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Subcontractor & Workforce Planning · Part 1 of 3
Subcontractor Prequalification: Check Their Record Before It Becomes Yours
As the prime, a subcontractor’s safety record becomes your risk. AAAT3 checks EMR, OSHA logs, citations, insurance, licenses and safety programs before anyone mobilizes.
Key numbers
What the rules say
An EMR of 1.0 is the industry average. Below 1.0 is better than average, and many owners and primes set 1.0 as the cutoff
NCCI experience ratingHow long employers must keep OSHA 300 logs and 300A summaries, so there is a record to ask for
29 CFR 1904.33The prime contractor assumes all employer safety obligations, whether or not it subcontracts the work
29 CFR 1926.16(b)How we do it
Step by step
Prequalification package
Send one questionnaire and document list to every sub bidding the work.
Safety record review
Review three years of EMR letters and OSHA 300A summaries, and work out TRIR and DART rates.
Citation search
Search OSHA inspection and citation history for serious, willful and repeat items.
Insurance and licenses
Check certificates of insurance, required limits, additional insured wording, licenses and registrations.
Written programs
Confirm the safety program matches the scope, with named competent persons and training records.
Scope fit and past performance
Check similar work, references and, on federal jobs, CPARS records.
Decision
Approve, approve with conditions or decline, and file a scorecard for every sub.
Checklist
What we track and deliver
- Prequalification questionnaire
- EMR letters (3 years)
- OSHA 300A summaries (3 years)
- OSHA citation history
- Certificate of insurance with required limits
- Licenses and SAM registration (federal work)
- Written safety program and site-specific plan
- Training and competent person records
- Drug and alcohol policy
- Past performance references
- Scorecard and approval letter
Common problems
Where this usually goes wrong
Only checking the EMR
A small company with few hours can show a low EMR. We also check TRIR, DART and citations.
Insurance that lapses
We track every certificate expiration date and ask for renewals before coverage ends.
Paper safety programs
Downloaded programs often miss the real hazards. We check the program against the scope of work.
Mobilize first, vet later
We finish prequalification before the sub is on site, so problems are found on paper.
Standards
Codes and standards behind this work
7 standardsFederal government requirementIndustry recognized practice
Prime and subcontractor responsibility
3- 29 CFR 1926.16
Prime contractor and subcontractor responsibilitiesFederal
- OSHA CPL 02-00-124
Multi-employer citation policyFederal
- FAR 9.104-4
Primes determine the responsibility of their prospective subcontractorsFederal
Records and programs
4- 29 CFR 1904
Injury and illness recordkeeping (OSHA 300, 300A, 301)Federal
- EM 385-1-1
USACE contractor and subcontractor safety requirementsFederal
- ANSI/ASSP A10.33
Safety and health programs for multi-employer projectsIndustry
- ISO 45001 8.1.4
Procurement and control of contractorsIndustry
FAQ
Common questions
What EMR is good enough?
Many owners and primes ask for 1.0 or lower. We look at EMR together with TRIR, DART and citation history, because one number can hide problems.
Can a sub fail and still work?
Yes, if the gaps can be fixed. We can approve a sub with conditions, such as a corrected program or a named competent person before work starts.
Do you prequalify subs for federal jobs?
Yes. We add federal checks such as SAM registration, CPARS past performance and EM 385-1-1 requirements on USACE work.
Subcontractor & workforce planning in detail
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Get a quote for Subcontractor Prequalification
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