As more and more large companies require the services and products within their supply chain, there has been a substantial growth in the use of ISNetworld® and other third party prequalification companies such as Avetta and PEC Premier. ISNetworld® is a company that offers verification services for what they call "owner-clients" or “hiring clients” (the organization that you want to do business with) and suppliers/vendors (your company). The ISN review team checks and approves documents for specific requirements and issues a report card called the "Dashboard Grade" to the hiring-client. This Dashboard Grade is extremely important because that is really what is meant by ISNetworld® compliance. This article aims to describe the process of achieving ISNetworld® compliance.
Prepare by gathering your company documents together. You will need to gather 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 assist in the startup process since it will be readily available to you.
Select the most appropriate NAICS code that applies to your operations and business. Be sure to input this into your company profile as accurately as possible keeping in mind that some industries have a harder time than others fitting into a NAICS code category. ISNetworld® will ask that you identify your industry type, or work 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 potentially irrelevant employee safety training and/or written safety program requirements. My advice: Get this right from the start!
MSQ (Management Safety Questionnaire)
The management safety questionnaire, or MSQ, is a very important next step towards achieving ISNetworld® compliance. Prepare to take some time to complete the MSQ because completing this can potentially take some time depending upon what information is being requested. There are two categories of MSQ 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. If your business is located outside of the United States expect a General MSQ for your country such as the Canada MSQ. You will 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 MSQ is going to be hiring-client specific. More to the point, some hiring-clients have devised their very own MSQ questionnaire for you to complete and these can range in terms of the expected time commitment and effort. It is not uncommon for some of these questions to be repeated from other MSQ sections such as the United States MSQ or from another hiring-client MSQ. If the same information is being requested in different MSQ sections, you will need to complete each questionnaire anyway.
HINT: Make sure that the information you input into the MSQ matches the documents you gathered in the beginning. Discrepancies will be noticed by the ISNetworld® review team and they will ask that these be resolved by flagging them as action items. Save yourself some effort and get this right the first time!
What is an I-RAVS? Many people ask that question and it is just ISNetworld® vernacular for insurance review and verification services, or simply, I-RAVS. This section pertains to your company's commercial insurance policy lines such as automobile, commercial general liability, etc. Each hiring-client will have specific and required insurance coverage lines that they want your company to carry at certain limits depending on your determined risk level. Hiring-clients utilize ISNetworld® reviewers to verify these certificates for accuracy and to ensure that every requirement is met. Don't mess around here. The ISNetworld® insurance review team will be looking over the insurance certificates that you have submitted and if your policies do not meet the requirements, expect a rejection notice. Many very experienced insurance brokers commonly fail to get passed the scrutiny of the ISNetworld® insurance review team.
The process to get the insurance requirements satisfied is really simple, but a high level of attention to should be paid to the details. You need to call or email your insurance broker. Print or save a copy of the insurance requirements for each hiring-client. Pay special attention to the word "required" and make sure that your insurance broker meets every "required" coverage type (i.e. CGL, Auto, Excess, and workers' compensation). Other setbacks are usually related to clauses like the 10-day notice of cancellation/non-payment policy, failure to add the certificate holder as an additional insured, or lack of a waiver of subrogation on a particular line of coverage. For example, if the requirements mandate a written 30 days notice policy on cancellation, this had better be listed 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 the ISNetworld® review team will reject the insurance certificate.
Many insurance brokers would simply check the Waiver of Subrogation box on the certificate and call it good. But...this won't be acceptable all of the time depending upon the hiring-client requirements. The waiver of subrogation is sometimes requested as an endorsement supplemental to the Acord 25 form or, where acceptable, may be simply checking the WOS box or adding this language into the description of operations box. It all depends on what the hiring-client requirements are and how these types of concerns are evidenced on insurance certificates can vary from state to state further adding to the complexity of attention to detail requisite for success.
It is worth noting that in the four (4) monopolistic workers' compensation states of Ohio, North Dakota, Washington, and Wyoming, the certificate of insurance provided by your insurance broker will not be sufficient to pass the verification of the ISNetworld® insurance review team. Most commonly, the requirements of hiring-clients will mandate what is called a Stop Gap, or employer's liability, line of coverage, which is indeed listed on the Acord 25 form in the appropriate section. However, if your business operates in these monopolistic states and/or has residents of these states, it is likely that you will need to get a certificate of good standing or certificate of premium payment from the workers' compensation authorities having jurisdiction for the respective state. For example, in Wyoming, you would reach out to the underwriters at Wyoming Workforce Services and in North Dakota, it would be North Dakota WSI. Because these monopolistic states are independent on workers' compensation concerns within that state, getting a certificate proving workers' compensation coverage may not be an immediately issued document; it can and does take some time, especially for new businesses or startups. This can often lead to delays in getting through the ISNetworld® insurance review procedure.
