🤝 Subcontractor Safety Management Playbook
As the general contractor, you're responsible for safety on the entire worksite — including subcontractor crews. Prequalify subs for safety, orient them properly, and monitor continuously to protect workers and limit liability.
Why This Matters
| Without Sub Safety Management | With Sub Safety Management |
|---|---|
| Multi-employer worksite doctrine — GC can be cited | Documented oversight reduces liability |
| Unqualified subs bring incidents and OSHA attention | Prequalification filters high-risk subs |
| Sub violations become your violations | Monitoring and enforcement show due diligence |
| No defense when sub worker is injured | Documentation proves you enforced safety |
| EMR and insurance impact from sub incidents | Subs with strong safety records protect your rates |
Multi-Employer Worksite
OSHA can cite multiple employers on the same site. As the controlling employer (GC), you have a duty to monitor and enforce safety. "The sub did it" is not a defense if you didn't exercise reasonable oversight.
Roles and Responsibilities
| Role | Responsibilities |
|---|---|
| GC Safety Director | Prequalification criteria, sub orientation content, audit sub compliance, escalate enforcement |
| GC Superintendent | Ensure sub orientation before work, daily safety observations, issue corrective actions |
| GC Project Manager | Contract language for safety, support removal of non-compliant subs |
| Subcontractor Superintendent | Attend orientation, ensure sub crew compliance, submit JHAs, participate in safety meetings |
Pre-Qualification Safety Requirements
Before awarding work, verify:
| Requirement | What to Check |
|---|---|
| EMR | Experience modification rate — below 1.0 preferred, above 1.25 may disqualify |
| TRIR | Total recordable incident rate — compare to industry average (NAICS) |
| Safety program | Written program, designated safety contact, training records |
| Training records | OSHA 10/30, task-specific training, documentation |
| OSHA history | Current citations, outstanding penalties, inspection history |
| Insurance | Workers' comp, general liability — certificates current |
Pre-Qualification Scorecard
| Criteria | Pass | Fail | Conditional |
|---|---|---|---|
| EMR | < 1.0 | > 1.25 | 1.0–1.25 with safety plan |
| TRIR | Below industry avg | Above 2x industry | Between — 90-day review |
| OSHA citations (2 years) | 0 | 3+ serious | 1–2 with abatement |
| Written safety program | Yes | No | In development |
| Safety contact designated | Yes | No | — |
| Training documentation | Current | Missing | Provided within 30 days |
Site Safety Orientation for Sub Crews
Separate from GC employee orientation. Sub crews receive:
| Topic | Content |
|---|---|
| Site-specific hazards | Active excavations, overhead work, traffic, confined spaces |
| Site rules | PPE zones, smoking areas, speed limits, pedestrian paths |
| Emergency procedures | First aid, AED, assembly point, evacuation |
| Reporting | Injuries, near-misses, hazards — who to tell |
| GC expectations | JHA requirements, toolbox talk participation, stop-work authority |
Document attendance. No sub worker starts without orientation.
Safety Meetings App for Sub Orientation
Use the Safety Meetings app for sub crew orientation. Document attendance with digital signatures. Track who has been oriented and when. Pre-built orientation topics ensure consistent delivery. BLDR Pro can link sub orientation records to daily reports and issue tracking for a complete audit trail.
Ongoing Monitoring
| Activity | Frequency | Who |
|---|---|---|
| Daily observations | Daily walk-through | Superintendent |
| Corrective actions | As needed | Superintendent, foreman |
| Formal reviews | Weekly or bi-weekly | Safety Director, Superintendent |
| Sub safety meeting participation | Per schedule | Sub superintendent |
Enforcement Escalation
| Level | Action | Documentation |
|---|---|---|
| 1 | Verbal warning | Note in daily log |
| 2 | Written notice | Email or form; sub superintendent copy |
| 3 | Stop work (specific task) | Written notice; resume when corrected |
| 4 | Removal from site | Written notice; bar re-entry until corrective plan |
| 5 | Contract termination | Per contract; legal review |
Document every step. Escalation is your defense if OSHA or a plaintiff cites lack of control.
Subcontractor Safety Meeting Participation
- Subs attend GC safety meetings (toolbox talks, project safety meetings)
- Subs responsible for trade-specific JHAs
- Subs report near-misses and incidents per GC process
JHA Requirements for Sub Work
Subs must provide JHAs for their high-hazard tasks. GC reviews before work starts. Ensure:
- JHA is site-specific and current
- GC superintendent has reviewed and approved
- All sub workers have been briefed and signed
Documentation for Legal Protection
| Document | Purpose |
|---|---|
| Prequalification records | Proves you screened sub before award |
| Orientation sign-in | Proves you trained sub on site rules |
| Corrective action notices | Proves you enforced safety |
| Meeting minutes | Proves safety was discussed |
| Incident reports | Proves you investigated and took action |
BLDR Pro Integration
Track sub safety performance in BLDR Pro. Log sub safety violations, corrective actions, and closure status. Attach photos and documentation. Create reports for leadership and legal review.
Metrics to Track
| Metric | Target | Frequency |
|---|---|---|
| Sub orientation completion rate | 100% before work | Per sub crew |
| Sub safety violations per month | Declining | Monthly |
| Corrective action closure rate | 100% by due date | Weekly |
| Sub participation in safety meetings | 100% | Per meeting |
Common Mistakes
| Mistake | Problem | Fix |
|---|---|---|
| Awarding to lowest bid without safety check | High-risk sub brings incidents | Prequalify safety before or during bid evaluation |
| One orientation for entire project | New sub workers never oriented | Orient each crew before they start; new workers added to existing crews get orientation |
| Verbal warnings only | No record of enforcement | Document every corrective action in writing |
| Ignoring sub violations | "Not my employee" — OSHA disagrees | Enforce consistently; escalate when needed |
| No JHA review for sub work | Sub work proceeds without GC oversight | Require JHA submission and approval before sub work starts |
Troubleshooting
"Sub refuses to correct a violation"
- Escalate. Written notice first. If no correction, stop work for that sub's task. If still no compliance, removal from site. Document everything.
"Sub's EMR is high but we need them for specialty work"
- Conditional qualification. Require a written safety improvement plan, more frequent monitoring, and possibly a dedicated safety coordinator. Re-evaluate at 90 days.
"Sub workers arrive without orientation"
- Do not allow them to work. Orientation before first day. If sub superintendent didn't coordinate, issue written notice. Repeat offenders escalate.
"We have multiple subs with overlapping work — who's responsible?"
- GC coordinates. Hold coordination meetings. Assign control for shared areas. Document who is responsible for what. GC remains the controlling employer.
Related Resources
| Resource | Link |
|---|---|
| Subcontractor Management Guide | Subcontractor Management |
| Subcontractor Qualification Checklist | Sub Qualification |
| Toolbox Talk Playbook | Daily Toolbox Talk |
| JSA/JHA Playbook | JSA/JHA Process |
| Incident Reporting Playbook | Incident Reporting |