Before contracting for work in or adjacent to a PSM-covered process, the host employer must evaluate the contractor's safety performance and programs. This is a pre-qualification obligation, not a box to check at contract renewal. OSHA has addressed what the evaluation must cover, what documentation is required, and whether a contractor's OSHA recordable rate alone is sufficient. These letters also address the scenario where a preferred contractor has a poor safety record: the host cannot simply assume the contractor will perform better on your site.
What OSHA Has Said
Jun 29, 1994
Pre-Contract Safety Evaluation and What Must Be Assessed
OSHA addresses the scope of the pre-contract safety evaluation. The host must review the contractor's safety programs, training records, and injury and illness history, not simply obtain a certificate of insurance.
Read OSHA Letter ↗
Feb 16, 2022
Contractor Qualification Documentation and Record Retention
OSHA confirms that contractor safety evaluation records must be retained and made available for inspection. A verbal evaluation or an undocumented phone call does not satisfy the requirement.
Read OSHA Letter ↗
Mar 16, 2005
OSHA Recordable Rate as a Sole Evaluation Criterion
OSHA addresses whether a low OSHA recordable rate is sufficient basis for contractor qualification. OSHA position: recordable rates are one data point, not a complete evaluation. Program documentation and training verification are also required.
Read OSHA Letter ↗
⚡ Key Compliance Takeaway
Contractor evaluation is a pre-selection requirement, not an afterthought. Document your evaluation criteria, collect safety program and training documentation, and retain the records. A low TRIR alone is not adequate justification for contractor qualification under PSM.