OSHA Issues Recordkeeping Guidance for Temporary Staffing Firms

As part of the previously announced temporary worker initiative, the Occupational Health & Safety Administration (OSHA) will be releasing guidance documents pertinent to issues in the temporary staffing industry. Recently, the first of these documents was released and focused specifically on recordkeeping requirements. OSHA requires all employers to maintain an OSHA 300 log. This log is used to record all injuries and illnesses that have medical treatment above and beyond first aid, need modified duty or require days away from work. At the end of each year, the number of injuries is totaled and the number of hours worked is added onto the OSHA 300A form, which is posted from February 1–April 30 of the following year. The OSHA 300 log and 300A form are used to calculate incident rates, which are often used for bids or internal loss trending. Who’s responsible for recording temporary worker injuries? The OSHA standards state that whoever is providing the day-to-day supervision is the employer that needs to record those injuries. Day-to-day supervision occurs when the “employer controls conditions presenting potential hazards and directs the worker’s activities around, and exposure to, those hazards.” In most cases, this is the host employer. Even in cases where the temporary staffing agency has an on-site supervisor, since the host client controls the conditions, the responsibility of recordkeeping would still fall on the host client. Continuing with OSHA’s previous statements, the guidance document reminds temporary staffing agencies that while they’re generally not responsible for the actual recordkeeping, it’s still their responsibility to ensure injuries are being properly reported and recorded. The full document issued by OSHA can be found here. –