The OSHA Temporary Worker Q&A You Might Have Missed
Staffing Safety & OSHA Temporary Worker Initiative
In late April, Assurance hosted an Assurance University webinar titled “OSHA’s Temporary Worker Initiative and Client Selection.” We had a large number of staffing companies on the webinar which made for some great questions at the end. If you weren’t able to attend, or did attend and want a recap, I provided some of the Q&A below. For additional OSHA and client selection questions by your industry peers, check out our recording on Assurance University Replay.
If we have on-site coordinators at a client location and are involved in day-to-day supervision, do we the staffing company have to report on our staffing OSHA log?
If during day-to-day supervision, an on-site supervisor is directing or showing employees the job assignment, then ‘yes’ report on the staffing OSHA log. If the on-site supervisor has more of a HR role (i.e. something that can be done at the staffing company’s office), then it will go on the host company’s OSHA log.
Are we required to request loss run reports, if so where is it noted by OSHA, so we can reference that to the host employer?
As far as I’m aware, you’re not required to request loss runs, but you still should know what’s going on at a client’s operations. This includes the nature and number of injuries prior to placing employees at that client or in a particular area. If the client is having losses, they may look at trying to transfer the risk instead of correcting the problem.
Does the staffing company take on more liability, if while doing a site inspection sees that machine guarding is not in place? Down the road if an employee is injured losing three fingers, can OSHA cite both companies for a willful violation?
If there’s an issue you’re seeing on-site and you’re noting it on an evaluation form, there should be documented follow-up saying the item was corrected prior to you sending a temporary employee to that location.
In the specific case you went out there and saw a machine that wasn’t guarded, there should be some sort of follow up stating that guarding was done prior to the employee going to the site and working on that machine. You could be cited for a willful violation if you knew the hazard existed, noted it and did not follow up to ensure the problem was fixed prior to sending an employee to that machine.
How often should you inspect construction job sites?
Under the Construction OSHA Standard, OSHA expects construction companies to be doing their own evaluations once a week. As such, staffing companies should be doing right around the same, if possible. I know that sounds like a crazy high frequency, but construction is a much higher hazard and the conditions change frequently. In industries like manufacturing, the environment can change from business to business, but a lot of what you’re doing in that case is monitoring. With construction, the phases of a project can change greatly from day-to-day, so the hazards encountered could be very, very different – making it much more important to get out there. For other industries, frequency depends on the hazards at that particular client site or job.
How do I word it to clients when I want to do a walk thru or audit?
It’s important to make sure you’re using language that’s customer-friendly, as you want to maintain good relationships with clients. Word it as a ‘walk thru’ or ‘check-up’ rather than an ‘audit’ or ‘evaluation.’ It sounds more positive if your company is just ‘checking in’ with their temps. Delivering pay checks is a great time to conduct a walk thru, look at the conditions and talk to temporary workers.
- OSHA Temporary Worker Initiative & Client Selection Webinar Replay
- Four Topics for Your Host Client Safety Agreement
- The OSHA Recordkeeping Scramble
- OSHA Launches Initiative to Proctect Temporary Workers
- OSHA Emphasizes Joint Responsibility Between Staffing Firms and Clients
- OSHA Penalties to Increase Up to 80% in 2016
- OSHA 10 and 30-Hour Trainings
- OSHA Issues New PPE Guidance for Temporary Staffing Firms
- Safety E-Book
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