17 Feb Multi-Employer Worksite Safety

Multi-Employer Worksite Safety

Multi-employer worksite safety requires all employers working at the same location to understand their responsibilities, communicate hazards, and coordinate their work to protect employees. Construction projects commonly involve general contractors, subcontractors, specialty contractors, and other employers whose activities may affect one another.

An employer’s responsibility does not necessarily end with its own employees. Depending on its role and authority at the worksite, an employer may have responsibilities for hazards it creates, hazards to which its employees are exposed, or hazards it has authority or responsibility to correct.

OSHA Multi-Employer Categories

Under OSHA’s Multi-Employer Citation Policy, an employer may fall into one or more of four categories:

• Creating Employer: The employer that caused a hazardous condition that violates an OSHA standard.
• Exposing Employer: An employer whose employees are exposed to the hazardous condition.
• Correcting Employer: An employer responsible for correcting the hazardous condition.
• Controlling Employer: An employer with general supervisory authority over the worksite, including the authority to require other employers to correct safety and health violations.

A single employer may fall into more than one category for the same hazardous condition.

Responsibilities of All Employers

Every employer should actively participate in maintaining a safe multi-employer worksite.

• Identify hazards associated with its work before operations begin.
• Inform affected employers of hazards created by its operations.
• Protect its employees from hazards created by other contractors.
• Follow site-specific safety requirements and applicable OSHA standards.
• Coordinate work that could affect employees of another employer.
• Correct hazards within its authority and promptly report hazards it cannot correct.
• Ensure employees receive appropriate training and understand site-specific hazards.
• Participate in required safety meetings, inspections, and pre-task planning.

Employees should never assume another contractor is responsible for addressing a hazardous condition.

Controlling Employer Responsibilities

A controlling employer must exercise reasonable care to prevent and detect safety and health violations on the worksite. The extent of the controlling employer’s obligations depends on factors such as the nature of the work, the hazards involved, its knowledge of other employers’ safety performance, and the amount of authority it possesses.

Reasonable oversight may include:

• Conducting periodic worksite inspections.
• Coordinating contractor and subcontractor activities.
• Communicating site safety requirements.
• Identifying and communicating changing worksite conditions.
• Requiring responsible contractors to correct identified hazards.
• Following up to verify corrective actions have been completed.
• Taking appropriate action when contractors repeatedly disregard safety requirements.

A controlling employer is not necessarily required to inspect another employer’s work with the same frequency or level of detail that the employer would inspect its own operations.

Planning and Coordination

Safety coordination should begin before work starts and continue as conditions change.

Before each project or significant phase of work:

• Identify site-specific hazards and necessary controls.
• Determine which employer is responsible for implementing each control.
• Establish emergency procedures and communication methods.
• Coordinate simultaneous operations that could create hazards for other contractors.
• Discuss access, fall protection, electrical hazards, equipment movement, excavations, hot work, hazardous materials, and other applicable hazards.
• Establish procedures for reporting and correcting unsafe conditions.
• Communicate changes that could affect other employers or their employees.

Pre-task planning and coordination meetings are especially important when one contractor’s activities can create hazards for another contractor.

When a Hazard Is Identified

Do not ignore a hazardous condition because another employer created it.

If a hazard is discovered:

1. Warn affected employees and employers.
2. Protect employees from exposure.
3. Correct the condition when authorized and qualified to do so.
4. Notify the employer responsible for correction when the hazard is outside your authority.
5. Follow up as appropriate to ensure the hazard has been addressed.
6. Stop or restrict affected work when necessary to prevent employee exposure.

An exposing employer that did not create or control a hazard may still have responsibilities to protect its employees.

Communication Is Critical

Conditions can change rapidly on a multi-employer worksite. Employers should communicate changes involving equipment movement, energized systems, excavations, overhead work, hazardous materials, restricted areas, shutdowns, and other conditions that could affect workers.

Employees should know:

• Who is supervising their work.
• How to report hazards.
• What site-specific rules apply.
• Which areas are restricted.
• What to do when another contractor creates a hazard.
• When to stop work and contact a supervisor.

Remember

Multi-employer worksite safety is a coordinated effort. Creating, exposing, correcting, and controlling employers may have different responsibilities, but each must take appropriate action within its role and authority to prevent employee exposure to workplace hazards.