- Why does a subcontractor’s entry onto the plant premises require a clear procedure?
- What should the step–by–step process for onboarding a subcontractor look like?
- How do you organize health and safety training for subcontractors?
- When does a subcontractor need a work permit?
- How should incidents involving subcontractors be documented?
- What are the most common mistakes that derail the subcontractor onboarding process?
The lack of valid contractor background checks or a clearly defined scope of work on the plant premises poses a risk of accidents, penalties from the National Labor Inspectorate, and production downtime. Allowing subcontractors onto the plant premises requires a scalable, universal procedure. Below, we’ll show you step by step how to plan for subcontractors’ access, what documents to require, and when an additional work permit is needed.
Why does a subcontractor’s entry onto the plant premises require a clear procedure?
When employees of different employers work simultaneously at the same location, pursuant to Article 208 of the Labor Code, a health and safety coordinator must be appointed, rules for cooperation in the event of an emergency must be established, and the parties must keep each other informed about accident prevention measures. This obligation arises when employees of different employers work simultaneously at the same location.
Failure to appoint a coordinator constitutes a violation of Article 283 § 1 of the Labor Code, punishable by a fine ranging from 2,000 to 60,000 PLN. Added to this is the risk of accidents data from the Central Statistical Office (GUS) for 2025 indicate that 66,733 people were injured in workplace accidents, and 189 people died as a result of such accidents.
What should the step–by–step process for onboarding a subcontractor look like?
You can effectively organize subcontractor check–ins in a few steps.
How do you schedule a subcontractor’s visit in advance?
Notifying subcontractors is the first step. This allows you to arrange the visit date, the scope of work, and the person in charge at the facility in advance. Requests of this type should be directed to a single point of contact, such as the reception system. This ensures that you know in advance how many people and companies will be arriving on a given day, making it easier to plan appropriate supervision.
What information should you gather from a subcontractor before they start work?
Before entry, it is necessary to determine which documents need to be verified based on the type of work, the associated hazards, the contract, and the facility’s procedures. There is no single set of legally required documents that applies in every case. Large facilities verify, among other things:
- confirmation from the contractor’s employer that employees have up-to-date health and safety training and the required medical certificates,
- the qualifications and certifications needed to perform specific tasks,
- a risk assessment regarding the tasks to be performed and confirmation that employees have been informed of the hazards,
- a list of individuals assigned to carry out the job.
The company may also require a liability insurance policy if this is stipulated in the contract or in its internal guidelines for working with contractors.
How can you verify whether a subcontractor is allowed to enter the facility?
Verification involves comparing the collected documents with the current status. Check whether the documents are valid, whether the scope of work matches the notification from the registration process, and whether the person in question appears on the list submitted by the external company. After verification, you can issue a pass or activate access.
Implementing a subcontractor registration system relieves the health and safety team of its heaviest burden: repetitive orientation training. At the Bunge factory in Karczew, before HRcode Wizyty was implemented, OHS specialists trained subcontractors and drivers in person, sometimes several times a day. After implementation, every person entering the premises whether an employee, subcontractor, or supplier—completes a self-guided training session via a link or QR code on a phone, tablet, or computer.
How do you organize health and safety training for subcontractors?
The subcontractor’s employer is responsible for the initial training of its own employees, but in accordance with § 2 of the regulation on occupational safety and health training, you should inform the employee of the outside company about the hazards present on your premises.
The contractor should be familiar with:
- hazards specific to your facility,
- the evacuation plan,
- and the rules for moving around the premises.
This information can be provided via e-learning. However, the employee of the external company must confirm receipt with a signature. Therefore, the system must allow for the collection of appropriate confirmation; simply completing the course or passing a test will not always be sufficient.
When does a subcontractor need a work permit?
The Regulation on General Occupational Safety and Health Provisions defines particularly hazardous work in § 80. The list is not exhaustive; it can be expanded to include other types of work involving increased risk if the specific nature of your facility requires it.
Simply classifying a task as particularly hazardous does not automatically mean that written authorization is required. The general regulations primarily require direct supervision, appropriate safety measures, and employee training.
Written authorization is required when specified by regulations governing a particular job, such as work in tanks and other hazardous confined spaces. It may also be required by the facility’s internal procedures.
The employer determines the procedure for issuing the permit, its content, the number of copies, and the authorized persons, unless specific regulations establish additional requirements. The document may include:
- the exact scope, location, and time of the work,
- identified hazards and required safety measures,
- a detailed assignment of tasks and responsibilities by name,
- required qualifications and protective equipment,
- procedures for handling emergencies,
- confirmation that the work has been completed and the area has been restored to a safe condition.
