Subcontractor Management Program: Prime Contractor Requirements for ISN and Avetta

If you bid as a prime contractor on ISNetworld or Avetta and you ever bring subcontractors to a hiring client's site, you have a homework assignment whether you realize it or not: a written subcontractor management program that holds up under reviewer scrutiny, plus operational practice that matches the program. The MSQ on ISNetworld and the equivalent questionnaires on Avetta both ask, in some form, "do you prequalify your subs?" — and the answer is graded the same way RAVS programs are graded: by what you can document, not by what you say.

This guide is the practical buildout: the MSQ questions that drive the requirement, what a written subcontractor management program must contain, the due diligence checklist, the option to use ISN or Avetta as the prequalification tool itself, the flowdown clauses you need in your subcontract, and how to keep operational practice in lockstep with the written program so reviewers and hiring client auditors can't separate the two.

Where the Question Comes From

On ISNetworld, the Management System Questionnaire (MSQ) includes a subcontractor management section that any prime contractor sees. The questions vary by hiring client overlay but the core set is consistent: do you have a written subcontractor management program, do you prequalify subs before they mobilize, do you verify their insurance and safety statistics, do you flow down hiring client requirements, and do you have a removal procedure for non-performers. On Avetta, the same questions appear inside the Avetta Connect client overlay for primes — and clients like Shell, Chevron, and ConocoPhillips often weight this section heavily.

If you answer "yes" without a written program behind it, the next desktop audit opens a finding. If you answer "no" and you actually use subs, you've told the hiring client you bring uncontrolled risk to their site. Either way, the path forward is the same: build a program, run it, document it. For the broader picture of how grading works, start with ISNetworld grade requirements.

The Subcontractor Management Lifecycle

What a Written Subcontractor Management Program Must Contain

This is the document an ISN RAVS reviewer or an Avetta reviewer will read first. It is not a generic template you copied off the internet. It must address each of the elements below, in your own voice, with your company's specific procedures and named owners.

1. Purpose, Scope, and Definitions

State that the program applies to all subcontractors performing work on behalf of your company at hiring client sites, regardless of contract size. Define subcontractor, sub-tier subcontractor, independent contractor, and vendor/supplier distinctly — reviewers note when those terms get used loosely. State which roles within your company own the program (typically the HSE Manager and a Procurement or Contracts Manager).

2. Selection and Approved Subcontractor List

Describe how a subcontractor gets added to your approved list. The trigger is usually a project need; the gating activity is prequalification. State that no subcontractor mobilizes without prequalification on file. Maintain an approved subcontractor list — a real spreadsheet or system, with status, expiry, and category — that an auditor can look at.

3. Prequalification Criteria

Spell out the criteria a subcontractor must meet before approval. The standard set:

• Three years of OSHA 300/300A logs and computed TRIR / DART rates within thresholds you publish (commonly TRIR < 1.5 and EMR < 1.0 for industrial work; thresholds may track your hiring client's requirement).
• Current EMR letter on carrier letterhead.
• Written safety programs covering the topics applicable to the sub's scope (LOTO, Confined Space, Fall Protection, Hot Work, Excavation, Respiratory Protection, BBP, HazCom, etc.).
• Drug and alcohol program with a named consortium administrator.
• Insurance certificates meeting your minimums and your hiring client's minimums (whichever is greater), with the additional insured, primary and non-contributory, and waiver of subrogation endorsements you require.
• Training records demonstrating their crews are trained on the tasks they'll perform.
• Disclosure of citations, fatalities, and major incidents in the last three to five years.

4. Verification Method: ISN, Avetta, or In-House

This is where you choose the tool. Three legitimate options:

• Use ISNetworld for your own subs. ISN sells primes the ability to invite their subs into ISN, review their RAVS and grades, and use ISN as your prequalification system of record. This is the most common approach for primes already on ISN, and it is what the larger oil-and-gas owner-operators expect. Tier fees are the contractor's responsibility — see ISNetworld tier fees explained.
• Use the Avetta Marketplace for your own subs. Avetta offers an equivalent path: you can require your subs to register on Avetta and inherit Avetta's prequalification grading. See the Avetta Connect requirements guide for how the platform layers requirements per client.
• Run an in-house prequalification process. Acceptable as long as your written program defines the documents collected, the review checklist, the approver, the file location, and the renewal cycle. In-house works for small primes with stable sub rosters; it gets brittle fast as you scale.

Whichever you pick, the written program must say which one and stay consistent. Mixing approaches without documenting the rule is a finding.

5. Flowdown Clauses in the Subcontract

Every subcontract must flow down the obligations the hiring client placed on you. At minimum:

• Insurance flowdown: limits, additional insured (typically CG 20 10 + CG 20 37), primary and non-contributory, waiver of subrogation, A.M. Best rating minimum.
• Indemnity: sub indemnifies prime and prime's hiring client to the extent permitted by law in the state of performance. Watch anti-indemnity statutes — Texas Oilfield Anti-Indemnity Act, Louisiana Oilfield Anti-Indemnity Act, and similar.
• Safety flowdown: sub agrees to comply with the prime's HSE program and the hiring client's site-specific HSE rules.
• Site rules: PPE, drug testing, badging, orientation, JHA process.
• Right to remove: prime's right to remove the sub for safety, performance, or compliance reasons, with stated process.
• Audit rights: prime's right to audit the sub's records during the contract and for a defined period after.
• Subcontracting restriction: sub may not further subcontract without written approval.

