New OSHA Recordkeeping Bulletin-Temporary Workers

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Injuries and illnesses should be recorded on only one employer’s injury and illness log. 29 CFR 1904.31(b)(4).

In most cases, the host employer is the one responsible for recording the injuries and illnesses of temporary workers.

According to OSHA Release, injuries to Temporary workers go on the host employers, not the Temp Agency's OSHA 300. — According to OSHA Release, injuries to Temporary workers go on the host employers’, not the Temp Agency’s OSHA 300.

OSHA has released a new educational bulletin for staffing agencies and host employers on current requirements for recording injuries and illnesses of temporary workers. The new Recordkeeping Bulletin (PDF*), which is part of OSHA’s Temporary Worker Initiative, addresses how to identify which employer is responsible for recording these work-related injuries and illnesses on the OSHA 300 log.
“The Recordkeeping Bulletin is the first of many materials we are releasing and helps clarify which employers are responsible for reporting injuries and illnesses,” said Dr. David Michaels, assistant secretary of labor for occupational safety and health. “These materials will provide valuable information for both host employers and staffing agencies on how they can work together to make sure their workers are properly trained and protected.”
The temporary worker Recordkeeping Bulletin helps businesses determine which employer is responsible for recording work-related injuries and illness on the OSHA 300 log. For more information, read the news release and visit OSHA’s temporary worker page.

Year End To-Do List

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Some ideas to be working on during the ‘slow time’ at the end of the year.

1) Audit your shop’s Injury, Illness, Accident records and Incident reports.If any are missing now is the time to start looking- before you need to prepare your next OSHA 300 log.

2) Audit your OSHA 300 log. If you find any deficiencies- FIX THEM!

3) Prepare a listing of all raw materials brought in by type and grade to facilitate next year’s TRI reporting.

4) Review the years stack of no quotes. What capabilities do you lack that the market is telling you you need?

5) Review your jobs by profitability list. (If you don’t have one, why not?) What is it that you are really doing right?

6) Look at your machine utilization rate by department or type. If you have clear winners or losers the market is telling you that the way you are assigning costs needs to be reevaluated.

7) Come in on the weekend when noone else is there. Bring a trusted friend or colleague that is not in the business. Look, really look, at what you see. Are you comfortable? What would you change? Can you answer their questions about “Why it’s like this?”

8) Develop a safety, quality, and a production theme for the year. In my steel mill days I made it the “Year of No Rust Claims,” and our work and investigations and permanent corrective actions put an end to rust claims off that mill by the middle of the summer. For the rest of the year and the next…Why not do that for safety, and productivity too?

9) Inspect all slings, cables, straps, and other lifting and rigging. Destroy and replace all showing frays, wear, damage of any kind.

10) Identify the stupidest policy that you have in place. Eliminate it.

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” 8) ” Glitch in the list above is an undocumented feature courtesy of WordPress (Typed the numeral 8 and the close parentheses…)

5 Tips For Best OSHA 300 Log Recording

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Homer_Working_in_Office_by_foxalex — "I have to get it right too?"

You wouldn’t use a gage that measures in 0.001″ increments for a requirement in 0.0001.” Why tolerate similar inaccuracies in your OSHA reporting work product?

Guest Post by James Pryor II, American Safety and Health Management Consultants, Inc.
Here are 5 tips to help keep your OSHA 300 up to requirements:

Record ALL hours worked by ALL employees covered by the records – Hourly , Salary, Part Time, and Temporary.
If necessary, estimate by multiplying the average number of workers by 2000 to obtain hours worked.
Verify hours by confirming against what amount was paid to unemployment insurance.
If the hours you report are too low (underestimated) the incidence rate will be too high.
If the hours you report are too high (overestimated) the incidence rate will be too low.

Why is the incidence rate so important? It is the go / no go gage that will determine whether or not your shop safety program gets a pass or a closer look. The DayAway and Restricted Time Report is a listing that is closely examined by OSHA. Too high an Incidence Rate will indicate a need for a review. Too low an incidence rate could give a false picture of your safety performance and lead to unintended consequences.
We don’t really have the technology to do a long form Gage R&R on your safety paperwork, but following these 5 tips will assure that your program “meets print.”
Use your passion for quality to assure high performance in all aspects of your shop’s safety program.The actionable information in your accurate OSHA 300 Log will help you continue to improve your shop’s safety performance.
Here is a link to our post on the 7 Indirect Costs of a Failed Safety Program.
Photo credit: Thanks Eighth Diary. Good luck with your work in the office!