According to OSHA contractor employers are required to train their workers on fall protection prior to exposing the workers to the hazards. When either you or someone else trains your employees you also need to document the training in writing. Information should include who was trained, by whom, the topic, the date and a copy of the certification for each worker must be maintained.                                                                  

The rule of thumb is the training needs to be done by a "Competent Person" who is qualified to train others on the subject.

If you the contractor owner are the Competent Person identified in your Company Safety Manual and you know what needs to be trained then you can do it. If this does not describe your situation or you are not sure of what you really need to do then:

• You can train yourself by going to the OSHA website, reading and learning the rules and using their tools.
• You can work with a safety trainer to train you. Once trained you can train your own people. However if you do not feel comfortable training your own team you can hire a safety trainer to do it for you.
• You can call OSHA and ask educational assistance side to help you. 
• Know your responsibilities and follow through on training your employees.

On the subject of Sub-contractors; they must be trained and OSHA compliant if they are on your job site. General contractors are required under the General Duty Clause to make sure that all workers on the job have a healthy and safe work place. The general contractor is responsible for the safety of the subs workers. The prudent way to proceed here is to demand that all of your subcontractors work OSHA compliant on your site. One way to reduce your risk is to require that your sub contractor provides you with proof of their safety program and certifications.

Many contractors argue that this is a problem with subs. Well it is a bigger problem if you have a sub who is working unsafe on your job site and OSHA comes by. You as the general contractor can be fined along with the sub.

• What if this was your sub on your job site ?
• Do you think OSHA would have a problem with safety on this job?                               
• Is the money saved hiring this sub contractor worth the OSHA fines?              

If you have a sub who will not provide the proper documentation and certification you should not use them. Attorneys and insurance professionals we work with tell our clients all the time never hire any subcontractor who doesn't carry or do these things:

• General Liability Insurance
• Workmen's Compensation Insurance
• Proper Licensing for what they do
• Safety Program and proof that they have trained their workers on the job related hazards they will be exposed to.
• Sign a sub contractor agreement.
• Provide Release of Liens
• Sign Indemnification Form

The winter is a good time to assess your fall protection program and also make sure your subs do not pose a risk for your business if they are working on your projects. OSHA is still pretty busy focising on fall protection compliance.