Yes, a controlling contractor can require a subcontractor to provide a safe plan of action before returning to work. A controlling employer is one with general supervisory authority over a worksite, established through contract or practice, including the authority to correct safety and health violations or require others to do so [1].

For example, a construction manager is contractually obligated to set schedules and construction sequencing, require subcontractors to meet contract specifications, negotiate with trades, resolve disputes between subcontractors, direct work, and make purchasing decisions that affect safety [2]. Even if the contract states that the manager does not have a right to require compliance with safety and health requirements, the combination of rights actually given in the contract provides broad responsibility over the site and results in the ability to direct actions that necessarily affect safety [2].

In this scenario, the construction manager can require a subcontractor to provide a safe plan of action before returning to work, as their decision directly relates to whether the subcontractor's employees will be protected from hazards [2].