Host Employer Responsibilities for Contract Workers — OSHA Letters of Interpretation

A host employer can deliver the hazard and emergency-plan training required by (h)(3)(ii) and prepare the records, but the contract employer must make sure that training and documentation are adequate, including how understanding was verified, keep the records (employee identity, training date, and means used to verify understanding), train new employees before they work, and still provide job-skills training under (h)(3)(i). The contract employer also remains responsible under (h)(3)(iv) for making sure its people follow the facility's safety rules.

OSHA said the safe work practices required by (f)(4) must control entry into a facility by maintenance, contractor, laboratory, and other support personnel, including supervisors and people only planning future work, so operators know who is in their area and everyone can be accounted for in an emergency. Under (h)(2)(iv), the host must also control the entrance, presence, and exit of contractors. OSHA enforces the procedure the employer writes, and recommends one consistent entry practice for all groups.

In a letter about ammonia refrigeration maintenance, OSHA described responsibility for contractor safety as shared: the host creates and controls the hazards and has primary responsibility, while the contractor trains its own people. Under PSM, the host must give the contract employer process information and periodically evaluate how the contractor is meeting its training duties. For managers without PSM experience, OSHA suggested training, an outside consultant, or a designated manager, and pointed to its compliance directive.