Contractor Safety Management: What Every Site Owner and GC Needs to Know | SafetyRegulatory.com — Workplace Safety Certifications, Training & Careers

Most workplace fatalities on construction and industrial sites don’t involve the owner’s direct employees. They involve contractors. And when a subcontractor worker gets killed, the questions come fast: who was supervising them, who created the hazard, who knew about it and said nothing.

OSHA’s answer to those questions is the multi-employer citation policy. Understanding it changes how you think about contractor safety management entirely.

The OSHA Multi-Employer Citation Policy

OSHA recognizes four distinct employer roles at multi-employer worksites. Any one of them can result in a citation.

The creating employer is the one who caused the hazardous condition. If a subcontractor digs an unprotected trench, they created the hazard regardless of who gets hurt.

The exposing employer is the one whose workers are actually exposed to the hazard. Even if they didn’t create it, they can be cited if they knew about it and didn’t act.

The correcting employer is the one responsible for fixing the hazard. On many sites, that’s a general contractor or construction manager who has the actual authority to call a halt and require correction.

The controlling employer is the one with general supervisory authority over the site. This is where general contractors and owners often get caught. You don’t need to supervise the exposed workers directly. You just need to have the authority to require corrective action and fail to exercise it.

This is what makes contractor safety management a real liability issue, not just a paperwork exercise. You can be cited for another employer’s workers if you knew or should have known about the hazard. The standard for a controlling employer is “reasonable care,” which OSHA defines based on the hazard’s severity, your control over the site, and whether you have the expertise to identify the problem.

For a practical breakdown of how this applies to your site safety programs, see the OSHA 30-hour Construction certification, which covers multi-employer worksite rules in detail.

Contractor Prequalification

Prequalification is the process of screening contractors before you award work. Done right, it filters out the bad actors before they’re standing on your site with a crew.

Third-party platforms do most of the heavy lifting now. ISN, Avetta, and Browz are the major ones. Owners subscribe to these platforms and require contractors to maintain profiles. The platforms verify insurance certificates, track OSHA incident rates, collect written safety programs, and flag contractors whose documentation lapses.

What these systems track comes down to a few core metrics. Your OSHA Recordable Incident Rate (RIR) is the number of OSHA-recordable injuries per 100 full-time employees. Your Days Away, Restricted, or Transferred rate (DART) is a subset of that, counting only the more serious incidents. And then there’s the Experience Modification Rate.

Your safety program documentation also matters. A contractor who can’t produce a written hazard communication program, a fall protection plan, or evidence of competent person training is a red flag regardless of what their numbers say. Numbers can be massaged. Missing documentation is a clear signal.

Experience Modification Rate: The Number That Follows You

EMR is a workers’ compensation insurance metric, but it’s become the standard screening tool for contractor safety prequalification in most industries.

Your EMR compares your actual workers’ compensation claims over the past three years (excluding the most recent policy year) to the expected losses for an employer of your size and type. A 1.0 means you’re exactly average. Below 1.0 means your claims are lower than the industry expects. Above 1.0 means you’ve had more claims than expected.

An EMR of 0.8 reflects a clean safety record and typically earns contractors favorable insurance pricing. An EMR of 1.2 signals worse-than-average performance, and many owners and GCs set 1.0 as a hard cutoff for bidding eligibility. Some require 0.85 or lower for work on high-hazard projects.

EMR is calculated by your insurance carrier using NCCI (National Council on Compensation Insurance) data or state rating bureau data. The inputs are your payroll by job classification and your actual claims experience. A single severe claim, especially a fatality, can spike an EMR for three years. That’s why contractors protect their 300 logs carefully and why claims management matters beyond just insurance cost.

If you’re managing contractor relationships, ask for the current EMR certificate directly from the contractor’s insurance carrier, not just a number the contractor provides. Carriers issue these certificates. They’re not self-reported documents.

What to Require Before a Contractor Sets Foot on Site

Pre-mobilization requirements are your first real control point. Once the contractor’s crew is on site and work is underway, your ability to enforce requirements drops significantly.

At minimum, require before mobilization:

A current written safety program, not a generic template downloaded from the internet. The program should be dated, signed, and name a designated competent person for the scope of work being performed.

Proof of OSHA training for key personnel. For construction work, OSHA 30-hour cards for the foreman and supervisors. For general industry work, 10-hour cards for craft workers minimum.

