Summary
In short
- Reasonable care as a controlling employer is evidenced by inspecting the work, correcting what is found, and enforcing compliance. None of it is evidenced by an approval file.
- Inspection frequency should follow the risk of the work, not the length of the contract. High-risk activity warrants attention while it is happening rather than a visit at the end.
- Look at work practice rather than paperwork. Whether the permit was issued matters less than whether the isolation described in it is actually applied.
- Record what was found and what happened to it. An inspection that identifies deficiencies with no correction trail evidences knowledge rather than care.
- Escalation needs a defined route, including the authority to stop the work, and the person inspecting needs to hold it or be able to reach someone who does.
- Repeated findings against the same contractor are a procurement matter, and they rarely reach anyone who makes engagement decisions.
What it is
What it is
What is a contractor site inspection?
Observation of contractor work in progress by the site, checking work practice, equipment and protective measures against what was agreed, recording deficiencies and escalating where required. It is distinct from the contractor's own supervision and from the approval process.
Why does the site inspect a contractor's work?
Because under multi-employer principles a controlling employer with general supervisory authority can be liable for hazards affecting another employer's workers, and the defence turns on whether it exercised reasonable care. That is assessed by periodic inspection, an effective system for correcting hazards, and enforcement.
When to use it
When to use it, and when not to
This observes contractor work in progress. Approval and permitting sit before it.
Use it for
- Observing contractor work in progress, at a frequency set by the risk
- Verifying that permitted conditions are actually being applied
- Checking equipment, protective measures and competence in practice
- Recording deficiencies with correction and verification
- Escalating where work should be stopped or conditions have changed
Not for
- Contractor approval and onboarding, which precede the work
- The permit to work, which authorises the activity and sets conditions
- The contractor's own supervision and quality control
- Incident investigation, where something has already happened
- Contract performance management, which addresses commercial delivery
Standards
What it is built against
Contractor oversight sits under coordination duties and multi-employer liability principles.
| Clause | Requirement | Where it lands |
|---|---|---|
| OSHA CPL 02-00-124 | Controlling employer reasonable care assessed by periodic inspections, correction system and enforcement | Header |
| ISO 45001 cl.8.1.4.2 | Coordination with contractors to identify hazards and control risks arising from their activities | Work practice |
| ISO 45001 cl.8.1.4.3 | Control of outsourced functions and processes, consistent with the management system | Result |
| 29 CFR 1910.119(h)(2)(iv) | Periodic evaluation of contractor performance where process safety management applies | Escalation |
| ISO 45001 cl.5.4 | Consultation and participation, including workers of contractors where applicable | Work practice |
| ISO 45001 cl.10.2 | Corrective action arising from deficiencies identified | Observed deficiencies |
| CDM Regulations 2015 | Client duties to ensure arrangements are suitable and maintained for construction work (GB) | Header |
| ISO 45001 cl.9.1 | Monitoring and measurement, including contractor safety performance | Result |
What it does not cover
- Contractor approval and onboarding, which precede the work.
- The permit to work, authorising the activity and setting conditions.
- The contractor's own supervision, which does not substitute for the site's oversight.
- Incident investigation, where something has already occurred.
- Commercial performance management, addressing delivery rather than risk.
Filling it in
Filling it in well
Go where the work is, look at practice, and close what you find.
A week of confined space entry warrants attention while it is happening. A six-month cleaning contract at low risk does not need the same intensity. Frequency driven by contract value or duration produces oversight concentrated where the money is rather than where the hazard is.
Where a permit specifies isolation, edge protection, gas testing or an attendant, check that those things are physically in place. The permit is a statement of intent issued before the work; the inspection is the only occasion anyone verifies that intent survived contact with the job.
An inspection identifying deficiencies with no record of what happened next evidences that the site knew about a hazard, which is a worse position than not having looked. The correction trail is what converts an observation into evidence of care, and it is the second of the three questions.
The person inspecting needs the authority to stop unsafe work, or immediate access to someone who has it. Where escalation means raising it with the contractor's supervisor and hoping, the inspection cannot correct anything and the third question, enforcement, has no answer.