6. Pre-Mobilization Meeting

Before any sub mobilizes to a hiring client site, conduct and document a pre-mobilization meeting that covers scope, schedule, site rules, JHA review, emergency response, and the documents the sub must produce on day one. The meeting record should list attendees with signatures, topics covered, and any open items. Auditors love this artifact — it is the cleanest proof your program operates.

7. Document Verification Before Mobilization

Your written program must say: no document on file, no mobilization. Specifically, before the sub's first day:

• Current COI with required endorsements naming the hiring client and prime as additional insureds.
• Drug program proof (consortium membership letter or equivalent).
• Current EMR letter.
• Training rosters for the specific scope of work.
• JHA for the planned tasks, signed by sub crew.
• Hiring client orientation completion records if applicable.

8. Onsite Performance Monitoring

Describe how you observe the sub once they're working. Common elements: daily safety walks, JHA spot checks, near-miss reporting expectations, weekly toolbox talks, monthly safety meetings, and incident reporting requirements. State whether your supervision includes the sub or whether the sub provides their own competent person, and either way how the prime verifies sub competency.

9. Performance Reviews

Annual or per-project performance reviews of each sub: did they hit safety, quality, schedule, and compliance metrics? Document the review, communicate findings to the sub, and record actions. This is what feeds the renewal-or-remove decision at the end of the cycle.

10. Removal Procedure

Spell out the trigger and process for removing a sub: serious safety violation, repeated minor violations after written notice, document expirations not cured within a stated grace period, fraudulent submissions, criminal acts. State the approver, the documentation required, and notification to the hiring client when applicable. Reviewers look for this section by name.

11. Recordkeeping and Retention

State retention periods (typically the longer of OSHA recordkeeping requirements, contract terms, and statute of repose in the state of performance — commonly 5 to 10 years), where records are kept, who owns them, and how they're produced on request. Hiring client audit rights typically extend two to five years past project completion.

Due Diligence Checklist for Each New Sub

The ISN-as-Tool-for-Subs Option in Detail

If you're already on ISN, using ISN as your subcontractor prequalification tool is the cleanest path because it shares the same reviewer culture, the same RAVS standard, and the same grading transparency your hiring clients already trust. You invite your subs into ISN under your account view, they pay their own subscription tier, you get visibility into their grade, RAVS, and document expiries through ISN's prime portal. It scales because ISN is keeping the data current, not your team. The trade-off is cost transparency to your sub — they will quickly understand they're paying ISN because you said so, and small subs sometimes push back on the fee. That is a contract negotiation, not a program flaw.

For first-time setup mechanics on ISN itself, see our first-time ISNetworld setup checklist. If you're comparing ISN to other platforms because some of your subs may already be on a different system, see Veriforce vs ISNetworld and the BROWZ compliance portal overview.

Why the Written Program Is Graded Separately From Practice

This is the single most misunderstood point in subcontractor management on ISN and Avetta. Reviewers grade your written program the way they grade any RAVS program: against a checklist of required topics, owners, and procedures. They are not visiting your sites. They are reading your document. If the document is missing the removal procedure, the grade drops, even if you actually do remove non-performers in real life.

Conversely, hiring client auditors verify operational practice: do the pre-mob meeting records exist, are COIs on file before mobilization, were performance reviews conducted last year. They are not reading your manual page by page; they are checking whether the manual matches reality.

The trap: contractors with great operational practice but a thin written program get downgraded by RAVS, and contractors with a perfect written program but no operational evidence get findings from hiring client audits. The fix is mechanical — the written program describes exactly what your operations actually do, and your operations leave the paper trail the written program promises. The two halves are useless apart and bulletproof together.

Common Mistakes That Drop Grades

• "We don't use subs" on the MSQ when your project files show three subs on the last job. Reviewers cross-check, and the inconsistency itself is the finding.
• Generic flowdown clause that says the sub will "follow all applicable laws" without enumerating insurance, indemnity, safety, and removal.
• Missing removal procedure in the written program even when you actually have one in practice.
• No approved subcontractor list as an artifact — operationally you know your subs, but no document exists.
• Pre-mobilization meeting referenced in the program but never documented in practice.
• Inconsistent verification approach — some subs prequalified through ISN, others not, with no rule about which path applies when.

Run It as a System, Not as Paperwork

The contractors who pass subcontractor management reviews without drama treat it as a system: written program owned by named people, prequalification platform consistently applied, flowdown clauses in every subcontract template, pre-mob meeting as a standing checkpoint, document verification gated before mobilization, performance reviews scheduled, removal triggers defined and used. The reviewers are pattern-matching to that system. When they find it, the grade reflects it.

PrequalPilot tracks your subs' COIs, EMR letters, training records, and prequalification status across ISNetworld and Avetta in one dashboard, with expiry alerts before mobilization windows. See pricing.