Contractors
Selection based on safety performance, pre job orientation, injury tracking, and periodic evaluation of contractors
What this element is and why it matters
OSHA PSM at 1910.119(h) covers maintenance, repair, turnaround, major renovation, and specialty work performed by contractors on or near covered processes. The element splits responsibility into two parts. Paragraph (h)(2) sets the employer obligations, which include selecting contractors on the basis of safety performance, communicating hazard information, providing a pre job orientation, tracking injuries, and evaluating performance periodically. Paragraph (h)(3) sets the contractor obligations, which include training employees, supervisor responsibility, hazard reporting, and adherence to the safety rules. Our team builds a programme that holds both sides to the same standard.
Individual significance for organisations
Without a structured programme, contractor incident rates have historically run two to five times the rate of direct employees. The modern process industry depends on contractors for between thirty and sixty per cent of turnaround work hours. Facilities that manage contractors as peers see their contractor incident rates fall in line with direct employee rates, while facilities that treat contractors as separate carry a disproportionate share of incident exposure, and we help your team close that gap.
Contribution to OSHA Process Safety Management (29 CFR 1910.119)
Paragraph (h) extends the management system out to the workforce that is not directly employed yet performs the highest risk activities, including turnarounds, modifications, and specialty maintenance. It integrates with employee participation in (c) through joint health and safety committees, with training in (g) through contractor competency, with hot work in (k) through permit to work discipline, and with the pre startup safety review in (i) through contractor work close out. This element prevents a coverage gap during exactly the work where prevention matters most.
What compliant execution looks like
How we implement this element
A focused six step methodology calibrated to deliver contractors as a working capability rather than a documented compliance artefact.
To meet (h)(2)(i) we build pre qualification criteria around recordable and lost time injury frequency thresholds, OSHA citation history, and insurance certificates, aligned with ISNetworld, Avetta, and OISD 149.
To meet (h)(2)(ii) and (iii) we run a pre mobilisation orientation covering the site hazards, evacuation, the permit to work system, and emergency response.
To meet (h)(2)(iv) we specify the reporting requirements across recordable injuries, lost time injuries, and near misses with monthly aggregation.
To meet (h)(2)(v) we evaluate contractor safety performance during and after the engagement and document it to inform future selection decisions.
We match supervision intensity to the tier of work, with continuous supervision for high hazard tier one, intermittent for tier two, and periodic for tier three.
We close each contract with an HSE scorecard and lessons learned and tie the re engagement decision into your procurement database.
Element implementation flow chart
A decision gated workflow that shows the actual sequence of activities from initiation through steady state operation, with key decision points highlighted.
What we produce
- A contractor pre qualification framework meeting (h)(2)(i)
- A pre mobilisation orientation package
- An injury and illness tracking system meeting (h)(2)(iv)
- A periodic evaluation scorecard
- A supervision plan matched to the tier of work
- A close out review protocol
Where execution fails
- Pre qualification done once and never refreshed
- Orientation treated as a box to tick without verifying comprehension
- Periodic evaluation skipped so the same poor contractors are re engaged
- Tier classification ignored under turnaround time pressure
Codes this element is built on
Explore related elements in this framework
OSHA Process Safety Management (29 CFR 1910.119) full element index
Talk to us about implementing Contractors
We can scope this element implementation against your facility, regulatory context, and existing management system maturity, then integrate it with the other OSHA Process Safety Management (29 CFR 1910.119) elements you already operate.