Current EMR certificate from the insurance carrier, along with certificates of insurance showing general liability and workers’ compensation coverage.

OSHA 300 logs for the past three years. Review them. Look for patterns, not just totals.

Documented competent person designations for any work involving fall protection, excavation, scaffold, or confined space. OSHA requires a competent person for these activities. “We’ll figure it out on site” isn’t acceptable.

Set a deadline. Require all documents at least two weeks before mobilization. This gives you time to review and address gaps, not scramble on day one.

Site Orientation: Make It Site-Specific

A video is not a site orientation. Playing a generic construction safety video and signing a form checks a box but teaches the worker almost nothing useful about your specific site.

A real site orientation covers emergency evacuation routes and muster points for this site. It covers the specific hazards present right now (active excavations, overhead work, energized equipment). It covers your stop-work authority policy and who to call. And it covers site-specific rules that go beyond OSHA minimums, like hard-hat color codes, visitor escort requirements, and prohibited areas.

The person delivering the orientation should be able to answer questions about the actual site. Generic videos can supplement, but they don’t replace a real conversation.

Document every orientation with name, date, contractor company, and the topics covered. You’ll need these records if there’s ever a question about what a worker knew.

Ongoing Oversight During the Work

Pre-mobilization and orientation get contractors started right. Ongoing oversight keeps them there.

Daily safety walks with contractor supervisors are the standard for active construction projects. Not a solo tour by the GC safety manager, but a walk with the sub’s foreman present. When you identify a hazard together, the foreman can’t later claim they weren’t aware. You document the walk, note any corrections required, and set a timeline.

Toolbox talks are another touchpoint. Require contractors to conduct them and submit brief documentation weekly. You don’t need to run them yourself, but you should see the records.

Your stop-work authority policy needs to include GC safety staff explicitly. Your people should be able to halt unsafe work without needing supervisor approval first. And when they use it, document it clearly: what the hazard was, who was notified, what correction was required, and when work resumed.

This kind of documentation also builds the record you’d need if a contractor disputes a citation or a stop-work order.

For a deeper look at the documentation side of site safety programs, the job hazard analysis guide covers how to connect hazard identification to corrective action systematically.

Incident Reporting From Contractors

When a contractor worker gets hurt on your site, the first question is always whose 300 log it goes on.

Under OSHA’s recordkeeping rules, the employer who supervises the worker on a day-to-day basis records the injury. If a subcontractor brings their own crew and their own foreman, and your staff isn’t directing that foreman’s daily work, the injury goes on the subcontractor’s 300 log. Your 300 log doesn’t include it.

But if your staff is actually directing the subcontractor’s workers, telling them specifically what to do and how to do it, those workers may be considered your employees for recordkeeping purposes. The supervision test is what matters.

Regardless of whose log it goes on, you still need to know about contractor injuries quickly. Require contractors to notify your site safety contact within one hour of any recordable incident or near-miss. Require a written incident report within 24 hours. Review those reports. Look for contributing factors that your site controls, your site layout, your scheduling decisions, might have contributed to.

Contractor incidents are data. Use them.

When to Remove a Contractor

Removing a contractor mid-project is expensive and disruptive. That’s exactly why the criteria need to be written down before work starts, not invented in the moment.

Your contractor safety program or your contract terms should define the grounds for removal: three documented violations of the same requirement, a fatality or serious injury with evidence of willful disregard for the safety plan, refusal to correct a hazard after written notice, or operating without required documentation.

With written criteria, removal is an administrative decision, not a confrontation. Without them, it becomes a negotiation every time.

Give contractors a corrective action process before removal. First violation gets a written notice. Second gets a formal corrective action plan with a deadline. Third gets removed from the project and flagged in your prequalification system.

The goal isn’t to be punitive. It’s to protect your workers, your liability, and the project. Contractors who can’t meet your standards are a risk that compounds every day they stay on site.

The One Number That Matters Most

You can review a contractor’s written program, check their training records, and walk their sites. All of that matters.

But EMR is the one number that owners and GCs use to screen contractors before any conversation starts. A contractor with an EMR of 0.78 gets invited to bid. A contractor with a 1.35 often doesn’t. That number represents three years of real claims history, and it’s harder to fake than a polished safety manual.

If you’re managing a contractor program, track EMR for every contractor you use regularly. If you’re a contractor, know your EMR, know what’s driving it, and have a plan to move it down. It’s the number that costs you work before you even submit a proposal.

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