Contractors play a vital role in process facilities, performing maintenance, turnarounds, construction, and specialized services. However, contract employees often lack the site-specific knowledge that regular employees develop over time, making them particularly vulnerable to process hazards. Under 29 CFR 1910.119(h), both the host employer and the contract employer have specific obligations to ensure contractor safety on covered processes. Ecesis PSM software provides contractor management tools to evaluate, train, and track contract employees working in your facility.
What OSHA Requires
29 CFR 1910.119(h) establishes requirements for both the host employer and the contract employer:
Host employer responsibilities:
- Obtain and evaluate the contract employer's safety performance and programs when selecting contractors
- Inform contract employers of known fire, explosion, or toxic release hazards related to the contractor's work and the process
- Explain the applicable provisions of the emergency action plan
- Develop and implement safe work practices to control the entrance, presence, and exit of contract employers and employees in covered process areas
- Periodically evaluate the contract employer's fulfillment of their PSM obligations
- Maintain a contract employee injury and illness log for work in process areas
Contract employer responsibilities:
- Assure each contract employee is trained in safe work practices needed to perform the job and understands the known hazards
- Assure each contract employee is instructed in the known fire, explosion, or toxic release hazards related to the job and process
- Document that each contract employee has received and understood the required training
- Assure each contract employee follows the safety rules of the facility
- Advise the host employer of any unique hazards presented by the contract employer's work
Step-by-Step Implementation
Develop Contractor Qualification and Selection Criteria
Before hiring contractors for work on covered processes, establish written criteria for evaluating their safety programs. Your evaluation should consider:
- Contractor's OSHA recordable injury and illness rates (EMR, TRIR, DART)
- Written safety programs relevant to the work being performed
- Employee training and certification documentation
- Previous experience with similar process safety work
- History of OSHA citations or serious incidents
- Insurance coverage and safety compliance documentation
Document the evaluation results and retain them as part of your PSM records.
Develop Site-Specific Orientation and Training
Create a standardized contractor orientation that covers your facility's specific hazards and safety requirements:
- Known fire, explosion, and toxic release hazards in the areas where contract work will occur
- Your facility's emergency action plan including alarm systems, evacuation routes, assembly points, and shelter-in-place procedures
- Safe work practices and permit requirements (hot work, confined space, lockout/tagout, line breaking)
- Restricted areas and access control procedures
- Incident and hazard reporting procedures for contract employees
- PPE requirements for specific areas
Document completion of orientation with contractor employee signatures and comprehension verification.
Implement Access Control and Work Oversight
Develop procedures to control contractor presence in covered process areas:
- Define sign-in/sign-out procedures to track contractor personnel on site
- Require work permits for activities with process safety implications
- Assign a host employer representative to oversee contractor activities in process areas
- Conduct periodic walkthroughs to verify contractors are following safe work practices and permit requirements
- Establish clear communication channels between contractor supervisors and host employer operations personnel
Track Contractor Incidents and Evaluate Performance
Maintain ongoing oversight of contractor safety performance:
- Keep a separate injury and illness log for contract employees working in process areas
- Include contractor incidents in your incident investigation program when they involve covered processes
- Conduct periodic evaluations of each contract employer's fulfillment of their PSM obligations
- Document evaluation results and use them in future contractor selection decisions
- Require contract employers to report any unique hazards introduced by their work methods or materials
Common Pitfalls to Avoid
How Software Supports This Element
Ecesis PSM software streamlines contractor management for PSM compliance:
- Contractor management: Evaluate, qualify, and track contractor safety performance with documented selection criteria and periodic performance reviews
- Training delivery: Deliver site-specific orientation and safety training to contract employees with documented comprehension verification
- Incident tracking: Track contractor injuries and incidents separately while integrating with your overall incident investigation program
- Mobile app: Provide contractors with mobile access to safety procedures, emergency plans, and hazard reporting tools
Frequently Asked Questions
Are all contractors subject to PSM requirements?
The contractor provisions apply to contractors performing maintenance, repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. Contractors providing incidental services not directly related to process operations (such as janitorial or landscaping) are generally not covered.
Who is responsible for training contract employees?
Both parties share responsibility. The host employer must inform the contract employer of process hazards and emergency procedures. The contract employer must ensure their employees are trained in safe work practices and understand the known hazards. Documentation of training completion is the contract employer's responsibility.
How often should contractor performance be evaluated?
OSHA requires periodic evaluation but does not specify frequency. Best practice is to evaluate ongoing contractor performance during and after each work engagement, with formal reviews at least annually for long-term contractors.
Do contract employees need access to PHAs?
Contract employees do not automatically receive PHA access under the contractor element, but they must be informed of known process hazards relevant to their work. If contractors participate in PHA teams or incident investigations, they would need appropriate information access under the employee participation and trade secrets provisions.
What goes in the contractor injury and illness log?
The log must record injuries and illnesses of contract employees working in process areas, similar to the OSHA 300 log format. This log is maintained by the host employer and should be available for OSHA inspection.
Ecesis PSM Compliance Software
PSM Software
Centralized platform to manage all 14 PSM compliance elements
Management of Change
Submit, route, and approve change requests through defined workflows
Incident Investigation
Report, investigate, and track corrective actions to completion
Training Management
Deliver and track PSM training with comprehension verification
Mechanical Integrity
Schedule inspections, track deficiencies, and manage maintenance
PSM Compliance Calendar
Track deadlines across all 14 elements automatically
