Danielle Hardy, Vice President, ABC Greater Houston
In 2025, Harris County adopted three policies that will significantly affect contractors and subcontractors bidding on and performing County construction projects: the Contractor Safety Record Policy, the Worksite Safety Policy, and the Harris County Minimum Wage Policy for Contract Workers. While the intent behind these policies is to improve safety and service quality, they also raise important questions about cost, competition, and implementation for the Greater Houston construction industry.
Associated Builders and Contractors (ABC) Greater Houston supports safe jobsites, workforce training, and responsible project delivery. At the same time, we believe public policies must be structured to encourage continuous improvement, not restrict participation, duplicate regulation, or reduce competition.
Safety Is Already a Core Industry Value
Construction safety is not new to Houston contractors. Many firms already meet and often exceed —federal and state safety requirements through internal training, compliance programs, and third-party evaluations. ABC members have a long-standing commitment to safety leadership.
A key example is ABC’s Safety Training Evaluation Process (STEP), a nationally recognized safety management system that helps contractors assess and improve their safety culture. STEP goes beyond basic compliance by focusing on leadership commitment, employee engagement, hazard identification, training, and accountability. Contractors that participate in STEP consistently outperform industry averages, with fewer recordable incidents and safer jobsites overall.
Programs like STEP demonstrate that safety outcomes improve most effectively when contractors are encouraged to invest in proactive, performance-based systems rather than being evaluated solely on past citations or administrative checklists.
Contractor Safety Record Policy: Accountability Without Context
The Contractor Safety Record Policy, effective February 1, 2026, requires both prime contractors and subcontractors to certify compliance with a range of safety and legal criteria to bid on or perform certain County projects.
While accountability is essential, ABC Greater Houston is concerned that this policy relies heavily on lookback periods and citation history without sufficient consideration for corrective actions or demonstrated improvement. OSHA already provides a comprehensive regulatory and enforcement framework and duplicating that authority at the local level adds administrative burden without clear evidence of improved safety outcomes.
These requirements may also disproportionately impact small and specialty contractors, limiting competition and reducing opportunities for otherwise qualified firms that have invested in training and compliance.
Worksite Safety Policy: Added Oversight, Added Risk
The Worksite Safety Policy introduces additional safety planning, reporting, inspections, and enforcement mechanisms, with expanded provisions taking effect in July 2026. While ABC supports compliance with all applicable safety laws, the creation of parallel inspection authority and stop-work protocols raises concerns about project delays, liability exposure, and inconsistent enforcement.
Safety is best achieved through collaboration, training, and clear expectations—not overlapping oversight that may discourage transparency or create uncertainty on active jobsites.
Minimum Wage Mandates and Market Impact
The Harris County Minimum Wage Policy for Contract Workers, which sets a wage floor of at least $21.65 per hour and adjusts annually using the MIT Living Wage Calculator, presents the greatest challenge for the construction industry.
Construction compensation is highly trade-specific and experience-driven, often including total compensation packages that account for benefits, training, and career advancement. A one-size-fits-all wage mandate fails to reflect these realities and risks increasing project costs, reducing bidder pools, and pricing small and emerging contractors out of public work.
Ultimately, higher costs and fewer bidders mean taxpayers pay more for public projects.
A More Effective Path Forward
ABC Greater Houston believes Harris County can achieve its safety and workforce goals without undermining competition or duplicating existing regulations. A more effective approach would:
• Recognize and incentivize proven safety programs like ABC’s STEP
• Rely on existing OSHA enforcement and data
• Promote education and continuous improvement
• Preserve open competition and fair market principles
Houston’s construction industry has built this region through innovation, investment in people, and a strong commitment to safety. Policies that support those efforts, rather than restrict them, will deliver the best outcomes for workers, contractors, and the public.
As these policies move toward implementation, ABC Greater Houston looks forward to working collaboratively with Harris County to uphold safety, quality, and opportunity as hallmarks of public construction in our region. With the seven-member council already established, ABC is actively pursuing a seat at the table to ensure the merit shop voice is represented.