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Course 833 - Developing a Construction Safety Management System

Safety guides and audits to make your job as a safety professional easier

Managing Subcontractors

One of the greatest challenges the general or prime contractor has is managing the work that is being conducted by one or more subcontractors on a project. Change is continual on the worksite and subcontractors routinely create hazardous conditions, and unless all employees of other contractors are continually aware, they may get seriously injured or killed by a hazard that didn't exist just moments ago. Consequently, one of the greatest hazards in any construction project is the lack of subcontractor awareness of what’s going on around them.

The Project Safety Plan

Both the Project Manager and Project Safety Representative/Manager have the responsibility to take reasonable care to recognize and control all worksite hazards and to make sure subcontractors comply with all safety and health requirements. To do that, a specific project safety plan needs to be written.

A well-designed project safety plan will include most or all of the following subjects:

Safety Management System

  • Contractor Prequalification
  • Contractor Safety Representatives
  • Monthly Safety Reports
  • Communication
  • Communication
  • Job Safety
  • Plan Overview

Project-Specific Safety Plan

  • Accountability Plan
  • Audits/Inspections
  • Cell Phone Usage
  • Confined Space Entry
  • Crane Safety and Rigging
  • Electric - Temporary
  • Emergency Action/Response Plan
  • Hazard Communication
  • Equipment Safety
  • Fall Protection
  • Fire Prevention and Protection
  • Housekeeping
  • Job Hazard Analysis (JHA)
  • Job Safety Analysis Form
  • Hot Work Permit
  • Personal Protective Equipment (PPE)
  • Potentially hazardous exhaust systems
  • Protection of the Public/Visitors
  • Recordkeeping and Incident Reporting
  • Rooftop Access
  • Smoking
  • Substance Abuse Policy
  • Temporary Elevators
  • Utility Tunnel Safety
  • Incident/Accident Reports

General Contractor Responsibilities

The general contractor should take the following actions to help ensure subcontractor safety on the worksite:

  • Prior to the start of work on the project, obtain and review site-specific subcontractor safety plans and training records to make sure needed programs are included.
  • Ensure coordination and cooperation of subcontractors regarding information and worksite safety and health activities, such as safety training and meetings
  • Make sure there is appropriate safety and health communication processes between and among all contractors on the project.
  • Require that all subcontractors conduct regular safety and health training and toolbox/tailgate meetings.
  • Ensure adequate procedures are in place for non-injury incident and injury accident reporting.
  • Develop measures for safety and health and document performance through written reports, audits, and safety inspections.
  • Control visitor access to the project.

Steps for Managing Subcontractors

The contractor is responsible to prequalify all subcontractors/trade contractors engaged on a project per their own written prequalification process. Managing subcontractors on the worksite involve these steps for the General Contractor:

  • Make sure you require bid documents include subcontractor injury and illness records for the past three years (if the subcontractor has them), and copies of their written safety and health program, including training.
  • Establish the criteria for safety and health performance required of potential bidders.
  • Select subcontractors who can show they are competent to do the job safely and can demonstrate a history of doing so with a workers' compensation rate at or below 1.0.
  • Require subcontractors to develop and implement their own effective CSMS.
  • Give selected subcontractors a copy of your worksite safety plan and have them sign an agreement that they intend to comply with all requirements. Get a copy of the subcontractor's safety plan as well.
  • Only allow subcontractors on site who have completed safety orientation and training.
  • Monitor subcontractor safety performance on the worksite to make sure they are complying with safety rules and policies and using safe work procedures and practices.

As part of the subcontractor bid process, you will want to ask subcontractors for documentation of the following:

  • experience modification rate (called a "Mod Rate" or EMR) for the past three years (should be 1.0 or less)
  • OSHA Recordable Incident Rate, DART incidents and near misses for the past three years
  • OSHA inspection results for the past three years, if available
  • incident/accident analysis and investigation procedures
  • participation by management and supervisors
  • supervisors' safety meetings and toolbox safety meetings
  • written safety and health plan
  • employee orientation and training

Safety Representatives

Prior to the start of a project, a designated project safety representative/manager should be appointed and required to be on site at all times while work is being performed.

Safety Representative: General and subcontractor designated project safety representatives should have completed and documented at least a 30-Hour OSHA Construction Safety Course and have current CPR/First Aid Training. The project safety representative may also concurrently function as a superintendent, foreman or crew leader on the Project.

