How to prequalify and manage subcontractors, step by step
To manage subcontractors safely, collect their safety information before you hire them, approve them against written criteria, orient them to your site, coordinate their work with yours, check it while it is under way, investigate their incidents with them, and evaluate them when the job ends. The law puts the coordination duty on the prime contractor in Alberta, British Columbia and Saskatchewan and on the constructor in Ontario, so on most multi-employer jobs somebody is legally responsible for this. Here is how to run each step and keep the records that prove it.
By Quick Safety Compliance · · 4 min read
Who carries the duty
- Alberta: every construction and oil and gas work site with 2 or more employers must have a prime contractor, designated in writing by the person in control of the site (OHS Act, s. 10).
- British Columbia: at a multiple-employer workplace, the prime contractor coordinates the health and safety activities of everyone there and maintains a system to ensure compliance, and each employer names its supervisor to the prime contractor (Workers Compensation Act, s. 24).
- Saskatchewan: a construction, forestry or oil and gas worksite with 10 or more self-employed persons, or workers of 2 or more employers, needs a prime contractor, and each employer gives the prime contractor the name of its designated supervisor (OHS Regulations, 2020, s. 33-2 and 33-3).
- Ontario: on a construction project, the constructor ensures every employer and worker complies with the Act and regulations (OHS Act, s. 23(1)).
Step 1: collect safety information before you hire
- Proof of workers' compensation coverage in good standing for the province where the work is.
- Proof of liability insurance at the limits your client requires.
- Their health and safety program, or the parts that apply to the work: hazard assessment, the safe work practices for their tasks, emergency response and incident reporting.
- Recent incident statistics, if your client asks you for yours.
- Training and certification records for the high-risk work they will do, for example fall protection, confined space or ground disturbance.
Step 2: approve against written criteria
Decide in advance what a subcontractor must have to be approved, and who signs the approval. Write the criteria into your subcontractor management plan and apply them every time, so the decision does not depend on who is in the office that day. Keep a list of approved subcontractors with the date each one was checked and when their coverage expires.
Step 3: orient them to your site
Every subcontractor worker gets your site orientation before starting: site hazards, emergency procedures and muster points, the rules for permits and PPE, how to report incidents and near misses, and who to go to with a concern. Use the same orientation checklist you use for your own workers and keep the signed copy.
Real pages from the files you download. Tap a page to see it full size. From: Subcontractor Management Plan RAVS - Alberta, Subcontractor Management Plan RAVS - Saskatchewan, Alberta Construction Safety Manual.
Step 4: coordinate the work
Before work starts each day, share the hazards your work creates for them and theirs for you: overhead work, hot work, energised equipment, excavations, mobile equipment. Include their supervisor in your daily start-up or toolbox meeting, and have their crews complete field level hazard assessments for their own tasks.
Step 5: check the work while it is under way
Include subcontractor work areas in your site inspections, record what you find, and give the subcontractor's supervisor a copy of anything they need to correct, with a date. Escalate repeated problems in writing. Your plan should say what happens when a subcontractor will not correct an unsafe condition, up to stopping the work and removing them from site.
Step 6: report and investigate together
Make sure subcontractors report every incident and near miss to you, not only to their own office, so the prime contractor or constructor can meet its own reporting duties. Investigate together and share the corrective actions with every employer on site who could be affected.
Step 7: evaluate at the end of the job
Score each subcontractor at close-out on safety performance, incidents, how quickly they fixed deficiencies and the quality of their paperwork. Record the result against their approval, and use it the next time you hire. A short written evaluation is also what a client asks for when it checks how you manage your own subcontractors.
Keep one file per subcontractor
Open a file for each subcontractor when you approve them and keep everything in it: the information you collected, your approval and its date, the orientation records for each of their workers, inspection findings and how they were closed, incident reports and the close-out evaluation. When a client asks how you manage subcontractors, the file is the answer, and when you hire the same company again you can see at a glance whether anything has expired.
Templates
Subcontractor Management Plan written programs are $9 each for Alberta, Saskatchewan and Canada-wide practice. Every manual also includes a section on visitors, contractors and other parties on your sites, for $499.
Read the legislation
Official sources
- Alberta OHS Act, Part 1: general obligations, including prime contractors (s. 10)
- BC Workers Compensation Act, Part 2: occupational health and safety
- BC OHS Regulation, Part 20: construction, excavation and demolition
- The Occupational Health and Safety Regulations, 2020 (Saskatchewan Publications Centre)
- Ontario: Guide to the OHS Act, Part III (duties of employers and constructors)
Questions
Is a subcontractor management plan required by law?
No law names the document, but the prime contractor and constructor duties above require you to coordinate and oversee the other employers on your sites, and ISNetworld often lists the plan as a required program. The written plan is how you show you do it.
What if a subcontractor has no safety program?
Decide whether your criteria allow it for the work in question. For low-risk work you might accept their workers following your program under your supervision; for high-risk work, require their own written program and safe work practices before they start.
How often should I re-check approved subcontractors?
At least once a year, and whenever their compensation coverage or insurance expires. Keep the date of each check on your approved list.
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