OSHA’s multi-employer worksite policy defines when employers other than the direct employer of an injured worker can be cited for OSHA violations. The policy identifies four employer roles: creating employer (created the hazard), exposing employer (their employees were exposed to the hazard), correcting employer (responsible for correcting the hazard), and controlling employer (has overall responsibility for conditions on the worksite). General contractors typically function as controlling employers — they have the authority and ability to correct hazards even those created by subcontractors. A GC can be cited as a controlling employer when: they had the authority to require safety measures, they knew or should have known of the hazard through a reasonable inspection program, and they failed to exercise their authority to address the hazard. Documenting GC safety oversight activities — inspection frequency, corrective actions issued to subcontractors, safety orientation requirements — demonstrates the reasonable inspection program that controlling employer defense requires.

OSHA’s controlling employer guidance suggests that inspection frequency should be calibrated to the hazard level of the work — more frequent inspection for high-hazard operations (work at heights, confined space entry, energized electrical work) and less frequent for lower-hazard operations. A practical framework: daily walkthrough inspection of all active work areas during the project’s high-risk phases, with documented findings; weekly comprehensive site safety inspection with written report; immediate inspection following any near-miss or incident report. The inspection documentation must be more thorough than a general presence on the site — it should identify specific conditions observed, corrective actions required of specific subcontractors, and verification that required corrections were made. This documented inspection program is the primary evidence that the GC exercised the reasonable oversight that controlling employer defense requires.

Before any subcontractor begins work on a GC-managed project, collect and document: current workers’ compensation insurance certificate with the GC named as additional insured, current general liability insurance certificate naming the GC as additional insured, a copy of the subcontractor’s written safety program, the subcontractor’s OSHA 300 logs for the past three years (or equivalent), current EMR documentation from the subcontractor’s workers’ comp carrier, OSHA 10 or 30-hour training certifications for subcontractor supervisors, any required trade-specific certifications (confined space, fall protection competent person, rigging certification), and the subcontractor’s specific safety plan for the work to be performed on this project. Many GCs also require subcontractors to report all incidents on the GC-managed project through the GC’s IncidentVault implementation — creating the GC’s own project-level safety record independent of the subcontractor’s internal reporting.

Construction safety prequalification portals (ISNetworld, Avetta, Browz, project-owner systems) require contractors to submit TRIR, DART rate, EMR, and total recordable incident counts for recent calendar years. IncidentVault’s analytics generate these metrics directly from incident records — providing current-year and multi-year safety statistics without a manual calculation project. For prequalification systems that require safety program documentation, IncidentVault provides exportable reports demonstrating: incident management system deployment across all projects, investigation completion rates for reported incidents, corrective action completion rates, and near-miss capture program volume — the qualitative safety program evidence that goes beyond raw statistics in competitive prequalification processes.