Florida Licensure Education Track 1 – Subcontractor Safety and Home Builder Liability: Who is Responsible When Subcontractors Violate OSHA Regulations

This course is designed to educate attendees on OSHA’s Multi-Employer Citation Policy (CPL 02-00-124) which places safety and health regulatory responsibilities on general contractors, hiring contractors, prime contractors, and even facility owners who have committed no violation of any OSHA standard, yet these employers can still be found liable by OSHA when a subcontractor or vendor commits a violation on a worksite. The OSHA Multi-Employer Citation Policy has been reviewed by the Federal Courts, and enforced against employers, for over fifty years. However, the interpretation of the policy, and the duties placed upon a home builder who hires subcontractors, is still unclear. This course provides a history of the Multi-Employer Citation Policy and educates participants on why/how the policy became a primary tool for OSHA officers tasked with enforcing safety and health regulations. The course identifies the responsibilities of home builders and general contractors who might work on worksites where multiple separate employers engage in a common workspace. Attendees will learn how OSHA officers approach multi-employer sites, what questions OSHA will ask on these worksites, and what evidence OSHA will seek during multi-employer inspections. Utilizing past cases brought before the Occupational Safety and Health Review Commission and the Federal Circuit Courts, attendees will learn what type of conduct equates to “control” under the Multi-Employer Citation Policy, and what duties controlling employers owe to the employees of subcontractors and vendors working within a common workspace.