Trade guide · NAICS 236

The safety program a construction contractor is actually required to have

What the regulations require of a construction contractor, in the order an inspector or a prequalification portal will ask for it. Written for the person who has to run the program.

12 min read Reviewed against current CFR text Sep 2026 By Chip Irek 5 obligation areas
OBLIGATION 01

What written programs does a construction contractor need?

What the rule requires

Construction work triggers several program requirements simultaneously. A written Hazard Communication program whenever hazardous chemicals are present (1910.1200(e)(1)). Documented energy control procedures for lockout/tagout (1910.147(c)(4)). A written emergency action plan at certain headcounts (1910.38(b)). Fall protection procedures for work at heights (1926.502). Confined space entry procedures if applicable (1926.1203).

What a compliant program contains

A written document for each required program area, specific to the work your crews actually perform. Not a generic template — a program that names your equipment, your sites, your procedures. The date it was created and who created it. Evidence it was communicated to affected employees.

Where companies slip

Buying a template and filing it. A program nobody has read does not satisfy the requirement, and an inspector can tell in about five questions whether yours has been implemented or exists only on paper.

What your record has to show

The program itself, accessible to employees. Proof of communication — training records, acknowledgements, or documented safety meetings. Evidence the program is current — annual reviews, updates when work changes.

OBLIGATION 02

What training is required, and how often?

What the rule requires

Construction-specific training obligations stack quickly. Fall protection training for anyone exposed to a fall hazard of six feet or more (1926.503). Scaffold user training before first use (1926.454). Electrical safety for qualified persons (1926.97). Hazard communication for crews working with or around hazardous chemicals (1910.1200(h)). Powered industrial truck evaluation every three years for lift operators (1910.178(l)(4)(iii)).

What a compliant program contains

A matrix of which employees need which training, based on actual job tasks. Dated records of training given, including topic, trainer, and how comprehension was verified. Retraining triggers — not just calendar dates, but the circumstances that require someone to be retrained.

Where companies slip

Two failures. First, treating retraining as a calendar item when several standards trigger it on circumstance — a change in equipment, a change in procedures, or reason to believe understanding is lacking. Second, training the crew but not the supervisors, when the standards place duties on the person directing the work.

What your record has to show

Who was trained, on what, by whom, on what date, and how comprehension was established. A signature sheet with a date and a general topic is the minimum. A signature sheet with no topic listed is worth nothing.

Not sure which of these obligations apply to your operation?

Run the free assessment. Ten minutes of questions about your work, and you get a named list of the programs, trainings, and inspections you're required to hold — not a score out of a hundred.

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OBLIGATION 03

What has to be inspected, and on what cadence?

What the rule requires

Daily inspections before each use for scaffolds, ladders, and fall protection equipment (1926.451, 1926.1053). Weekly inspections of excavations (1926.651(k)). Documented inspections of powered industrial trucks daily or before each shift (1910.178(q)(7)). Regular inspection of electrical equipment and cords. Confined space atmospheric testing before each entry.

What a compliant program contains

A schedule, documented inspections with dates and findings, and corrective action records when deficiencies are found. The person conducting the inspection identified and their qualifications established.

Where companies slip

Conducting inspections but not documenting them, which legally is the same as not conducting them at all. An undocumented inspection cannot prove compliance.

What your record has to show

Inspection checklists or logs, dated and signed. Corrective action records when defects were found. Evidence that defective equipment was removed from service until repaired.

OBLIGATION 04

What does a prequalification portal ask for?

Three years of OSHA 300A summaries showing incident rates. Training records for key positions. Copies of written safety programs. Evidence of an active program — recent inspection records, closed corrective actions, current training. ISNetworld, Avetta, and similar platforms ask for the same core set, phrased slightly differently.

Most portals score on completeness and currency. A program dated 2019 with no updates scores poorly. A program from this year with no training records or inspection logs scores poorly. The combination — current programs, current training, documented inspections — is what they are testing for.

Safety Sherpa is software, not a consultancy. Our tools walk you through the decisions the regulations require and record your reasoning. The determination is yours to make. We don't write your program for you, we don't certify a program, and no software should.

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