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February Reminder: Temporary Employees and OSHA Recordkeeping

John DeRoia Posted by John DeRoia

Are you confused over recordkeeping requirements for your temporary workers?  Here are some simple guidelines to help.   

OSHA regulations require employers to record work-related illnesses and injuries on the OSHA 300 log for all employees on their payroll.  The regulations also require employers to maintain such records for employees not on their payroll including temporary employees from a staffing firm.  Now here's the catch to this requirement.  If the employer supervises the temporary employee on a day-to-day basis, the employer is required to log the temporary employee’s injuries on their company OSHA log.  If the temporary agency dictates what the help will be doing in their day-to-day activities then the injury would be logged on the staffing companies OSHA logs. 

According to OSHA, day-to-day supervision means supervision of the “details, means, methods, and processes by which the work is to be accomplished.” In the majority of cases, the employer, not the staffing firm, exercises these functions.

In addition, if you should receive a request by OSHA to complete a survey for a previous year’s injuries and person-hours worked, do not forget to add your temporary workforce’s hours in your totals. 

Here are links to OSHA’s recordkeeping forms and OSHA’s recordkeeping handbook to help guide you.  Remember you need to post your OSHA 300A Summary Logs by February 1st.



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Sharon Sauers

Can you explain in more what "details, means, methods, and processes" are? Thanks!

John DeRoia

Hi Sharon,

Basically what OSHA is saying is that if you are in control of the temporary employee's duties/activities for the time frame that they are working for you, they are technically your worker and therefore any injuries would be posted to your OSHA logs. In some instances the temporary agency will actually dictate to the temporary worker what their job functions will be for that employer. This typically is not the case.

If you have any other questions please let me know.

John DeRoia
MEMIC Safety Management Consultant

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