Audit findings
Common audit findings
Findings here concern whether the oversight was real and what followed.
| Finding | Clause | What fixes it |
|---|---|---|
| Inspection reviews documentation rather than observing the work. | OSHA CPL 02-00-124 | Reasonable care is evidenced by looking at the work in progress. |
| No periodic inspection of contractor work at all. | OSHA CPL 02-00-124 | The first of the three controlling employer questions has no answer. |
| Deficiencies recorded with no correction trail. | ISO 45001 cl.10.2 | Knowing about a hazard without correcting it is a worse position than not looking. |
| Inspector has no authority to stop work and no immediate escalation route. | ISO 45001 cl.8.1.4.2 | Without it the inspection cannot correct anything. |
| Frequency driven by contract value rather than risk. | ISO 45001 cl.8.1.4.2 | Attention should follow hazard, not spend. |
| Repeated findings against a contractor not reaching procurement. | ISO 45001 cl.9.1 | Performance should affect engagement; otherwise nothing changes. |
| Permitted conditions not verified in practice. | ISO 45001 cl.8.1.4.2 | The permit states intent; the inspection is where intent is tested. |
| Contractor incidents and near misses excluded from site reporting. | ISO 45001 cl.10.2 | They perform much of the higher-risk work; the events are the ones you need. |
| Inspections conducted only during day shift on planned visits. | ISO 45001 cl.8.1.4.2 | Contractor work at night and weekends is the least observed and highest risk. |
| Process safety contractor performance not periodically evaluated. | 1910.119(h)(2)(iv) | An explicit host obligation where PSM applies. |
Worked case
Case in point: the three questions
After a contractor incident, a site with general supervisory authority over the work will be asked what it did. Under OSHA's multi-employer citation policy the controlling employer test considers three things: whether it conducted periodic inspections of the work, whether it implemented an effective system for correcting hazards found, and whether it enforced compliance by other employers.
A site with a comprehensive approval file, current insurance certificates, signed method statements and an indemnity clause has answered none of the three. Those documents describe the arrangement before the work started.
A site with a dozen dated inspection records, deficiencies noted, corrections verified, and one instance of work being stopped and restarted after a fix, has answered all three with evidence.
Definitions
Definitions and key terms
- Controlling employer
- An employer with general supervisory authority over a worksite, including power to correct hazards or require correction.
- Reasonable care
- The controlling employer standard, assessed by periodic inspection, a correction system and enforcement.
- Periodic inspection
- Observation of contractor work in progress at a frequency proportionate to the risk of the activity.
- Correction system
- The mechanism by which deficiencies found are fixed and verified, distinct from recording them.
- Enforcement
- Requiring compliance by other employers on site, which needs an escalation route and the authority to stop work.
- Permitted conditions
- The controls specified on a permit, which the inspection verifies are physically in place.
- Stop work authority
- The explicit power to halt an activity, without which enforcement is nominal.
- Performance feedback
- Contractor safety findings reaching procurement so they affect future engagement.
FAQ
Frequently asked questions
Why does the site inspect a contractor's work?+
Because a controlling employer can be liable for hazards affecting another employer's workers, and the defence is reasonable care. That is assessed by whether the site conducted periodic inspections, had an effective system for correcting hazards found, and enforced compliance. Those three questions are answered by activity, and no approval file answers any of them.
What should be inspected?+
The work in progress. Whether the isolation described on the permit is applied, whether edge protection is in place, whether access is safe, how people are actually performing the task. Reviewing permits and certificates examines the documentation, which is the part most likely to be in order and least likely to be where the risk is.
How often?+
By risk rather than by contract duration or value. A week of high-risk work warrants attention while it is happening; a low-risk long-term contract does not need the same intensity. Frequency driven by contract value produces oversight concentrated where the spend is, which correlates poorly with where the hazard is.
What if we find something?+
Correct it, verify the correction, and record both. An inspection recording deficiencies without a correction trail places the site in a worse position than not having inspected, because it evidences that the hazard was known. The correction record is the second of the three questions and it is frequently the missing one.
Does an indemnity clause help?+
Commercially, sometimes. For regulatory liability, no. A controlling employer is cited for its own failure to exercise reasonable care, and an allocation of risk between the parties does not affect whether the site inspected the work, corrected what it found and enforced compliance.
The agents
What the agents do with it
The inspection observes work in progress. What fails is a review of paperwork and a deficiency with no correction.
Sets inspection frequency from the risk of the work, records observations against permitted conditions, and tracks corrections to verified closure.
Provides the escalation route including stop work authority, so enforcement has an answer rather than an intention.
Aggregates findings by contractor and routes repeat performance to procurement, where engagement decisions are made.
Confirms that the individuals observed are the ones inducted and competent for the work being performed.
This template lives in KnowSafe — safety and compliance. Incidents, hazards, permits, inspections and the critical controls behind them.
Meet KnowSafe→Sources
Sources
- OSHA multi-employer citation policy, directive CPL 02-00-124
- ISO 45001:2018 clause 8.1.4, procurement, contractors and outsourcing
- 29 CFR 1910.119(h), process safety management contractors, OSHA
- Construction (Design and Management) Regulations 2015 (GB)
- ISO 45001:2018 clauses 9.1 and 10.2