Multi-Employer Citation Risk After OSHA’s 2024 Walkaround Rule

Frequently Asked Questions

What is the main practical effect of OSHA’s 2024 walkaround rule on construction inspections?

It can broaden who may join the walkaround as an employee representative when that person can reasonably aid the inspection. On construction sites, that may change what concerns are raised and how site conditions are described to OSHA.

Why does the rule matter more on multi-employer construction sites?

Because OSHA may evaluate hazards that involve more than one employer. A walkaround that highlights shared conditions, repeat issues, or coordination failures can draw attention to subcontractors and the GC at the same time.

Can a general contractor be at risk even if a subcontractor created the hazard?

Yes. OSHA may examine whether the GC acted as a controlling employer and used reasonable care through inspections, follow-up, and coordination to address the hazard.

What should a GC update first after the walkaround rule change?

Start with the inspection procedure, escort assignments, and subcontractor protocols. Clear roles, parallel documentation, and defined hazard-closeout steps help reduce confusion during an inspection.

What records are most useful if OSHA inspects a shared work area?

Daily inspections, time-stamped photos, correction notices, closeout verification, and coordination meeting notes are especially helpful. Those records can show what was observed, who controlled the area, and what the GC did to require correction.