Rethinking OSHA’s Multi-Employer Citation Doctrine: A Comprehensive Policy Analysis and Reform Blueprint

The National Construction Policy Institute (NCPI) has released a landmark white paper, “Rethinking OSHA’s Multi‑Employer Citation Doctrine,” which outlines a practical, legally durable framework to align accountability with actual control on complex construction sites. The paper traces the doctrine’s evolution, highlights the operational and economic costs of inconsistent enforcement, and proposes a balanced reform plan through legislation and formal rulemaking.

“Right now, well‑intentioned primes risk citations merely for helping subs get safer,” said Trent Cotney, Senior Fellow at NCPI and author of the paper. “Our recommendations would remove that chilling effect, reward proactive safety leadership, and still hold bad actors accountable.”

See what industry leaders are saying, download the white paper.