Who Is Responsible for Subcontractor Compliance?
Several commenters questioned who would be responsible for ensuring subcontractor compliance with drug and alcohol testing. Specifically, they asked if certificated repair stations or regulated employers (air carriers) would be held responsible for any and all subcontractors at any tier. Prime Turbines commented to both the NPRM and the SNPRM, expressing concern that it will be held liable for all tiers of contract work. Another commenter, ChevronTexaco, stated its current practice is to audit its contractors’ drug and alcohol prevention programs. ChevronTexaco also specifies in its contractual agreements that contractors must audit subcontractors’ programs because it is common for them to have several tiers of subcontractors. ChevronTexaco was concerned the proposal “would cascade employer responsibility for auditing drug and alcohol programs to ALL these subcontractors with which we have no direct business or contractual relationship.” Similarly, UTC questioned whether a third tier
Related Questions
- Who is responsible for auditing medical director services and compliance with the medical director policies and procedures?
- What type of ongoing compliance is required once a contract is awarded to a primary or assigned subcontractor?
- Is Environmental Health and Safety ultimately responsible for ensuring my compliance?
