Under OSHA's PSM contractor element, the host employer, not just the contract employer, bears direct obligations. Before work begins, the host must inform the contractor of known hazards, explain emergency action plan requirements, and develop and implement safe work practices for contractor employees. The host is also responsible for evaluating the contractor's safety performance and maintaining an injury and illness log for contractors in the process area. These letters define the scope of host employer duties, the limits of those duties, and how responsibility is allocated when contractor and host obligations overlap.
What OSHA Has Said
⚡ Key Compliance Takeaway
As host employer, you cannot outsource your contractor element obligations. You must communicate process hazards in writing before work begins, document contractor performance evaluations, and maintain your own injury and illness log for contractors in the process area.