Review a subcontractor safety plan before mobilisation

A subcontractor can pass corporate prequalification and still submit a plan that does not address the actual job. A general contractor needs to know how the subcontractor will control its work, communicate with other trades and respond when site conditions change. The review should end with a specific accept, revise or hold-mobilisation decision, with exceptions visible to those managing the site.

OSHA's Multi-Employer Citation Policy describes how responsibility can depend on an employer's role and actual control at a multi-employer worksite. It does not create one universal safety-plan template or transfer every subcontractor duty to the general contractor. OSHA's construction compliance resources provide sector context. Check federal and applicable state-plan standards, contract obligations and the specific work before setting approval criteria. This page owns pre-mobilisation plan review, separate from supplier onboarding or a site induction record.

Define the work the plan must cover

Start with the scope, dates, work area, crew and subcontract tiers. Identify high-risk activities, equipment, materials and interfaces with other trades or occupants. A plan for a previous project may describe the contractor's general system but omit the excavation, lift or shared access route on this site. Ask the contractor to identify what is genuinely specific to this work.

Map the plan to the current site information: drawings, known hazards, emergency arrangements, permits, access restrictions and simultaneous operations. Share relevant information early enough for the contractor to revise its method. A reviewer should not reject a plan for missing a hazard that the host team never communicated.

Review controls, roles and escalation

For each material risk, ask who performs the work, what control is planned, who checks it and what stops work if the control fails. Look for specific supervision, competent-person roles where required, equipment checks and communication with the site lead. A list of regulation numbers or a signature page does not explain how a crew will act when conditions differ from the plan.

Review emergency and incident communication. Who does the subcontractor call first? How will its crew hear about a changed site rule? How will it inform adjacent trades that an exclusion zone or isolation affects them? These interfaces may be more important than the length of the corporate safety manual.

Do not use the review to certify technical design beyond the reviewer's competence. A crane lift, excavation protective system or electrical isolation can require specialist design and approval. Record that requirement and the responsible specialist rather than marking the whole plan “approved” with an unexamined attachment.

Make the review decision explicit

Use a decision record tied to the plan version and scope. “Accepted for mobilisation” should state any conditions, documents still due and activities that remain prohibited. “Revise” should identify the material gap and the evidence needed. “Hold” should say which work cannot start and who will reassess. Avoid ambiguous comments such as “looks okay” when the project team needs a clear operational instruction.

The reviewer's acceptance does not release the subcontractor from its own safety duties. Nor does it mean all site hazards have been eliminated. OSHA's multi-employer policy considers actual roles and conduct, so a stamped plan should not be presented as a shield from responsibility. The site team must still coordinate and monitor work as conditions change.

Link plan review to mobilisation

Before crew arrival, confirm the accepted version is available to the site lead and subcontractor supervisor. Check that named people, equipment and dates remain accurate. If a different subcontractor crew or method arrives, the original review may not cover it. A targeted change review is better than either blindly accepting the old plan or repeating every corporate prequalification step.

During induction or pre-start briefing, explain the site-specific conditions and how the crew raises a conflict. Keep evidence that the relevant supervisor received the current plan and restrictions. A signature on a general handbook is not proof that the crew understood a new utility location or work-at-height interface.

Example: adjacent trades share an access route

A mechanical subcontractor submits a plan for equipment replacement. It describes lifting and lockout but assumes its delivery truck can use the service entrance throughout the morning. The general contractor knows another trade has an excavation at that entrance. The reviewer marks the plan “revise”, shares the current traffic arrangement and asks the contractor to reschedule delivery and specify a safe route. The revised plan is accepted for the defined scope, while the lift remains subject to a separate competent review.

The process closes an interface that a supplier database would not detect. The contractor's general safety rating did not answer whether this particular truck could enter this particular work area on this date.

Reopen the plan when work changes

A change in sequence, location, equipment, substance, crew or adjacent activity may alter the plan's assumptions. Record the change, who identified it, interim stop or restriction and the review outcome. Preserve the prior version so the project can see what controlled work at each stage. Do not replace a rejected plan in the archive with a later accepted version and erase the reason work paused.

Track recurrent gaps across subcontractors. If reviewers repeatedly find missing site information, improve the information the general contractor supplies. If one contractor repeatedly omits its own controls, address that performance issue. The goal is reliable coordination, not a higher count of reviewed PDFs.

For a current-product discussion, see Complys US construction and ask how a submitted plan, human review, version and conditional action could be evidenced in the present product. This guide does not claim Complys validates OSHA compliance, approves technical designs, integrates with supplier networks or automatically permits mobilisation.