10 Feb The Big “O” is Here

   The Big “O” is Here

This year, the Occupational Safety and Health Administration (OSHA) has decided to increase their efforts to monitor and record the training and safety of workers from temporary staffing agencies.

A memo was issued to the regional OSHA administrators on April 29, 2013 instructing them to determine whether temporary workers are exposed to conditions that would violate OSHA’s regulations and also to monitor whether the safety training is provided in a “language and vocabulary” that they can understand. As a general rule of thumb, temporary staffing agencies do not have site specific safety training requirements. It falls on the “host” employer, the client of the staffing agency.

An important component of compliance with OSHA is recordkeeping.  When the staffing agency has on-site managers as part of a contract to manage the temporary workers, the burden of record keeping and managing workplace injuries does fall directly on the staffing firm.

The form that must be maintained to record injuries is the OSHA Form 300. To help understand what a “recordable” event is, here is the flowchart:


Barrow Group LLC providing the 300 OSHA Recordability Flowchart


  1. Employee Report of Injury/Illness: Injury or illness reported assumes the individual reporting the injury or illness is an employee of host employer. If the employee is a temporary employee from a temporary staffing agency, incidents are to be recorded in the 300 log; however, the temporary staffing agency would be responsible for reporting workers’ compensation claims to the carrier. 


  1. Occupational Hearing Loss: Defined as:
    • A change in hearing threshold relative to the baseline audiogram as an average of 10dB or more in either ear at 2,000, 3,000 and 4,000 hertz.
    • Employee’s total hearing level of 25 dB or more above audiometric zero in both ears at the same hertz levels. 


  1. Medical Treatment: The management and care of a patient to combat disease or disorder. It does not include:
    • Visits to practitioners for observation and/or evaluation only
    • Diagnostic procedures
    • First aid 


  1. First Aid: Defined by OSHA in section 1904.7 (b) (5). Treatments that are considered first aid include:
    • The use of nonprescription medication at nonprescription strength
    • Tetanus immunizations
    • Cleaning, flushing or soaking surface wounds
    • Use of wound coverings, butterfly bandages, Steri-Strips
    • Hot or cold therapy
    • Use of non-rigid means of support
    • Temporary immobilization devices used to transport victims
    • Drilling of fingernails or toenails or draining fluid from a blister
    • Eye patches
    • Removal of foreign bodies from eye using irrigation or cotton swab
    • Removal of splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
    • Finger guards
    • Massage therapy
    • Drinking fluids for relief of heat stress 

The increased interest from OSHA into the temporary staffing world is that there has been an increase in injuries and deaths of temporary workers. Their intent is to protect the employees.  Additional info about record keeping may be found at http://www.osha.gov/recordkeeping/index.html


For questions, or to stay up on Workers’ Compensation or the Affordability Care Act (ACA), please feel free to contact:

Robert G. Barrow Jr. CIC, CWCA, CBWA

Barrow Group, LLC at 800-874-4798



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