900 Oil and Gas Safety Management

Responsibilities

According to OSHA, there are four employer roles or categories on a multi-employer wellsite:

1. Creating employer: The employer that caused a hazardous condition that violates an OSHA standard.
2. Exposing employer: This is an employer whose own employees are exposed to the hazard.
3. Correcting employer: This is an employer who is engaged in a common undertaking, on the same wellsite construction as the exposing employer, and is responsible for correcting a hazard. This usually occurs where an employer is given the responsibility of installing and/or maintaining particular safety/health equipment or devices.
4. Controlling employer: This is an employer who has general supervisory authority over the wellsite construction, including the power to correct safety and health violations itself or require others to correct them. Control can be established by contract or, in the absence of explicit contractual provisions, by the exercise of control in practice.

The controlling contractor assumes all obligations under the standards, whether or not the work is subcontracted [29 CFR 1926.16(b)].

To the extent that a subcontractor agrees to perform any part of the contract, he assumes responsibility for complying with the standards with respect to that part [29 CFR 1926.16(c)].

With respect to subcontracted work, the controlling contractor and any subcontractors are deemed to have joint responsibility [29 CFR 1926.16(d)].

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