The permit is issued by the person designated in the company’s procedure. The occupational safety and health coordinator does not automatically obtain this authority simply because he or she was appointed pursuant to Article 208 of the Labor Code.
How should incidents involving subcontractors be documented?
If an accident involving an employee of an outside company occurs on your premises, the circumstances are determined by an accident investigation team appointed by the injured party’s employer that is, the subcontractor in the presence of a representative from your company. At the request of the injured party’s employer, your team may determine the circumstances and then forward the documentation.
The accident investigation team begins its work immediately after the accident is reported. The report must be prepared no later than 14 days after notification of the accident. Until the circumstances are clarified, the accident site must be secured; unauthorized persons must not be allowed access, and the position of any objects that may be relevant to determining the causes must not be altered. Machinery must not be operated unless absolutely necessary.
What are the most common mistakes that derail the subcontractor onboarding process?
There are several mistakes, including:
- Treating safety issues as obstacles to be overcome without ensuring that the contractor actually knows how to work safely.
- Allowing work to begin before safety rules have been communicated (note: this is not just a mistake; it may constitute a violation of occupational safety and health regulations and result in liability under Article 283 of the Labor Code).
- Failure to appoint a jointly designated health and safety coordinator despite multiple companies working at the same site.
- A paper–based, scattered system for tracking entries and exits, which makes it impossible to quickly verify who is on the premises in the event of an emergency.
FAQ
With a system like HRcode, orientation training can be conducted via a link or QR code, without requiring a health and safety specialist to be present for every visit. You can keep track of subcontractors’ arrivals and departures in a single, up–to–date location.
The most important ones are the attendance report that is, who is currently on the premises the evacuation list, ready for use in an emergency, and the visitor log: who entered the facility, when, and for what purpose.
If you use a dedicated solution, such as the HRcode Visits module, you can check this in real time thanks to electronic check–in and check–out tracking, without having to manually count entries in a paper logbook.
Each employer is responsible for the safety of its own employees. The subcontractor’s employer is responsible, among other things, for their training, medical examinations, qualifications, and personal protective equipment. The facility where the work is being performed is required to provide information about the hazards present there and the safety rules. If employees of different employers are working simultaneously at the same location, the employers must cooperate and appoint a health and safety coordinator. Appointing a coordinator does not relieve any of them of their own responsibilities.
Bibliography:
GUS, Wypadki przy pracy w 2025 r. – dane wstępne, 2026, https://stat.gov.pl/obszary-tematyczne/rynek-pracy/warunki-pracy-wypadki-przy-pracy/wypadki-przy-pracy-w-2025-r-dane-wstepne,3,62.html?contrast=default;
Ministerstwo Pracy i Polityki Socjalne, Rozporządzenie w sprawie ogólnych przepisów bezpieczeństwa i higieny pracy https://przepisy.gofin.pl/przepisy,4,18,39,24,2479,20211120,rozporzadzenie-ministra-pracy-i-polityki-socjalnej-z-dnia.html;
Ministerstwo Gospodarki i Pracy, Rozporządzenie w sprawie szkolenia w dziedzinie bezpieczeństwa i higieny pracy, https://isap.sejm.gov.pl/isap.nsf/DocDetails.xsp?id=WDU20041801860;
Państwowa Inspekcja Pracy, Wypadek przy pracy, https://www.pip.gov.pl/dla-pracodawcow/porady-prawne/wypadek-przy-pracy;
Państwowa Inspekcja Pracy. Prace szczególnie niebezpieczne oraz prace wymagające szczególnej sprawności psychofizyczne, https://www.pip.gov.pl/dla-pracodawcow/porady-prawne/prace-szczegolnie-niebezpieczne-oraz-prace-wymagajace-szczegolnej-sprawnosci-psychofizycznej.
Małgorzata Turowska
Gosia has a scientific mind and feels at home in the world of processes, structures, and systemic solutions. With her technological approach and HR flair, she designs solutions that allow companies to say goodbye to the chaos of spreadsheets and take their competence management to the next level.
At HRcode, she is responsible for creating and developing tools that truly support HR departments, regardless of the size of the organization.
On her blog, she shares her knowledge on how to organize HR processes, implement changes step by step, and convince organizations that digitization pays off. Always to the point, without beating around the bush.
