Contractor compliance
Why OSHA can cite you for your contractor's violation
A common assumption is that a contractor's safety is the contractor's problem. OSHA's multi-employer citation policy says otherwise: the employer who controls the site can be cited when someone else's employee is exposed to a hazard. That changes what you need at the gate.
OSHA's directive CPL 02-00-124 sets out how citations work when more than one employer is present. It identifies roles: the creating employer, the exposing employer, the correcting employer, and the controlling employer. More than one can be cited for the same condition.
What controlling employer means
If you have general supervisory authority over the site, including the power to correct hazards or require others to correct them, you are likely the controlling employer. That is the position most facility owners and main contractors are in, whether or not they think of themselves that way.
The test applied is reasonable care. A controlling employer is not expected to supervise a specialist contractor as closely as it supervises its own staff, but it is expected to have taken reasonable steps: knowing who is on site, what they are doing, whether they are qualified for it, and acting when something is visibly wrong.
What reasonable care looks like in records
- You know who is on site. An accurate, current list of contractor personnel is the baseline. If you cannot say who was on your site on a given afternoon, nothing further is provable.
- You know what they were qualified to do. Training and certification records with dates, held before entry rather than requested after an incident.
- You inducted them. Site-specific orientation covering your hazards, with a record that the individual received it and when.
- You acted on what you found. Evidence that expired credentials or failed checks actually stopped someone entering, not just that the system flagged them.
The PSM angle, if you run covered processes
For facilities under process safety management, OSHA 1910.119(h) goes further than general duty. The host employer must inform contractors of fire, explosion and toxic release hazards, explain the emergency action plan, periodically evaluate contractor performance, and maintain a contract employee injury and illness log for work in process areas. The contract employer must document each employee's training, including identity, date, and how comprehension was verified. That is a records obligation many sites discover late.
Why the gate is the control point
Every duty above is easier to evidence if the check happens at entry. A credential verified at the point of access produces a timestamped record tied to a person and a site. The same credential filed in a folder proves only that a document existed somewhere.
Where BeckonDesk fits
BeckonDesk holds contractor companies and their people, with certification and insurance expiry dates on the record, and puts the check at sign-in. Inductions and site rules are presented at the kiosk and stored against the visit, so the induction record has a person, a date and a version attached to it.
Related reading
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