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July 25, 2005
Train Contractors? You Should.

You may be responsible for the safety of outside contractors. Generally, when employees of an outside contractor come into your workplace, both your company (what OSHA calls the "host" employer) and their own employer share responsibility for the outside employees' safety. The dividing line between areas of responsibility is not always clear, but you can use this rule of thumb as a starting point: The contractor is responsible for making sure that its employees know how to do their jobs safely, while the host employer is responsible for informing the contractor of any hazardous conditions that are specific to the host's workplace. For example, if your workplace includes hazardous chemicals, the host needs to make sure the outside contractor knows about the hazards.

Know the OSHA standards that refer to outside contractors. The "rule of thumb" mentioned above can apply for any potential hazardous situation involving outside contractors. But be aware, also, that several of OSHA's General Industry standards refer specifically to the host employer's responsibilities. These include:

  • Process Safety Management (29 CFR 1910.119)
  • Hazardous Waste Operations (HAZWOPER) (29 CFR 1910.120)
  • Confined Spaces (29 CFR 1910.146)
  • Lockout/Tagout (29 CFR 1910.147)
  • Hazard Communication (29 CFR 1910.1200)

Note that this list is not necessarily complete, and that there are various construction industry standards (29 CFR 1926) that include rules for outside contractors as well. Note also that different standards impose different requirements on the host employer, so be sure to read them thoroughly.

Why It Matters...

  • OSHA is likely to hold the host employer at least partially responsible in the case of a death or serious injury to a contractor's employee.
  • Demonstrating a comprehensive safety program that includes outside contractors can help defend your company from legal liability if something goes wrong.
  • Ensuring that outside contractors have good safety programs helps protect your own employees from accidents.

Communication and coordination are essential. Regardless of specific OSHA requirements for outside contractors (if any), it is essential for safety managers of both the host employer and the contractor to exchange all relevant information regarding potential hazards and safety procedures. This is for your own company's protection as well the safety of all employees. Here are some tips to keep in mind:

  • Require outside contractors to demonstrate an adequate safety program before they come into your workplace.
  • Review your own safety program with the contractor; identify any differences between the host's and the contractor's programs, and agree on how to bridge any gaps.
  • Arrange for any specific training that the contractor's employees might need, either by requiring the contractor to provide the training or by providing the training directly.
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