OSHA Provides Guidance on Recordkeeping Requirements for Temporary Workers
OSHA has released an educational bulletin providing guidance on the requirements for recording injuries of temporary workers. Requirements for both the staffing agency and the host employer are outlined. OSHA regulations require that the OSHA 300 log include not only recordable injuries and illnesses to “all employees on your payroll” but also all recordable injuries and illnesses “to employees who are not on your payroll if you supervise these employees on a day-to-day basis.” 29 C.F.R. 1904.31(a). In OSHA’s view, based on the educational bulletin, this entity is generally the host employer in a temporary worker relationship and not the staffing agency, but a traditional control/supervision analysis determines the appropriate entity for recording purposes. The full educational bulletin is available here.
