On a large site during a shutdown, contractor workers can outnumber permanent employees several times over. Ask how many are inside the boundary right now and the answer is usually an estimate assembled from three sources that disagree.
That is a safety problem before it is a compliance problem, and it is the same underlying gap.
What the principal employer keeps
Engaging labour through a contractor transfers the employment relationship. It does not transfer everything, and the areas where the principal employer retains exposure are precisely the ones that get neglected: whether the people on site are who the contractor says they are, whether their safety inductions are current, and whether the contractor is meeting its own obligations to them.
The specific allocation of responsibility varies by province and by the nature of the engagement, and it is worth getting legal advice on your own arrangements rather than relying on a general article. What does not vary is that "the contractor handles it" is not a position that survives an incident.
Headcount should be a query
The practical fix is to tie entry to the work order. A crew is registered once against the contract that authorises them. Each worker carries induction and permit validity. Entry is refused automatically when a certificate has lapsed, rather than depending on a guard remembering.
Done that way, the questions that matter become queries rather than exercises: how many contractor workers are on site now, by contractor and by work order; which inductions expire this month; and which crews have people whose documents are not current.
Why the gate is the right control point
Every other control depends on somebody choosing to apply it. The gate is the one place where everyone passes, every day, and where refusing entry is both possible and uncontroversial.
That makes it the only place where a lapsed induction can be caught reliably. A compliance report showing expired certificates is useful; a barrier that does not open is effective.
It also makes the muster list real. During an evacuation, a list of everyone inside — permanent and contractor — is the only version that matters, and it has to come from the same place for both.
At demobilisation
The end of a contract is when problems surface: tools that went out on gate passes and never came back, access cards still active, workers still registered against a closed work order.
A demobilisation checklist that runs from the same records — passes outstanding, cards to deactivate, crews to close — turns that into a routine rather than a reconciliation nobody wants to start.
Common questions
Is the principal employer responsible for contractor workers?
Not for everything, but not for nothing either, and the specific allocation depends on province and engagement type. Safety obligations and verification of who is on site sit with the principal employer in practical terms. Take advice on your own arrangements.
How do we count contractor workers on site?
Register crews against the work order that authorises them and check them in at the gate. Headcount then becomes a query rather than an estimate assembled from several sources.
What should happen when a safety induction expires?
Entry should be refused automatically at the gate. A report showing expired certificates relies on somebody acting on it; a barrier that does not open does not.