# Subcontractor Safety Management: The GC's Complete Guide
On a typical commercial construction project, the general contractor (GC) manages 10-30 subcontractors. Each brings their own chemicals, workers, and safety programs. Under OSHA's multi-employer worksite policy, the GC can be cited for subcontractor safety violations—even if the GC's own employees weren't involved.
Managing subcontractor safety with phone calls, emails, and paper binders is a recipe for citations. HazComFast gives GCs a digital system to verify, track, and document subcontractor compliance.
OSHA's Multi-Employer Worksite Policy
OSHA classifies employers on multi-employer worksites into four categories:
| Role | Definition | Liability |
|------|-----------|-----------|
| Creating employer | Created the hazard | Directly citable |
| Exposing employer | Workers exposed to the hazard | Directly citable |
| Correcting employer | Responsible for correcting the hazard | Citable if they fail to correct |
| Controlling employer | Has general supervisory authority | Citable if they fail to exercise reasonable care |
GCs are almost always classified as controlling employers. This means you're liable if you fail to exercise reasonable care in ensuring subcontractor safety—including HazCom compliance.
The Subcontractor HazCom Problem
What Goes Wrong
1. Unknown chemicals — Subs bring chemicals to the jobsite without notifying the GC
2. Missing SDSs — Sub's chemical inventory isn't shared or doesn't match what's on site
3. Training gaps — Sub workers aren't trained on chemicals other trades brought to the jobsite
4. Label failures — Secondary containers without proper GHS labels
5. No documentation — When OSHA cites the GC, there's no evidence of sub oversight
The Real Cost
OSHA can cite the GC for each subcontractor's HazCom violations as a controlling employer. With 15 subs on a project and a single chemical inventory gap per sub, th