Safety Manager/Officer: A dedicated, full-time safety manager should be assigned on large or high-risk projects. If a safety manager is required by contract, he or she should not have any other duties. Safety managers should have earned professional credentials (CSP, CIH, CSHM, etc.), completed an OSHA 30-Hour Construction Safety Course or equivalent, and have additional training and experience necessary to understand the management of a project CSMS.

Safety Representative/Manager Duties

During the construction phase it will be important for safety representatives to do the following:

  • Conduct regular scheduled and random worksite safety inspections and incident/accident investigations as needed.
  • Identify the impact of changes on the worksite in safety and health of workers involved in the project.
  • Provide sufficient information on health and safety on the worksite to supervisors and those who will train workers on safety, so they can conduct the necessary training if needed.
  • Cooperate and coordinate safety and health with subcontractors and others throughout each phase of the project.
  • Provide advice and information regarding the general contractor's health and safety plan to everyone involved with the project.
  • Make sure the general contractor and all subcontractors continue to carry out their duties and responsibilities to regularly submit activity reports and hold worksite safety meeting.

Subcontractor Responsibilities

All subcontractors should make sure the following is completed during the project:

  • Develop a site-specific written safety and health plan for your particular work activity.
  • Identify the hazards of the work you will be doing on the worksite and determine the risks they pose to your employees and other subcontractors, and how these risks will be controlled.
  • Maintain written documentation of the training and competence of all employees involved in the project.
  • Keep the general contractor informed of all hazardous conditions, non-injury incidents and injury accidents that occur on the worksite.

Correcting Hazards Created by Subcontractors

  • Establish and communicate the requirement for and methods that subcontractors can use to promptly correct hazards involving their work activities.
  • Make sure subcontractors understand the hazards on the specific worksite, and the hazard other subcontractors may create during the workday. One of the most common reasons for injuries by one subcontractor is the lack of awareness of hazards created by other subcontractors.
  • Work with subcontractor to use methods to ensure that hazards are identified, analyzed, corrected, and tracked in subcontractor's work areas.
  • Make sure subcontractors have a person assigned responsibility for managing their safety and health program on site.
  • Ensure subcontractors effectively implement systems to identify and correct hazards in their work areas and include responsibility for hazard correction in writing.

Multi-Employer Worksites

Most large construction projects are actually multi-employer worksites composed of the general or prime contractor and a number of subcontractors. It's important to understand the safety responsibilities of each employer category as more than one employer may be citable by OSHA for violations. Employers may perform one or more roles on a project.

Multi-Employer Categories

The four employer roles or categories on multi-employer worksites are:

  1. Creating employer: The employer that caused a hazardous condition that violates an OSHA standard.
  2. Exposing employer: This is an employer whose own employees are exposed to the hazard.
  3. Correcting employer: This is an employer who is engaged in a common undertaking, on the same worksite as the exposing employer, and is responsible for correcting a hazard. This usually occurs where an employer is given the responsibility of installing and/or maintaining particular safety/health equipment or devices.
  4. Controlling employer: This is an employer who has general supervisory authority over the worksite, including the power to correct safety and health violations itself or require others to correct them. Control can be established by contract or, in the absence of explicit contractual provisions, by the exercise of control in practice.

Multiple Roles

As mentioned above, an employer on a multi-employer worksite may, in fact, play a number of roles throughout the project. For instance, an exposing employer may also perform the role of a correcting employer.

For a more complete discussion of these categories, reference OSHA CPL 02-00-124, X. Multi-employer worksites.

Reasonable Care

It's important for everyone on a project to understand the concept of "Reasonable Care." According to OSHA, reasonable care may be established by meeting the following criteria on multi-employer worksites:

  1. The controlling employer should have adequate knowledge of the hazards or violations of the creating or exposing employer.
  2. There should be evidence of an effective safety and health program in place for the project.
  3. There should be a system in place for identifying and correcting hazards for the project.
  4. There should be documentation of regular jobsite safety meetings and or safety training.
  5. If creating or exposing employers have a previous history of similar violations, documented steps should have been taken to identify and correct these situations.


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Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the module content, but only focuses on key concepts and ideas.

Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you do not answer all the questions, you will receive an error message.

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1. What is one of the greatest hazards on any construction project?

2. The _____ must take reasonable care to recognize and control all worksite hazards and to make sure subcontractors comply with all safety and health requirements.

3. Select subcontractors who can show they are competent to do the job safely and can demonstrate a history of doing so with a workers' compensation rate _____.

4. A dedicated, full-time _____ should be assigned on large or high-risk projects. If a safety manager is required by contract, he or she should not have any other duties.

5. On a multi-employer project, the employer that caused a hazardous condition that violates an OSHA standard is called the _____.

Have a safe day!

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