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
- Job Safety
- Project-Specific Safety Plan Overview
PROJECT-SPECIFIC SAFETY PLAN
- Accountability Plan
- 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
- Job Hazard Analysis (JHA)
- Personal Protective Equipment (PPE)
- Potentially hazardous exhaust systems
- Protection of the Public/Visitors
- Recordkeeping and Incident Reporting
- Rooftop Access
- Substance Abuse Policy
- Temporary Elevators
- Utility Tunnel Safety
- Near Miss/Incident/Accident Reports
- Safety Plan Certification Form
- Job Safety Analysis Form
- Hot Work Permit
OSHA Challenge: Equal S&H Protection
Stage 1: Develop and begin implementing a plan for how subcontractors will provide their employees with equal S&H protection.
Stage 2: Work with subcontractor to improve and continue implementing subcontractor program.
Stage 3: Work with subcontractor to improve and continue implementing subcontractor program.
OSHA Challenge: Adherence to Rules
Stage 1: Require subcontractors and their employees to comply with OSHA and company S&H rules. Inform all subcontractor employees of this requirement before work begins.
Stage 2: Develop a system to handle S&H violations of subcontractor employees working on-site.
Stage 3: Improve and continue to enforce company policy for S&H violations.
Steps for Managing Subcontractors
Managing subcontractors on the worksite involve these steps for the General Contractor:
- 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.
- Give 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.
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.
Subcontractor management is a collaborative team effort throughout all phases of the project. Be sure to establish requirements pertaining to subcontractor safety. The contractor is responsible to prequalify all subcontractors/trade contractors engaged on a project per their own written prequalification process.
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 an authorized 30-Hour OSHA Construction Safety Course and have current CPR/First Aid Training from a nationally recognized program. The project safety representative may also function as a superintendent, foreman or crew leader on the Project.
Safety Manager: 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.) or completed the OSHA 30-Hour Construction Safety Course plus have additional training and experience necessary to understand the management of a project CSMS.
- 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.
- Encourage subcontractors to develop and implement their own effective CSMS.
As part of the subcontractor bid process, you will want to ask subcontractors for documentation of the following:
- The experience modification rate (called a “Mod Rate” or EMR) for the past three years. It should be 1.0 or less.
- The 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
OSHA Challenge: Subcontractor Selection
Stage 1: Require in bid documents to include subcontractor injury and illness records for past three years (if available), and copies of their written S&H program. Consider the above information in when selecting subcontractors for work.
Stage 2: Implement policy and process for addressing S&H performance of potential bidders.
Stage 3: Continue to encourage and reinforce the importance for subcontractors to develop and implement good effective S&H management systems.
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.
OSHA Challenge: Subcontractor Selection
Stage 1: Establish a requirement that subcontractors promptly correct hazards involving their work activities.
Stage 2: Formalize and begin implementing methods to ensure that hazards are identified, corrected, & tracked in subcontractors’ work areas including assignment of responsibility.
Stage 3: Ensure subcontractors effectively implement systems to identify and correct hazards in their work areas and include responsibility for hazard correction in writing.
OSHA Challenge: Removal Policy
Stage 1: No action required.
Stage 2: Establish and communicate a formal policy on subcontractor S&H violations, including removal and possible financial penalties. Include policy in the company contract requirements.
Stage 3: Hold subcontractors responsible for correcting hazards created by their work and ensure any penalty policies are understood by all subcontractors and tier contractors described in their contracts.
Project Safety Representatives and Managers
During the construction phase it will be important to do the following:
- Continue to identify the impact of changes on the worksite in safety and health of workers involved in the project.
- Continue to 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 the 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 other the general contractor and all subcontractors continue to carry out their duties and responsibilities to regularly submit activity reports and hold worksite safety meeting.
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.
The four employer roles or categories on multi-employer worksites are:
Creating employer: The employer that caused a hazardous condition that violates an OSHA standard.
Exposing employer: This is an employer whose own employees are exposed to the hazard. See Chapter III, section (C)(1)(b) for a discussion of what constitutes exposure.
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.
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.
For a more complete discussion of these categories, reference OSHA CPL 02-00-124, X. Multi-employer worksites.
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.
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:
- The controlling employer should have adequate knowledge of the hazards or violations of the creating or exposing employer.
- There should be evidence of an effective safety and health program in place for the project.
- There should be a system in place for identifying and correcting hazards for the project.
- There should be documentation of regular jobsite safety meetings and or safety training.
- 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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