Prime contractor duties in BC
Who becomes prime contractor on a BC site, what section 24 of the Workers Compensation Act requires, and the Notice of Project and coordination rules in Part 20.

On most BC construction sites there's more than one employer at work: the GC's crew, an electrician, a framer, a drywall sub, a crane outfit. When that happens, the law needs one party to hold the whole picture together on health and safety. That party is the prime contractor, and the role is easy to accept without fully reading what it involves. This guide sets out prime contractor duties as written in the Workers Compensation Act and WorkSafeBC's Occupational Health and Safety Regulation, who ends up holding the role, and what a small or growing contractor should have in place before signing on as prime. It's general information, not legal advice.
Who is the prime contractor?
The Workers Compensation Act defines a multiple-employer workplace as one where workers of two or more employers are working at the same time. For that workplace, the prime contractor is either:
- the directing contractor, employer or other person who enters into a written agreement with the owner to be the prime contractor, or
- if there's no written agreement, the owner.
Two consequences follow. First, an owner who hires several contractors and never signs a prime contractor agreement keeps the role by default. Second, a contractor who signs that agreement takes it on in full. WorkSafeBC has made the same point in its own guidance: verbal understandings cause confusion, and without a written agreement the owner retains responsibility.
The OHS Regulation adds one more condition (section 20.1A): a person who agrees with the owner to be the prime contractor must be qualified.
Core prime contractor duties under the Act
Section 24 of the Workers Compensation Act is short. The prime contractor of a multiple-employer workplace must:
- ensure that the activities of employers, workers and other persons at the workplace relating to occupational health and safety are coordinated, and
- do everything that is reasonably practicable to establish and maintain a system or process that will ensure compliance with the OHS provisions and the regulations in respect of the workplace.
The same section puts a duty on every employer on the site: each must give the prime contractor the name of the person it has designated to supervise its workers there. And section 25 requires the owner to give the prime contractor the information the owner knows that's needed to identify and eliminate or control hazards, which is where hazardous materials surveys and site information come in.
Construction-specific duties in the OHS Regulation
Notice of Project
Under section 20.2, the owner or the prime contractor must ensure WorkSafeBC receives a written notice of project at least 24 hours before work begins, and post a copy on site, if any of these apply:
| Trigger | Threshold |
|---|---|
| Estimated total cost of labour and materials | Exceeds $100,000 |
| Engineered design | All or part designed by a professional engineer (other than pre-engineered or pre-manufactured components) |
| New erection, major alteration, structural repair or demolition | A building more than 2 storeys or 6 m high; a bridge; a retaining structure over 3 m; a silo, chimney or similar over 6 m |
| Special environments | Work in a cofferdam or compressed-air environment |
| Trenches and excavations | A trench over 30 m long, or an excavation other than a trench over 1.2 m deep |
Work involving moderate- or high-risk asbestos activities, or significant disturbance of lead-containing material, needs a separate hazardous-substances notice at least 48 hours before that activity starts (section 20.2.1).
Coordination and the qualified coordinator
Section 20.3 requires each employer to tell the owner or prime contractor in advance of anything likely to create a hazard for another employer's workers. Where overlapping or adjoining work of two or more employers creates a hazard and the combined workforce is more than five, the prime contractor must:
- appoint a qualified coordinator to ensure health and safety activities are coordinated, and
- keep up-to-date information readily available on site: the coordinator's name, a posted site drawing showing layout, first aid location, emergency transportation and the evacuation marshalling station, and a set of construction procedures to protect workers.
The coordinator's duties include informing employers and workers of the hazards created and making sure those hazards are addressed for as long as the work goes on. Each employer must name a qualified person responsible for its own site health and safety activities.
A practical checklist before you agree to be prime
- Get the agreement in writing, and read what the owner is actually handing over.
- Confirm who files the Notice of Project and diary the 24-hour (or 48-hour) deadline.
- Get the owner's hazard information, including any hazardous materials survey, before mobilizing.
- Collect each sub's designated supervisor and safety contact in writing.
- Name your qualified coordinator and give them time on the schedule to do the job.
- Post the site drawing and emergency information on day one.
- Run orientations and coordination meetings and keep the records. WorkSafeBC's guidance suggests documentation like initial safety meeting notes, inspection and investigation reports, first aid records and orientation records.
- Check each sub's WorkSafeBC standing with a clearance letter, as covered in our clearance letter guide.
Prime contractor duties as a growth step
For a trade contractor moving up to small general contracting, being prime contractor is often the first real test of whether the company's systems can handle it. Owners and GCs notice who runs a coordinated site, and some also ask about a formal safety management system; our guide to COR certification in BC explains WorkSafeBC's voluntary Certificate of Recognition program.
We don't run safety programs or audits. What we help with is the business side of that step up: operations, staffing and process so the company can carry larger work without the wheels coming off. That's the Construction Industry pillar, and when a growing company needs someone in the seat temporarily, our FAQ explains fractional leadership, including temporary or part-time field supervision. Start with a free conversation.
Frequently asked questions
Who is the prime contractor on a BC construction site?
The directing contractor, employer or other person who enters into a written agreement with the owner to be the prime contractor, or, if there's no written agreement, the owner.
What are the prime contractor's main duties?
Under section 24 of the Workers Compensation Act, the prime contractor must ensure occupational health and safety activities at the workplace are coordinated, and do everything reasonably practicable to establish and maintain a system or process that ensures compliance with the OHS provisions and regulations.
When is a Notice of Project required in BC?
Among other triggers, when the estimated total cost of labour and materials exceeds $100,000, when part of the project is designed by a professional engineer, or when a worker may enter a trench over 30 m long or an excavation over 1.2 m deep. It must reach WorkSafeBC at least 24 hours before work begins.
When must a prime contractor appoint a qualified coordinator?
When overlapping or adjoining work of two or more employers creates a hazard and the combined workforce at the workplace is more than five.
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