Safety Tidbit #10: Recording and Recordkeeping for Temporary Workers

So what does OSHA want to know about the injuries or illnesses in our workplaces?  You need to understand, that the recordkeeping OSHA that has put in place is a trending tool.  It enables them to trend injuries in the workplace nationally.  That is why they conduct a data call each year (well either OSHA and/or Bureau of Labor Statistics) and requests the summary records completed by the employer.  But also, OSHA wants to hear about more severe cases (fatalities, amputations, loss of an eye, hospitalizations).  They can then decide to intervene to ensure the employer is conducting a thorough accident investigation and implementing controls to prevent further injuries.  So let’s make the broad assumption that we all know exactly how to complete the OSHA 300 log and when to call OSHA.  What happens when the injured worker is a temporary worker? They’re people too, right?

My question is simple. Why is the safety of the temporary worker any different than that of a full-time or part-time worker? Now you might argue that the temporary agency provides their worker’s compensation. Worker’s compensation gets the worker healthy and takes care of them while they are convalescing. The agency does not know the work conditions, may not know the appropriate training necessary for your specific site and ultimately did not have anything to do with worker’s day-to-day activities.  The agency is really only taking care of the Human Resources portion for the worker.  The safety of the worker still rests firmly with the gaining employer. 

The employer may contract that certain general safety and health training and physical requirements be met prior to the temporary worker coming onsite. However, the employer must give site specific training. For instance, a temporary worker may need to be able to operate a forklift but the employer must ensure they can operate their forklifts under their conditions and verify their proficiency.  Or, for a particular employer the temporary worker must be able to wear a respirator, so the agency ensures they are medically qualified. The agency may even provide fit-testing for a particular respirator and some training.  The employer then must incorporate that information into their company's respirator program and validate the adequacy of the respirator and filters for their hazards, and still provide site-specific training on their expectations with respect to respirator use.

Bottom line, if you direct the activities of temporary workers, you need to record their injuries on your OSHA 300 log.  And, heaven forbid, contact OSHA if the injury is severe enough to warrant the call to the OSHA office (1904.31).  The employer is solely responsible for the safety of their work sites. Safety for all of the workers on the site (Full-time, part-time, permanent, temporary, or for that matter brown, black, blue or green).