Manage Contractor Safety: PSM Element 6 Compliance Checklist
Manage Contractor Safety: PSM Element 6 Compliance Checklist
Author: Fidelis Associates | Published: 2026-03-03 | Last Updated: 2026-03-03
Meta Description: Checklist for OSHA 1910.119(h) Contractors — verify contractor evaluation, hazard communication, safe work practices, and performance monitoring.
OSHA Reference
Under OSHA's Process Safety Management standard 29 CFR 1910.119(h), employers must evaluate contractor safety performance during selection, inform contractors of known potential fire, explosion, or toxic release hazards, explain the facility's emergency action plan, and develop and implement safe work practices for contractor activities in and near covered processes. Contractors, in turn, must train their employees on the work practices necessary to safely perform their jobs, document that training, and ensure their employees follow the safety rules of the facility. The employer must maintain a contract employee injury and illness log.
Fidelis Insight
Contractors perform a significant share of work on PSM-covered processes — turnarounds, maintenance, construction, and specialized services. Yet contractor employees often have less familiarity with the specific hazards, alarm systems, emergency procedures, and operating realities of the facility than direct-hire staff. This gap makes the Contractors element one of the most practically important in PSM.
The standard places obligations on both sides: the employer must screen, inform, and monitor; the contractor must train, document, and enforce. In practice, the most common failures occur at the handoff — the employer assumes the contractor handles training, and the contractor assumes the employer covers site-specific hazards. Neither side closes the loop.
Strong contractor programs treat contractor employees as extensions of the workforce, not outsiders. They integrate contractors into hazard communication, safe work practices, and emergency response — and they monitor performance in the field, not just on paper.
Common Gaps We See
- ⚠ Contractor pre-qualification limited to paperwork reviews without verifying field safety performance
- ⚠ Hazard communication is generic — doesn't cover process-specific risks or recent incidents
- ⚠ Emergency action plan briefings are one-time orientations with no refresher or verification
- ⚠ On-site performance monitoring is inconsistent or nonexistent
- ⚠ Contractor employees performing PSM-covered work don't receive process-specific hazard training
- ⚠ Contractor injury and illness logs not maintained or reviewed
- ⚠ No defined safe work practices for contractor activities near covered processes
- ⚠ Contractor supervisors not integrated into permit-to-work and MOC processes
Best Practices Checklist
Employer Responsibilities
- [ ] Contractor safety performance evaluated during pre-qualification (EMR, TRIR, safety program review)
- [ ] Contractors informed of known potential fire, explosion, or toxic release hazards
- [ ] Facility emergency action plan explained to contractor employees
- [ ] Safe work practices developed for contractor activities in and near covered processes
- [ ] Contractor activities periodically evaluated to ensure compliance with safe work practices
- [ ] Contract employee injury and illness log maintained and reviewed
Contractor Responsibilities
- [ ] Contractor employees trained on work practices necessary to safely perform their jobs
- [ ] Contractor training documented with employee identity, date, and means of verification
- [ ] Contractor employees instructed on known hazards of their work and the process
- [ ] Contractor ensures employees follow facility safety rules
Integration & Oversight
- [ ] Contractors integrated into permit-to-work systems (hot work, confined space, LOTO)
- [ ] Contractor supervisors participate in daily safety briefings and pre-job meetings
- [ ] Contractor performance data (incidents, near-misses, observations) tracked and trended
- [ ] Lessons learned from contractor incidents shared with the workforce
- [ ] Contractor employees included in relevant emergency drills
Scoring Tip
- 12–15 checks = Strong contractor management program
- 7–11 checks = Needs improvement
- 0–6 checks = Immediate action required
Practical Use
Use this checklist before contractor mobilization and during active work phases. Review contractor pre-qualification packages against actual field performance — paperwork alone doesn't predict safety outcomes. During turnarounds and high-activity periods, increase oversight frequency and ensure contractor employees receive the same quality of hazard communication as direct-hire personnel.
Key Takeaways
- Contractor safety is a shared responsibility — both employer and contractor have specific obligations under 1910.119(h).
- Pre-qualification must evaluate actual safety performance, not just administrative compliance.
- Hazard communication must be process-specific and include recent incidents and changes.
- On-site monitoring is essential — assumptions about contractor competence are a common failure mode.
- Maintaining and reviewing the contractor injury and illness log is a regulatory requirement, not optional.
Assess Your Program
Use this checklist as a starting point, then benchmark your program with a FidelisCheck PSM assessment.
Related Resources
- What is Process Safety Management? A Complete Guide
- The 14 Elements of PSM: A Practitioner's Breakdown
- OSHA 1910.119 PSM Compliance Checklist
- PSM Element 5: Training Checklist
- PSM Element 7: Pre-Startup Safety Review (PSSR) Checklist
Frequently Asked Questions
What are the employer's responsibilities versus the contractor's responsibilities under OSHA PSM? OSHA 29 CFR 1910.119(h) divides responsibilities between the host employer and the contract employer. The host employer must evaluate the contractor's safety performance during selection, inform contractor employees of known fire, explosion, and toxic release hazards, explain the emergency action plan, develop safe work practices for contractor activities near covered processes, periodically evaluate contractor compliance, and maintain a contract employee injury and illness log. The contract employer must train their workers on safe work practices, document that training, ensure workers understand process hazards related to their jobs, and ensure workers follow facility safety rules.
What safety information must be shared with contractors? Under 1910.119(h)(2)(ii) and (iii), the host employer must inform contract employers and their employees of known potential fire, explosion, or toxic release hazards related to the contractor's work and the process. The host employer must also explain the applicable provisions of the emergency action plan. Best practice goes further: share process-specific hazard information, recent incident summaries, current MOC status for areas where contractors will work, and any PHA findings relevant to the contractor's scope. Generic safety orientations that do not address site-specific hazards are a common OSHA citation area.
How should contractor safety performance be evaluated? OSHA 29 CFR 1910.119(h)(2)(i) requires the host employer to evaluate contractor safety performance and programs when selecting contractors. The standard does not prescribe specific evaluation criteria, but common metrics include Experience Modification Rate (EMR), Total Recordable Incident Rate (TRIR), review of the contractor's safety program, and verification of training records. Best practice extends beyond pre-qualification paperwork to include on-site performance monitoring, regular safety observations, tracking of near-misses and incidents, and periodic reviews of contractor safety metrics during active work periods.
Fidelis Associates provides PSM compliance consulting and assessment services through FidelisCore and FidelisGap. Our team brings 40+ years of combined experience across major operators including Chevron, Valero, and Shell.
Ready to strengthen your operations?
Talk to a Fidelis specialist about how we can help.