Employer guide · 2 min read · Updated 2026-10-25
Contractors, Subcontractors and Multi-Employer HAZWOPER Sites
Cleanup sites are rarely one-company jobs. A prime contractor may manage drillers, excavation subs, a lab, waste haulers and specialty contractors at the same time. HAZWOPER and OSHA's enforcement policy both address who is responsible for what.
What HAZWOPER requires
- Share the safety and health program. The written program must be made available to any contractor or subcontractor involved in the hazardous waste operation (1910.120(b)(1)(iv)).
- Tell contractors about hazards. Employers who hire contractors must inform them of the site emergency response procedures and any known fire, explosion, health, safety or other hazards (1910.120(b)(1)(v)).
- One site safety and health plan governs work on the site, and everyone on site follows it.
OSHA's multi-employer citation policy
On multi-employer worksites, OSHA can cite more than one employer for the same hazard. Its policy describes four roles:
| Role | Who it is |
|---|---|
| Creating employer | Caused the hazardous condition |
| Exposing employer | Its own employees are exposed to the hazard |
| Correcting employer | Responsible for fixing the hazard, such as the sub hired to maintain decon or ventilation |
| Controlling employer | Has general supervisory authority over the site, including the power to correct hazards or require others to |
A prime contractor or site owner acting as controlling employer is expected to use reasonable care to prevent and detect violations, which includes checking that subcontractor workers are trained.
Prequalifying subcontractors
- Training certificates for every worker who'll be on site, at the right level, with refreshers within 12 months
- Supervisor training for their on-site lead
- Medical surveillance and respirator fit test confirmation for workers who need them
- Their safety and health program and recent safety performance (for example, OSHA 300A summaries and citation history)
- Agreement to follow the site safety and health plan and attend pre-entry briefings
On site
- Check training at the access control point before badging workers in.
- Include subcontractor crews in pre-entry briefings and site-specific training.
- Use one emergency response plan and one communication system for everyone.
Helping subcontractors get compliant
When a sub's crew is short on training, they can buy every course and seat they need in one order and start right away. Point them to the crew training planner.
Frequently asked questions
Does the prime contractor have to verify subcontractor HAZWOPER training?
Under OSHA's multi-employer citation policy, a controlling employer must use reasonable care to prevent and detect violations, which in practice includes checking subcontractor workers' training before they go on site.
What must a hiring employer tell contractors under HAZWOPER?
The site emergency response procedures and any known fire, explosion, health, safety or other hazards, and make the written safety and health program available to them.
What are the four employer types in OSHA's multi-employer policy?
Creating, exposing, correcting and controlling employers.
This guide summarizes federal OSHA, Cal/OSHA and EPA rules for training purposes. It is not legal advice. Always check the current regulation text and your site safety and health plan.