When prime contractors outsource warehousing, drayage, last-mile delivery, or rail transloading, safety gaps often travel with the contract. Under the OSHA’s Multi-Employer Citation Policy (Multi-Employer Citation Policy, 1999), host employers can be cited alongside contract employers when hazards affect subcontracted workers, making “it’s the vendor’s job” a costly myth. Occupational Safety and Health Administration Temporary Worker Initiative further clarifies joint responsibility for training, hazard communication, and PPE when staffing agencies or third-party providers place workers in your logistics flow (Protecting Temporary Workers, n.d.); (Occupational Safety and Health Administration, 2014); (National Institute for Occupational Safety and Health [NIOSH], 2022).

National data show why this matters. In 2023, the United States recorded 5,283 fatal work injuries, with transportation and warehousing among the highest-risk sectors; transportation incidents remain a leading cause of death on the job (U.S. Bureau of Labor Statistics [BLS], 2024). On the highway, large truck and bus crash facts (Federal Motor Carrier Safety Administration [FMCSA], 2023) and Pocket Guide highlight the human and financial stakes of carrier non-compliance across driver qualification, hours of service, and vehicle condition risks frequently pushed into subcontracted lanes (Federal Motor Carrier Safety Administration [FMCSA], 2024a; FMCSA, 2024b).

For construction firms, subcontracted material haul-offs, crane support trucking, and laydown-yard staffing introduce multi-employer exposure. Worksite-specific training, equipment checks, and coordination are required, and contract employees must follow host safe-work practices per OSHA’s process safety and contractor provision where applicable (Occupational Safety and Health Administration [OSHA], 2022). Transportation operations that outsource routes must ensure that motor carriers and owner-operators meet 49 CFR requirements; when carriers perform shipper functions, they assume the shipper’s HMR duties, underscoring the need for clear role delineation in contracts and job hazard analyses (FMCSA, 2024); (General Information, Regulations, and Definitions, 2025) . General industry warehousing that relies on temporary or staffing-agency labor must deliver site and task-specific training in a language workers understand and maintain coordination on incident reporting and recordkeeping (OSHA, n.d.; (OSHA, 2023); (OSHA, n.d.).

Environmental obligations travel with the load. Hazardous waste shipment require accurate manifests and transporter signatures; generators, transporters, and TSDFs each hold defined responsibilities that cannot be outsourced away (Standards Applicable to Transporters of Hazardous Waste, 2025); (Manifest Requirements Applicable to Small and Large Quantity Generators, 2025). In rail logistics, FRA’s Roadway Workers Protection Rules mandate on-track safety programs for employees and contractors alike, making contractor integration and protection planning non-negotiable (U.S. Department of Transportation, Federal Railroad Administration, 2025).

Disaster seasons further stress subcontracted logistics. FEMA’s Supply Chain Resilience Guide urges public-private planning to keep lifelines moving; private companies that pre-map vendor networks, clarify decision rights, and align on waivers and routing during disruptions recover faster and safer (Federal Emergency Management Agency [FEMA], 2019); (Levin, 2022).

A practical path forward is to anchor subcontracted logistics in the four safety pillars. Safety and health training must be jointly planned and verified before work starts and whenever tasks change. Hazard prevention and control should extend to carrier vetting, equipment inspections, and proper packaging and placarding under the HMR. Worksite analysis has to include vendor operations, with shared near-miss learning and audits. Management commitment and employee involvement should appear in contracts, KPIs, onboarding, and standing meetings that keep vendors part of your safety culture. Key Safety LLC can help with document development for start-up projects to embed these controls in contracts and SOPs, provide Service on Demand to triage issues like carrier qualification or incident response, and deliver Regular Consultation Service to sustain multi-employer coordination across construction, transportation, general industry, and environmental programs.

Subscribe to the Key Safety newsletter for practical checklists and regulatory updates that keep subcontracted logistics safe and compliant.

References

Levin, A. G. (2022). FEMA’s role in logistics management for disaster response (CRS Report No. IF12239). Congressional Research Service. https://crsreports.congress.gov/crs_external_products/IF/PDF/IF12239/IF12239.3.pdf

Standards Applicable to Transporters of Hazardous Waste, 40 C.F.R. § 263 (2025) https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-263

Standard for Manifest Requirements Applicable to Small and Large Quantity Generators, 40 C.F.R. § 262(B) (2025). https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-262/subpart-B

Federal Motor Carrier Safety Administration. (2023, December 22). Large truck and bus crash facts 2021 (Annual report). U.S. Department of Transportation. https://www.fmcsa.dot.gov/safety/data-and-statistics/large-truck-and-bus-crash-facts

Federal Motor Carrier Safety Administration. (2024, July 31). Pocket guide to large truck and bus statistics. U.S. Department of Transportation. https://www.fmcsa.dot.gov/safety/data-and-statistics/commercial-motor-vehicle-facts

Federal Motor Carrier Safety Administration. (2024, June 12). How to comply with federal hazardous materials regulations (Overview webpage). U.S. Department of Transportation. https://www.fmcsa.dot.gov/regulations/hazardous-materials/how-comply-federal-hazardous-materials-regulations

U.S. Department of Transportation, Federal Railroad Administration. (2025, March 6). Roadway worker protection. https://railroads.dot.gov/railroad-safety/divisions/roadway-worker-protection

Federal Emergency Management Agency. (2019). Supply chain resilience guide. U.S. Department of Homeland Security. https://www.fema.gov/sites/default/files/2020-07/supply-chain-resilience-guide.pdf

National Institute for Occupational Safety and Health. (2022). NIOSH practices in occupational health program effectiveness: State of the science and research needs (DHHS Publication No. 2022-126). Centers for Disease Control and Prevention. https://www.cdc.gov/niosh/docs/2022-126/pdfs/2022-126.pdf

Occupational Safety and Health Administration. (1999, December 10). Multi-Employer Citation Policy (CPL 02‑00‑124). U.S. Department of Labor. https://www.osha.gov/enforcement/directives/cpl-02-00-124

Occupational Safety and Health Administration. (2014, July 15). Policy Background on the Temporary Worker Initiative Posted. U.S. Department of Labor. https://www.osha.gov/laws-regs/standardinterpretations/2014-07-15

Occupational Safety and Health Administration. (2022, February 16). Employer responsibilities and contractor responsibilities under the PSM standard (Letter of interpretation). U.S. Department of Labor. https://www.osha.gov/laws-regs/standardinterpretations/2022-02-16 .

Occupational Safety and Health Administration. (n.d.). Employer responsibilities. U.S. Department of Labor. https://www.osha.gov/workers/employer-responsibilities

Occupational Safety and Health Administration. (n.d.). Protecting temporary workers. U.S. Department of Labor. https://www.osha.gov/temporaryworkers

Occupational Safety and Health Administration. (n.d.). Recordkeeping – Overview. U.S. Department of Labor. https://www.osha.gov/recordkeeping

Standard for General Information, Regulations, and Definitions, 49 C.F.R. § 171 (2025). https://www.ecfr.gov/current/title-49/subtitle-B/chapter-I/subchapter-C/part-171

U.S. Bureau of Labor Statistics. (2024, December 19). National census of fatal occupational injuries in 2023(USDL‑24‑2564). https://www.bls.gov/news.release/pdf/cfoi.pdf