-07
8
Implementation of a program, and time
must be allocated to administer the
program. HC&A has provided a PreExisting Jobsite Inspection Program in
the NERI Safety Manual.
Time must be allocated to develop this
program and provide training to all
employees.
Mandatory
1/1/08
Mandatory
5/1/08
Crane
Safety
Auditing
Procedures
Expected
Results
Required Resources
NERI Members shall ensure that each crane
they own, operate, or rent has a 3rd party
annual inspection.
HC&A shall review
each members
documentation to
ensure 3rd party certs
are current.
Ensure crane is given
a comprehensive and
unbiased review of
safe operating
capacity. Provides
level of comfort to all
parties.
Crane Rentals
Insurance and
rental operator
training
requirements
If a crane is rented the crane supplier shall
provide evidence as follows;
a. Workers compensation (if rented with
operator)
b. General liability with minimum limits
of $1,000,000 naming NERI member
as additionally insured.
c. A one-time letter from the rental
company stating that their crane
operators are fully qualified, and
licensed (if necessary).
HC&A shall request
copies of insurance
certificates during
annual compliance
audits.
Ensures adequate
insurance coverage is
provided by the rental
company.
Financial resources will be required.
Tracking of the equipment to ensure reinspections occur yearly. Because no
state (other than CA) licenses crane
inspectors, it is recommended that
the inspection be conducted by an
agency associated with the Crane
Certification Association of America.
Communication with crane rental
companies.
Operator
Training
1. Operators working in states which require
licensing must be licensed.
HC&A shall review
certificates of
training during
inspections.
Improves
competency of
operators, helps
prevent incident.
Contact HC&A for assistance in
finding such a program. Ensure that
when working in different states, that
the requirements are met. Provide time
& resources to operators to complete
this training.
This is a
recommended SSOP.
Provides assurance
that the crane
operators are fully
qualified and possess
the highest level of
training.
Raise awareness of
crane safety
requirements, and
improve knowledge
of rigging, hand
signals, and safe
crane operation.
For information about the NCCCO or
CCO visit; http://www.nccco.org/
3rd Party Annual
Inspection
Member Requirements
2. Operators working in states that do not
require licensing must receive a minimum of
8-Hours Mobile Crane Awareness Training
every two years. (MANDATORY)
Operator
National
Certification
Training
Crane Safety
Awareness
Training for
Superintendents,
Foreman & Lead
Personnel
It is highly recommended that each company
mandate their crane operators pass the
Certification of Crane Operators (CCO) exam
which is conducted by the Nationally
accredited agency for crane certification
(NCCCO).
Superintendents, Foremen & Lead Personnel
should attend the 8-hour mobile crane
awareness training. (RECOMMENDED)
This is a
recommended SSOP.
9
Date
Required
Mandatory
Mandatory
Mandatory
Recommended
Contact HC&A for assistance in
finding such a program.
Recommended