A general contractor called me a few years ago. He was frustrated. One of his subcontractors had been on site for two weeks and had already had a near-miss — a worker nearly fell through an unguarded floor opening. The GC couldn't understand it. He had a safety program. His own crew was trained. His equipment was maintained. Everything was in order.
But here's what he had missed: none of that covered the subcontractor.
He had no prequalification process. No agreement outlining OHS expectations. No one was monitoring the sub's safety performance on site. And when things went sideways, he had no documentation to show he had done anything to prevent it.
Let's talk about procurement and contractor management — because in the construction industry, this is one of the most overlooked elements of a solid safety program, and one of the most consequential.
Why This Element Exists
When you bring a contractor or service provider onto your worksite, two things happen simultaneously:
They may be exposed to hazards your workers deal with every day — hazards you already know about and have controls for. But your contractor might not.
And at the same time, they may introduce entirely new hazards that your own team has never encountered. New equipment. Different work methods. Chemical exposures. Work at height on a section of the building your crew hasn't touched yet.
That's the double-edged risk. And it is your responsibility — as the constructor or employer — to address both sides of it.
The Occupational Health and Safety Act (OHSA) is clear that constructors must ensure the health and safety of every person on the project, not just direct employees. That responsibility does not pause when the work is being done by someone else's crew.
The Three Things Your Program Must Do
Effective procurement and contractor management comes down to three activities: selecting, monitoring, and evaluating. Most organizations do one of these reasonably well. Very few do all three — and even fewer can prove it.
1. Selecting
Selecting is about setting expectations before the work begins. Before a contractor ever sets foot on your site, you should have a clear process for vetting their safety record, reviewing their documentation, and communicating your OHSMS requirements. What do you expect from them in terms of hazard assessments, safe work procedures, and incident reporting? Who needs to sign off on what? That conversation should happen before the contract is signed, not after the near-miss.
2. Monitoring
Monitoring is what you do while the work is happening. This means actively observing and reviewing the contractor's OHS performance on site — not just assuming they're doing the right thing because they seemed organized at the prequalification stage. Set your audit and inspection criteria. Define who does the monitoring, how often, and what happens if there's non-compliance. If your procedure says monthly site inspections, there needs to be a record showing those inspections happened.
3. Evaluating
Evaluating is the step most organizations skip entirely. Once the job is done, sit down and formally assess how the contractor performed. Did they follow your OHSMS requirements? Were there incidents or near-misses? Would you hire them again? This evaluation should be documented and kept on file. It becomes part of your prequalification criteria the next time they bid on your work.
Here's the insight that changes how you think about this: contractor management is not a paperwork exercise. It's a communication system. You are building a relationship structure that ensures everyone on your site — regardless of who signs their paycheque — understands your safety expectations and is accountable to them.
What Your Policy and Procedure Actually Need to Say
If you're working toward COR 2020 certification, Element 4 will require you to demonstrate this through documented policy, procedure, and evidence of implementation.
Your policy statement needs to be specific to this element. Not a generic health and safety policy reworded to mention contractors. It should reflect senior management's direct commitment to managing procurement and contractor relationships safely — and it should stand on its own.
Your procedure needs to answer the who, what, when, where, why, and how for each stage of the process. The COR 2020 Audit Tool walks through six specific procedure requirements. Make sure all six are addressed and that your written procedure matches what actually happens in the field. That alignment — between what your procedure says and what your people do — is exactly what an auditor is looking for.
Your implementation evidence needs to show three complete contractor packages: the prequalification documents, the signed agreement, and records of monitoring and evaluation activities — for three separate contractors. Blank forms mean nothing. Completed records mean everything.
The Piece Most Companies Miss
Here's where I'll be direct with you.
Many organizations I've worked with have a policy. Some have a procedure. But almost none of them have a formal agreement with their contractors and service providers.
Not a verbal understanding. Not an email thread. An actual agreement that outlines how the contractor will be monitored and evaluated, how they will monitor their own workers, how changes that affect health and safety will be communicated, and what the consequences are for non-compliance.
That agreement is your evidence that expectations were set. It's your protection when something goes wrong and someone asks what you did to prevent it. And in the event of a Ministry of Labour inspection or a fatality investigation, that document — or the absence of it — will matter more than you can imagine.
One practical tip: include a revision log and document control system for every policy, procedure, and form in your contractor management program. The COR 2020 standard means "current" as in dated within the last year. Reviewers are checking. Make it easy for them to see that your materials are live, updated, and in use.
This Is Where You Start
If you're building your contractor management program from scratch, don't try to boil the ocean.
Start with a list. Think about your scope — the full scope of your organization's operations — and write down every contractor and service provider you typically hire. Snow removal. Equipment repair. Electrical. HVAC. Lifting device inspections. Fire system testing. Consultants. All of them.
That list is your starting point. From there, you can build the prequalification process, draft the agreement template, and establish your monitoring and evaluation system one contractor type at a time.
The goal isn't a perfect program on day one. The goal is a real program — one that you can actually implement, that your team understands, and that you can demonstrate to an auditor with completed documentation.
The contractor you hired to get the job done faster should not be the reason you're sitting across from a Ministry investigator. With the right program in place, you won't be.
The WorkSafe Sounds team is a group of health and safety consultants with over 20 years of combined experience in Ontario's construction and industrial sectors. We help supervisors, safety professionals, and construction companies build safer workplaces through practical training and consulting.