Under OSHA Recordkeeping regulation (29 CFR 1904), covered employers are required to prepare and maintain records of serious occupational injuries and illnesses, whether they are direct employees or those working through a staffing agency. According to OSHA, the agency’s new Temporary Worker Initiative will use enforcement, outreach, and training to make sure that temporary workers are protected in the workplace.

The agency announced the initiative to raise awareness and compliance with requirements that temporary workers receive the same training and protection that existing workers receive. Part of that effort is a new educational resource that focusing on requirements for injury recording of temporary worker injuries and illnesses. The measures were prompted in part by OSHA investigations in recent months into reports of temporary workers suffering serious or fatal injuries, many of which occur within their first few days on the job.

The new Recordkeeping Bulletin (https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf) explains the requirements for both the staffing agency and the host employer and addresses how to identify who is responsible for recording work-related injuries and illnesses of temporary workers on the OSHA 300 log.

Covered employers are required to record on that log any recordable injuries and illnesses of all employees on their payroll, whether those workers are classified as labor, executive, hourly, salary, part-time, seasonal, or migrant workers. Covered employers must log also any recordable injuries and illnesses that occur to employees who are not on the company payroll if these employers are supervised on a day-to-day basis.

OSHA says that the temporary worker Recordkeeping Bulletin is the first in a series of guidance documents to be released to support the initiative to raise awareness about compliance with OSHA requirements for temporary workers.