Multi-employer worksites: who gets the citation

The four roles

Under OSHA's multi-employer citation policy, more than one employer can be cited for the same hazard, each through a different role:

• Creating employer — caused the hazard (the sub who removed the guardrail).
• Exposing employer — its own employees were exposed, whoever created the hazard. If it lacked authority to correct, it must still protect its people and press the responsible party.
• Correcting employer — engaged specifically to install or maintain safety measures, cited for failing to correct what it owned.
• Controlling employer — has general supervisory authority over the site, typically the general contractor or construction manager, cited for hazards it should have detected and had corrected through reasonable care.

What "reasonable care" demands of a GC

A controlling employer's duty is lighter than an exposing employer's — it need not inspect as frequently or intensely as each sub inspects its own work — but it is real: periodic site inspections scaled to the project's pace and hazard level, a functioning system for subs to report hazards, enforcement of the project's safety requirements, and follow-through when violations are found.

The evidence that satisfies it is mundane and decisive: documented walkthroughs, correction notices to subs with closure, pre-task coordination, and orientation records. A GC with that trail can defeat a controlling-employer citation; a GC with a binder of unsigned policies cannot.

Temporary workers: host and staffing agency share the duties

OSHA treats staffing agencies and host employers as joint safety obligors for temporary workers: the host controls site conditions and task-specific training; the agency owes generic safety training and diligence about the placements. Injury recordkeeping follows day-to-day supervision — the host typically records the temp worker's case on its own 300 log.

The contract should say who provides which training and PPE — but a contract clause never transfers a duty OSHA has assigned; it only coordinates how the two employers discharge it.

Living on shared sites without collecting citations

The role-by-role survival kit:

• Subs: document your own inspections and your hazard reports up to the controlling contractor — the exposing employer's defense is proving it protected its people and escalated.
• GCs: run the inspection cadence you promised, and close what you find in writing.
• Everyone: coordinate at the plan level — sequencing decisions create the shared hazards inspectors later assign roles for.

Frequently asked questions