1910.119(h)(3)(iii) Process safety management, contractors |
The contract employer, on or adjacent to a covered process |
Document that each contract employee has received and understood the training, and prepare a record containing the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training. |
Yes, explicitly, and it asks you to name the means. This is the strongest comprehension record language in Part 1910. |
1910.119(h)(2) Process safety management, host duties |
The host employer |
Obtain and evaluate contractor safety performance, inform contractors of known hazards related to their work, explain applicable emergency action plan provisions, develop safe work practices controlling contractor entrance and presence, periodically evaluate contractor performance, and maintain contract employee injury and illness logs. |
No. Inform and explain, not verify. This is the half of the duty an orientation packet covers. |
1910.146(c)(8) and (c)(9) Permit required confined spaces |
Host and contractor, both |
The host informs the contractor that the workplace contains permit spaces, apprises them of the hazards and of the host's own experience with the space, apprises them of precautions in place, coordinates joint entries, and debriefs at the end. The contractor obtains that information, coordinates, and informs the host of the program it will follow and any hazards confronted or created. |
No. A two way information exchange with a debrief at the end, and no comprehension test anywhere in it. |
1910.147(f)(2) Lockout and tagout, outside personnel |
Host and outside employer |
The on site employer and the outside employer inform each other of their respective lockout or tagout procedures, and the on site employer ensures its own employees understand and comply with the restrictions and prohibitions of the outside employer's energy control program. |
Partly, and in the direction people expect least: the understanding duty runs toward your own staff about the contractor's program, not the reverse. |
1926.21(b)(2) Construction, safety training and education |
Every construction employer |
Instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to the work environment to control or eliminate any hazards or other exposure to illness or injury. |
No. Instruct is the verb, and there is no record field at all. Construction site inductions are documented by custom, not by rule. |
Multi Employer Citation Policy CPL 02-00-124, December 10 1999 |
Any employer on a multi employer worksite |
OSHA's enforcement directive under which more than one employer may be cited for a hazardous condition, using the creating, exposing, correcting, and controlling employer roles. A controlling employer is expected to exercise reasonable care to prevent and detect violations on the site. |
Not a training rule at all, but it is why a host that never checked whether contractors absorbed the site rules is exposed for their conduct. |