To be clear, in the monopolistic workers' compensation states, you would submit proof of workers' compensation from that respective state and the standard Acord 25 insurance certificate in order to obtain a positive review assuming, of course, your company has satisfied all of the other remaining lines of coverage requested by the hiring-client.
Occasionally, companies self-insured for workers' compensation require an ISNetworld® account and, in this case, there must be a valid certificate of self-insured status from the state in which has approved the self-insured status. However, the other lines of coverage, as required by the hiring-client, would need to be evidenced per the standard protocol described already herein.
The experience modification rating (EMR) letters are issued on an annual basis by the agency handling your company's workers' compensation in accordance with the applicable calculation rules of that state (e.g. NCCI). Most rejected EMR letters stem from submissions outside the desired effective dates or the EMR letter lacks an effective date for the calculation. ISNetworld® will track your EMR anniversary date and require submission each year once the new calculation becomes effective.
OSHA 300 and 300A Logs
The OSHA 300 and 300A logs are also quite simple in terms of what is needed. The biggest observed setback is that many companies have not met this OSHA mandatory recordkeeping requirement and have to draft these documents post hoc. Similarly, small companies with less than ten (10) employees are considered by the Occupational Safety and Health Administration (OSHA) as partially exempt from maintaining OSHA logs. Companies determined by OSHA to be very low risk such as employers in the floral sales business are also considered partially exempt. But… ISNetworld® will not grant you the partial exemption that OSHA allows and will require that the OSHA 300 and 300A logs are prepared, drafted, and submitted for review for the preceding last three (3) calendar years.
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. 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 MSQ questionnaire because this can result in a rejection and additional action items to be corrected.
Different hiring-clients will require a certain amount of written safety programs. Some hiring-clients won't require any written safety programs, while others will require your business to have inapplicable written safety programs. For example, an engineering consulting company may be required to have a Process Safety Management written program from the Title 29 CFR Part 1910.119 regulations despite the fact that these standards do not apply to the scope of work at that particular 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 impractical. 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 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
There are many requirements to the OSHA Hazard Communication standards, but it is evident that ISNetworld® selects those standards that suit its prequalification purposes. Most of the other written safety programs will have similar positions to what is shown in this example. Please note that not all of these written safety programs will be regulatory in nature as some will be hiring-client specific, but the point is clear on how the system functions. 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, it is not generally advisable 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. Many boiler-plate programs may be inadequate to meet regulatory requirements or injury prevention goals outside of ISNetworld®.
Once you have written or compiled your safety programs required by all hiring-clients, then ISNetworld® reviewers 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.
Training review and verification services, or T-RAVS, is reserved for the employee training that your organization must conduct (or have conducted) per hiring-client requirements. ISNetworld® does not conduct any regulatory training at the time of this writing, but many hiring-clients utilize the ISNetworld® platform to require mandatory site-specific online training or orientation programs. It is notable to differentiate that online hiring-client training modules geared toward site-specific or location specific policies do not necessarily cover the T-RAVS requirements.
Your company can have employees attend formal training or the training can be conducted in-house so long as the facilitator is a competent trainer. Note that some training sessions cannot be at the awareness level and require competency. Most training requirements, however, will be accepted at the awareness level. 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 depending on their workload demands.
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. It is recommend that your company complete all miscellaneous requirements as needed. ISNetworld® will usually review these documents within a few days on average, again, depending on their workload.
Overview and Summary
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 to be submitting and this will vary with the documents type. 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 document files.
Once your company has completed all of its action items in the ISNetworld® account, you will be awarded a Dashboard Grade on a per hiring-client basis. This means that each hiring-client grade is mutually exclusive of the other. You can have an A rating with one hiring-client and a D rating with another depending on the criteria utilized as the benchmark standards. Also remember that action items will populate in the account monthly, quarterly, and annually in addition to whenever a new hiring-client is added to the account or when insurance expires.
Lastly, ISNetworld® is not in any way a regulatory enforcement agency like OSHA. Rather, ISNetworld® is a review and verification agency that supports large corporations with complex supply chains. You can choose to what extent to participate or not by using their services. Overall, it is important to factor in the cost of ISNetworld® to your business and the associated administrative burden of maintaining your account on an ongoing basis.
This organization is in no way endorsed, sponsored, approved by, or otherwise affiliated with ISNetworld®.