b'26 OSHA UPDATE (continued from pg 25)is an exception to this is for alleged violations ofcomplianceofthesubcontractorsemployees, the General Duty Clause. you should have the attorney who you use for OSHA matters take a look at the contracts you I have recently seen OSHA cite an employerare using now and edit them to protect you as fornottakingimmediateactiontocorrectamuch as possible from exposure for the safety safetyviolationbyindividualemployeesofitsviolationsofyoursubcontractors.Youmaybe subcontractor. The point here is that you needsaying to yourself that the more simple approach to be sure your contract with your subcontractorwould be to require your subcontractors indemnify clearly states the subcontractors responsibilityandholdyouharmlessfromanyOSHAfines forthesafetycomplianceandsafetyofitsassessed against your company for the safety employees. In this instance the employer did notviolationsofthesubcontractorsemployees, havespecificlanguageinitscontractwiththebut I believe that such language would not be subcontractor that spelled out how the generalenforceableasagainstpublicpolicy.So,get was to ensure that the subcontractors employeesyour contracts reviewed and edited to clearly set wereworkingsafely.Mymessagehereisthatout the subcontractors responsibilities and your rather than just reciting in your contract that theresponsibilities for the actions for the employees subcontractor shall comply with all federal, state,of the sub as well as the method by which you and local laws and rules governing safety on thewill enforce those responsibilities.jobsite you need to be specific. I suggest that you take a look at the contracts you use with your subcontractors to be sure that your responsibility as to the safety compliance of Dedicated to keeping its members at the forefront in their industrytheir employees is clearly spelled out. Also, your contractshouldspecifymeaningfulpenalties againstyoursubcontractorwheneveryoursite supervisor or your safety manager observes the subcontractorsemployeesviolatinganOSHA standard,theiremployerssafetyrulesor,if yourequirecompliancewithyoursafetyrules, your own safety rules. You then need to be sure thatyoursitesupervisorisawareofhis/her responsibility to take action under the contract foranysafetyviolationsoftheemployeesof the subcontractor he/she observes. You should discusswithyourOSHAcounselhowfaryour responsibility for the safety of the subcontractors employeesshouldgosoyourcontractcanbe drafted appropriately. Everyones goal is to see that all employees work safely, but you need toPFAS anchor pointsask yourself how much of that goal you wish to takeonasacontractualresponsibilityandaHow do you anchor your personal fall arrest potentialOSHAliability.Attheendofthedaysystems?Manyemployers/employeestake and in light of this new interest being shown byshortcutswhenanchoringtheirpersonalfall OSHAholdingthegeneralcontractor(oranyarrestsystems.Ratherthanfindingananchor levelcontractorwhoretainstheservicesofapointthatcomplieswiththerequirementsof subcontractor) responsible to OSHA for the safety1926.502(d)(15) and is capable of supporting a continuedpg.28The InsulatorJanuary 2021'