June 23, 2010

Multi-employer job sites have three Cal/OSHA categories of employers—the controlling employer, the creating employer, and the correcting employer. If you're the controlling employer, you have the general supervisory authority, either by contract or actual practice, for safety and health conditions. You also hold the authority to correct Cal/OSHA violations that occur at the worksite.

As a controlling employer, you can take several steps to help preempt health and safety violations. These include:

Need more in-depth information on safety on multi-employer worksites? Join us on July 21 for our in-depth webinar Contractor Safety: How to Keep Contractors Safe and in Compliance at Your Worksite.

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1. Screen the other employers: Past performance is usually a good predictor of future performance. Before other employers' workers set foot on your site, review the employers' safety records. Search publicly available OSHA and Cal/OSHA databases and/or ask the employers to complete a questionnaire about their health and safety record. If you discover they have spotty health and safety histories, you may want to consider increased oversight--or possibly even using another contractor.

2. Be clear on expectations: If you don't clearly communicate the importance of a safe workplace and your expectations for maintaining safe work conditions, your contractors will assume that their safety standards are the same as yours—and their standards may be far lower than yours. To let the other employers know you're serious about safety, start your project with a safety kickoff meeting for all employers and their supervisors. Cover your job-specific safety plan, your expectations for health and safety on the site, and how employers should communicate among themselves and with you when a safety issue arises.

3. Give yourself a bigger hammer: To add force to your safety effort, include language in contracts addressing subcontractors' health and safety responsibilities and the consequences for failing to meet them.

4. Coach your supervisors: Supervisors on multi-employer worksites are often unclear about their level of authority when dealing with other employers, so they may let issues slide. From the start of the project, let your supervisors know what they can—or can't—do when it comes to supervising worksite safety. And let them know who to contact if they have difficulty getting another employer to comply with health and safety rules.

5. Meet and inspect: Because multi-employer worksites are generally very dynamic, regular meetings and inspections are necessary to ensure that any health and safety issues are addressed. If held regularly, job safety meetings need not be long. Fifteen-minute tailgates with the employer leads detailing issues and concerns—including items identified during inspections and proactive discussions about upcoming work and potential issues—will go a long way to ensuring safety at your worksite.

Contractor Safety: How to Keep Contractors Safe and in Compliance at Your Worksite

A federal court recently ruled that Summit Contractors, the general contractor on a college dormitory project, was liable for a hazardous work condition caused by one of its subcontractors. They may not technically be your employees, but if contractors get hurt on your job site—or create a dangerous condition that hurts someone else—it's most definitely your problem.

Contractors are required to follow your safety program and inform you of any hazards that could potentially occur as a result of their work on-site. You also need to make sure that every contract employee knows how to safely perform his/her job and has been trained as required by the Cal/OSHA regulations.

Join us for an in-depth webinar on July 21. You'll learn:

• How Cal/OSHA defines "multiple employers"
• When a general contractor may—and may not—be cited for its subcontractors' safety violations
• The degree to which you should get involved in the management, direction, or control over your contractors' safety programs
• Whether the general contractor and subcontractors need their own Injury and Illness Prevention Plan, or whether yours will cover them while on your property
• How the California Corporate Liability Act affects contracted activities
• How to spot-check and evaluate a contractor's ongoing safety performance, and when to require Safety Work Plans on phased projects
• Who has responsibility for management and disposal of hazardous materials used or left at your site by a contractor

Register now »

Learn more »