Contractor Overcomes the Hurdles to Obtain COR™ Certification

It may have been a decade in the making, but through sheer determination, perseverance and grit, BML Multi Trades proudly achieved its Certificate of Recognition (COR™) certification in August this year.

“Here we are a decade later from when we first considered this, and although it’s not a requirement to contract work, our COR certification has given us a health and safety management system which allows us to operate safer and avoid injury,” said BML President Jim Di Novo. “More importantly, it is guiding our work force to follow the safest processes as they go about their work each and every day.”

Established in 1977 under the name Brantford Mechanical Ltd., the company changed its name to BML Multi Trades in 1997 to better reflect the company’s scope of work which currently includes the HVAC/R, plumbing, millwright, fire protection, electrical and sheet metal trades.

Although the company has evolved over the years, one thing that has remained constant is its commitment to health and safety. As a member of various safety groups including the Hamilton & Halton Safety Association and other groups within the Workplace Safety Insurance Board (WSIB), BML had established a health and safety policy early on in the infancy of the business.

But it wasn’t until 2011 when the Infrastructure Health & Safety Association (IHSA) brought COR to Ontario that the company felt the need to take its safety practices to the next level.

“When COR was first launched in Ontario, the industry was made to believe that it was going to become a condition of bidding on government work,” Di Novo said. “We didn’t know if it would extend into school board and university projects, which we participate heavily within. Considering that our company could certainly benefit from a health and safety management system, we decided to look into it.”

With BML Human Resources/Health and Safety Coordinator, Susan Coulas, tapped to lead the charge, BML began to gather the pieces required to complete the puzzle, and move the company to the next level. But the journey certainly wasn’t going to be a walk in the park.

“You have to document everything,” Coulas said. “It’s one thing to say to your employees ‘before you use that tool, you have to inspect it’, now we actually had to prove that the inspection happened.”

Di Novo said that when dealing with tradespeople, their mindset is focused on getting the job done properly. They didn’t recognize the importance of documentation. Even if an inspection did occur, BML had to implement a process to ensure their was a paper trail that could be utilized for subsequent auditing purposes. Definitely not a small feat for a smaller contracting firm.

BML generally employs 60 to 80 tradespeople and, administratively, the company is extremely lean. With both Coulas and Di Novo wearing multiple hats, time became the greatest challenge.

“Administratively, we’re very light here,” he explained. “Just something simple as Sue making sure we’ve gathered all the documentation and filed it, was becoming an administrative burden. It’s not like we have a COR administrator on staff, where that’s all they do. We simply don’t have the staff resources to do everything. So time was definitely a factor.”

Another factor adding to the complexities of moving through the elements, was the business structure of BML. Serving three different markets, with six different trades added to the challenges.

“We’re actually running 18 small companies here, where other companies are serving one market with one or more trades,” Di Novo said. “We cover all markets including new construction, industrial installations and commercial services. For a small business that’s already very complex, combined with a small administrative staff, it’s quite a task to make sure everyone is on board.”

Creating policy reflective of all aspects of the business only added to the challenge of meeting the requirements, especially since COR does not provide the actual policy. COR provides methods for companies to address each specific element, but it’s up to the company undergoing certification to create and customize the policies (safe work practices), related safe work procedures, and forms and documentation to meet the requirements. Then there are legislative requirements that also must be incorporated into the policies and procedures. In order to achieve COR certification, the company was required to achieve a minimum score of 65 per cent of the 19 elements and achieve an overall score of 80 per cent. When it comes to the legislative elements, COR demands a 100 per cent score to pass. Any shortcomings in this area result in an automatic fail.

With government constantly coming up with new rules and legislation, it can make one’s head spin.

“Naloxone kits on construction sites, the right to disconnect… the government is constantly coming up with legislation with little consultation with the industry, and then it’s thrown on the laps of employers,” Di Novo said. “We were required to incorporate all this new legislation into our policies, and make sure it can work within our business structure.”

Having compiled all the documentation and feeling extremely confident in their undertaking, BML submitted its first desk audit pre-COVID in 2019, but the results were not what the company expected. With a score well below the pass rate, they went back to fill in some of the shortcomings within their documentation. The second attempt submitted in 2021 pushed the needle forward slightly, but still not to the pass level.

With time ticking to submit, the company enlisted the assistance of a consultant to provide guidance. This time, it was all or nothing. “I would suggest to anybody who is considering undertaking COR certification to hire a consultant,” Coulas said. “It is such a huge task, so the investment of bringing in an expert is well worth it.”

According to Di Novo, if BML didn’t pass this time, he’d be “done with COR.” “We are representative of small to mid-size business and if we can’t do it – because I think we’re a pretty good example – then the standard is simply too fussy,” he said.

With a score of 61 per cent, Coulas and Di Novo were devastated, and went back to their IHSA Internal Auditor who promptly advised them that “you’ve got this wrong, you actually had a really good fail.”

“What happens when you submit your desk audit, it’s like you’re submitting to double-blind judges. They’re looking for specific things,” Di Novo explained. “Like a teacher marking an essay, they just want to see if you mentioned everything that needs mentioning. So, if you receive two ticks for a section that is worth five, you get 40 per cent, in some sections of the grading, in other sections it is all or nothing for grading. In other words, we had the material, we just didn’t show it.”

It was back to the drawing board for the final time. At this point, BML knew where the gaps were and filled in the shortcomings with proper documentation to fill in the 39 per cent they were missing from their last submission.

With confidence, BML took the plunge and submitted their audit using an IHSA Approved External Associate Auditor and following a thorough review, the company finally achieved an outstanding 90 per cent to receive their certification.

Although it is a three-year certification, BML is required to submit annual desk audits to ensure they are maintaining their health and safety practices, and complying to any new government legislation. Because things are constantly changing, the company is regularly streamlining its processes to ensure their health and safety practices are in line with their business procedures, COR standards, and legislative requirements.

It may have been a long process, but through hard work, determination and sheer will, BML is proof that small to mid-size firms can achieve certifications in keeping with the larger companies.

“I always felt we had a really good health and safety program, but now it’s truly recognized, tested and audited,” Di Novo said. “This was a major hurdle that we overcame. Now, it’s our job to maintain it. We’re an example. If we can do it, and others want to achieve this, it is definitely worth the effort.”