A Serious Incident That Triggered an OHS Demand for Proof of Subcontractor Safety

We were growing quickly and starting to take on larger, more complex work. We had just gotten COR (Certificate of Recognition) certified, and we also had a long-term supervisor step into a safety role after completing their NCSO program. From my perspective, we were in a good place.

As our projects expanded, so did the number and type of subcontractors on our sites. I was aware that when there were multiple employers on site, there needed to be a prime contractor — and in our case, that was us.

What I didn’t fully understand was how far that responsibility actually extended when it came to subcontractors. I knew they had to meet safety requirements, and at the time, that seemed like a reasonable assumption based on how we had been operating.

As we brought on more subcontractors across different types of work, I started to realize I wasn’t fully clear on what we were actually expected to be verifying. From talking to other business owners running similar operations, it was a common way of operating at that stage.

Then I heard about a friend. Similar size company, similar type of work. He had an incident on one of his sites involving a subcontractor, and when Alberta OHS got involved, he ended up facing charges as the business owner.

That stuck with me. It wasn’t that he didn’t care about safety — he just assumed the subcontractor had it handled.

Could that happen to me?

This is based on a real situation. Certain details have been modified to protect privacy while preserving the accuracy of the events.

We had strong supervisors who understood the safety requirements of the work they were doing. That wasn’t where the gap was.

The challenge was understanding how Alberta’s Occupational Health and Safety legislation actually applied across multiple employers — and how that needed to be managed as we brought more subcontractors onto our sites.

We brought in a fractional safety management company — experienced consultants who worked with us about one day a week, providing senior-level support on retainer—without adding a full-time safety employee to payroll.

Part of what they helped us put in place was a consistent system to evaluate and manage subcontractors before they stepped on site, including prequalification, verification of competency, and ongoing monitoring.

At the time, I thought this program was overkill.

Not long after that, we had an incident. One of the subcontractors on site had a serious head injury because he wasn’t wearing a hardhat. It happened quickly — the kind of situation that doesn’t seem significant until it is — and then Alberta OHS got involved.

They weren’t just asking what happened — they gave us a client contact report with a demand notice. They wanted to see how we were managing safety across the entire worksite, including subcontractors, and how we were coordinating multiple employers operating at the same site.

We were asked to provide:

• Contractor prequalification and selection records
• Proof of training and competency verification
• Site orientations and onboarding documentation
• Hazard assessments related to the work
• Records showing how work was supervised and coordinated
• Documentation of how contractor safety performance was monitored
• Any records of non-compliance and corrective actions
• Our incident investigation documentation

Because we had been working with that safety consultant company, we were able to demonstrate how subcontractor safety had been evaluated, verified, and managed across our worksite.

In the end, we were not held responsible for the incident.

That was a level of relief I can’t really describe.

Looking back, one thing stands out clearly. At the time, I thought this program was overkill. I didn’t realize it was the only thing protecting my business — and me as the owner.

It also changed how I think about subcontractors. Bringing them onto our site didn’t reduce responsibility — it increased it. If they’re part of the work, accountability still sits with us under Alberta law.

Bringing in outside support wasn’t about adding paperwork. It was about making sure our systems kept pace with how quickly the scope of our work was expanding — and that if something happened, we could prove we had done what was required.

Executive Takeaways

• I assumed subcontractors were managing their own safety — but that didn’t remove my responsibility under Alberta’s Occupational Health and Safety Legislation
• As we hired more employers on our sites, the level of coordination and oversight expected from us increased
• When Alberta OHS got involved, they didn’t just look at the incident — they looked at how the entire worksite was being managed
• I was so relieved that we built an effective contractor compliance program with all needed documentation that helped us to avoid a fine
• Expert advice really made a huge difference in the outcome of this event

Could You Prove It Today?

If you’re relying on subcontractors across your work, it may be worth taking a closer look at how that responsibility is being managed — especially before you’re asked to demonstrate it.

A structured Safety System Assessment through Safety Ahead provides a clear view of how your current approach aligns with Alberta OHS expectations — and where gaps may exist.

Dealing with an OHS demand after a serious incident? We help Alberta contractors respond quickly and get things back on track.

Request a Safety Consultation