If you sub to larger GCs, you've seen the packet. The details vary, but the asks repeat across most of them.
Before you're awarded the job
- Insurance certificates naming the GC as additional insured.
- Experience Modification Rate (EMR) and OSHA 300A summaries for the last three years.
- A written safety program, including hazard communication and fall protection, which some GCs review line by line.
- Answers on a prequalification platform, if the GC uses one.
Before your crew shows up
- OSHA 10 Construction for every worker. It is common even where the law doesn't require it. Many GCs only accept cards from the last five years.
- OSHA 30 for the foreman or site lead.
- Competent-person documentation for scaffolds, excavations or fall protection, depending on your scope.
- Equipment operator records: aerial lifts, forklifts, cranes (with NCCCO or a similar certification for crane operators).
- On NYC sites, SST cards.
On site
- Site-specific orientation sign-in sheets.
- Daily or weekly toolbox talk sign-ins. A toolbox talk generator makes that easy.
- JHA / pre-task plans.
Why fast answers matter
The sub who sends a clean PDF of every worker's cards within an hour looks like a safer bet than the one who sends blurry photos over three days. Being fast is part of being prequalified.
Why GCs ask for so much
General contractors do not ask for paperwork just to be difficult. Under federal rules the prime contractor keeps responsibility for the whole job, even for work it subcontracts: 29 CFR 1926.16 says the prime contractor and any subcontractors share responsibility for compliance with their part of the work. OSHA's multi-employer citation policy (CPL 02-00-124) explains how a GC can be cited as a "controlling employer" for hazards a sub created, if the GC did not take reasonable steps to prevent or detect them.
So when a GC asks for your training records, they are partly protecting themselves. Knowing that helps you answer in their language: show them you control your own hazards and can prove it.
The prequalification packet, item by item
Here is what is usually asked for and what good looks like.
| Item | What they want | What good looks like |
|---|---|---|
| Certificate of insurance | General liability, auto, workers' comp, umbrella; GC as additional insured | Sent by your broker within a day |
| EMR | Your workers' comp experience modification rate, usually for three years | 1.0 or below; an explanation letter if above |
| OSHA 300A | Summary of work-related injuries for three years | Signed, posted Feb 1–Apr 30, matches your EMR story |
| TRIR / DART | Incident rates calculated from your 300 log and hours worked | Calculated correctly, with hours shown |
| OSHA citations | Any citations in the last three to five years | Listed honestly, with abatement shown |
| Written safety program | Your company safety manual | Specific to your trade, signed by an owner, dated this year |
| Training records | OSHA cards and task-specific training | One PDF per worker or per crew, current |
The OSHA 300A requirement comes from 29 CFR 1904.32. Small employers in some low-hazard industries are partially exempt from recordkeeping, but construction is not one of them; most contractors with more than 10 employees must keep the log.
EMR, briefly
The EMR compares your workers' comp claims with what is expected for your size and trade. A 1.0 is average. Many GCs set a cut-off around 1.0 to 1.25, and some owners require lower. If yours is high because of one serious claim three years ago, write a short letter explaining what happened and what you changed. A clear, honest letter often keeps you in the running.
The written safety program
GC safety managers read these. A generic manual downloaded from the internet with another company's name still in the footer is worse than a short, specific one. At minimum cover: management commitment, responsibilities, hazard communication (1926.59 / 1910.1200), fall protection, ladders and scaffolds, electrical, excavation if you dig, PPE, incident reporting, disciplinary policy, and training. OSHA's Recommended Practices for Safety and Health Programs in Construction is a good free framework.
Training records GCs check most often
From the GC's side, these are the records that most often get a sub held at the gate:
- OSHA 10 Construction cards for every worker, sometimes with a "within five years" rule.
- OSHA 30 for the foreman.
- Fall protection training under 1926.503, with a written certification record showing who was trained, when and by whom.
- Scaffold training under 1926.454 for anyone on or building scaffolds.
- Aerial lift and forklift evaluations. Forklift evaluations are due at least every three years under 1910.178(l); see forklift certification every 3 years.
- Crane operator certification under 1926.1427 for anyone operating cranes covered by Subpart CC.
- First aid and CPR where required; see first aid and CPR on construction sites.
- Local cards: NYC SST cards, Nevada OSHA cards, and state public-works OSHA 10 rules. The state requirement checker lists them.
How to answer a GC request in under an hour
The difference between a sub that gets invited back and one that does not is often the response time. Set it up once:
- Keep a current packet. Insurance, EMR letter, 300A summaries, safety manual and an index, in one folder, updated every January.
- Keep training records digital. A photo of every card, front and back, attached to the worker's record.
- Group by site. When a GC asks for "everyone on the Main Street job," you should be able to export just that crew.
- Know your gaps first. Check who is missing what before the GC does. A training matrix or the OSHA Card Tracker shows gaps per site.
- Name one person who answers GC compliance requests.
If you want a deeper checklist on how to keep records ready for that request, read audit-ready training records.
Common reasons subs get rejected or held at the gate
- An expired or missing card for one worker, discovered at orientation.
- A blurry photo of a card that cannot be read or verified.
- An OSHA 10 General Industry card instead of Construction.
- A card that looks fake. Use the fake OSHA card checker before the GC does.
- A safety manual with another company's name in it.
- An EMR above the GC's cut-off with no explanation.
- No proof of site orientation or toolbox talks.
Every one of these is preventable with a little preparation.
Prequalification platforms
Many large GCs and owners use third-party prequalification platforms. You fill in a long questionnaire once, upload documents, and the platform scores you for each client. A few practical points:
- Expect a fee. Most platforms charge the subcontractor an annual subscription, often tiered by company size or number of clients.
- Answer consistently. Your EMR, 300A numbers and incident rates must match across platforms and paper packets. Reviewers notice.
- Upload once, update on schedule. Insurance renews yearly, 300A data each February, EMR when the new rating arrives. Put those dates on a calendar.
- Read the scoring. A missing written program for one hazard, such as silica or confined spaces, can drop you from "approved" to "conditional". Fix the gap, then ask for a re-review.
The platform does not replace good records. It just makes gaps more visible.
Sources and further reading
The multi-employer and recordkeeping points above come from these sources.
- 29 CFR 1926.16 and CPL 02-00-124.
- OSHA recordkeeping: 300 logs and 300A summaries.
- OSHA establishment search: public inspection history.