Understanding OSHA’s Multi-Employer Citation Policy: What Every Employer Should Know

Construction projects, industrial facilities, and manufacturing sites often involve multiple employers working side by side. A general contractor may oversee the project, subcontractors perform specialized work, staffing agencies provide temporary employees, and property owners or host employers may also be involved.

When a workplace safety violation occurs in these situations, many employers assume OSHA will only cite the company whose employee was exposed to the hazard. That’s not always the case.

Under OSHA’s Multi-Employer Citation Policy, more than one employer may be held responsible for the same hazardous condition. Understanding how this policy works can help organizations better manage risk, clarify responsibilities, and strengthen communication between everyone on a worksite.

What Is OSHA’s Multi-Employer Citation Policy?

OSHA’s Multi-Employer Citation Policy recognizes that multiple employers may have different responsibilities for workplace safety on the same worksite.

Rather than looking only at whose employee was exposed to a hazard, OSHA evaluates each employer’s role in creating, controlling, correcting, or exposing employees to that hazard.

This policy is most commonly associated with construction projects, but it can also apply in manufacturing facilities, warehouses, maintenance activities, industrial plants, and other workplaces where multiple employers operate together.

The key takeaway is simple: A company doesn’t necessarily have to expose its own employees to a hazard to receive an OSHA citation.

The Four Employer Categories

OSHA identifies four types of employers that may have responsibilities under its Multi-Employer Citation Policy.

Creating Employer

A creating employer is the employer that caused the hazardous condition.

For example, imagine a subcontractor removes a machine guard and leaves the equipment operating without replacing it. Even if another company’s employees are the ones exposed to the hazard, the subcontractor that created the unsafe condition may still be cited.

Similarly, a contractor that improperly installs fall protection systems or leaves an unprotected floor opening could be considered the creating employer.

Exposing Employer

The exposing employer is the employer whose employees are exposed to the hazard.

Even if another company created the hazard, employers still have a responsibility to protect their own workers. Depending on the circumstances, reasonable actions might include:

• Correcting the hazard if they have the authority to do so.
• Requesting that the responsible employer correct the issue.
• Warning employees about the hazard.
• Preventing employees from entering the hazardous area until conditions improve.

Simply assuming another employer will address the problem may not be sufficient.

Correcting Employer

A correcting employer is responsible for correcting a particular hazard.

This responsibility often exists because of a contractual agreement or assigned duties. Examples may include:

• A contractor responsible for maintaining scaffolding.
• A company hired to repair electrical systems.
• A maintenance contractor responsible for machine guarding.

If the employer has agreed to correct safety hazards, OSHA may expect those responsibilities to be carried out in a timely manner.

Controlling Employer

The controlling has general supervisory authority over a worksite, including the power to correct safety and health violations itself or require others to correct them.

On construction projects, this is often, but not always, the general contractor. A controlling employer is expected to exercise reasonable care to prevent and detect safety violations.

That doesn’t mean inspecting every task every minute of the day. However, OSHA generally expects controlling employers to:

• Monitor overall site safety.
• Coordinate activities among contractors.
• Address known hazards.
• Ensure contractors are correcting identified deficiencies.

The level of oversight expected depends on factors such as the nature of the work, the degree of control, and the hazards involved.

Why This Policy Matters

The Multi-Employer Citation Policy reinforces an important principle: Workplace safety is often a shared responsibility.

When several employers are working together, safety depends on communication, coordination, and accountability. Not simply each company focusing on its own employees. Without clear expectations, hazards can easily be overlooked because everyone assumes someone else is responsible.

Best Practices for Multi-Employer Worksites

Organizations working alongside other employers can reduce risk by establishing clear safety expectations before work begins.

Some good practices include:

• Clearly defining safety responsibilities in contracts.
• Conducting pre-job planning meetings.
• Communicating site-specific hazards.
• Coordinating work activities between employers.
• Performing routine workplace inspections.
• Promptly correcting identified hazards.
• Encouraging employees to report unsafe conditions.
• Maintaining documentation of inspections and corrective actions.
• Holding regular coordination meetings when multiple contractors are on site.

Strong communication is often one of the most effective tools for preventing misunderstandings about safety responsibilities.

Documentation Is Important

When multiple employers share a workplace, documentation becomes especially valuable.

Maintaining records of inspections, hazard reports, corrective actions, contractor communications, and safety meetings can help demonstrate that organizations are actively managing workplace risks.

Documentation also helps ensure important information is communicated consistently as contractors, employees, and supervisors can change throughout a project.

The Bottom Line

OSHA’s Multi-Employer Citation Policy serves as an important reminder that workplace safety is rarely the responsibility of just one employer.

Creating employers, exposing employers, correcting employers, and controlling employers all have roles to play in identifying hazards, communicating concerns, and helping ensure work is performed safely.

Whether you’re a general contractor coordinating multiple subcontractors or an employer sending employees to work at another company’s facility, understanding how responsibilities may overlap is an important part of managing workplace safety.

Taking the time to clarify roles, communicate expectations, and address hazards promptly can help reduce risk for everyone and contribute to a safer, more collaborative working environment.