Temporary Worker Initiative

Ergonomics for the Prevention of 

Musculoskeletal Disorders

This is part of a series of guidance documents developed under the 

Occupational Safety and Health Administration’s (OSHA’s) Temporary Worker 

Initiative (TWI). This Initiative focuses on compliance with safety and health 

requirements when temporary workers are employed under the joint 

employment of a staffing agency and a host employer.

Introduction

Temporary workers are entitled to the same 

protections under the Occupational Safety and 

Health Act of 1970 (the OSH Act) as all other 

covered workers. When a staffing agency supplies 

temporary workers to a business, commonly 

referred to as the host employer, OSHA considers 

the staffing agency and the host employer as 

joint employers of those temporary workers. Both 

employers are responsible for determining the 

conditions of employment and complying with 

the law. In these joint employment situations, 

there are common questions regarding how each 

employer can fulfill its duty to comply with the 

OSH Act and other applicable standards. This 

bulletin addresses what both the staffing agency 

and the host employer can do to ensure that 

temporary workers in high-hazard industries are 

protected from ergonomic hazards. 

What is Ergonomics?

Ergonomics is the study of fitting workplace 

conditions to the working population. An 

ergonomic process or program uses the 

principles of a safety and health program to 

address and reduce ergonomic risk factors such 

as forceful exertion, awkward postures, contact 

stress, repetitive movements, and vibration. 

Some examples include frequently lifting heavy 

items, awkward bending, frequently reaching 

overhead or working with the hands above head 

height, frequently pushing/pulling/carrying heavy 

loads, working in squatting or kneeling postures, 

using tools while wrist is significantly bent, 

performing the same similar tasks repetitively 

several times a minute, using fingers, palms, or 

hands to press or insert parts with high force, 

sustained or static postures or positions; and 

using vibrating tools or tools that press into the 

muscles or nerves. Routine exposure to these 

ergonomic risk factors for several hours a day 

can cause soft tissue injuries or musculoskeletal 

disorders (MSDs). Some examples of MSDs 

include carpal tunnel syndrome, tendinitis, 

rotator cuff injuries, muscle strains, and low back 

injuries, as well as other disorders to muscles, 

nerves, blood vessels, ligaments, and tendons. 

Working in cold temperatures can aggravate 

MSDs. An ergonomic process or program with 

employee participation helps identify hazards 

and improvements to lessen muscle fatigue, 

reduce medical costs and days away from work, 

increase productivity, and reduce the number and 

severity of work-related MSDs.

TWI BULLETIN NO. 13
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Workers in many different industries and 

occupations can be exposed to risk factors at work. 

Biennially, the U.S. Bureau of Labor Statistics 

(BLS) releases MSD data specific to industries 

and occupations, including the days away from 

work (DAFW) incident rate and median DAFW. 

Review of the latest available data reported by 

BLS (for illness and injuries reported by employers 

during calendar year 2020) indicates that the 

transportation and warehousing industry had the 

highest incident rate of MSD injuries (see Appendix 

A for tables of BLS data). Other industries having 

an incident rate of MSD injuries higher than 30% 

included health care and social assistance, retail 

trade, wholesale trade, and the industry group that 

included agriculture, forestry, fishing, and hunting. 

BLS categories of occupations with the highest 

incident rates of MSDs included material moving; 

installation, maintenance, and repair; production; 

and healthcare practitioners and technical.

General Employer Responsibilities

Currently, OSHA does not have a specific standard 

addressing ergonomic hazards. However, all 

employers covered under the OSH Act must ensure 

that workers are protected from recognized hazards 

that may cause death or serious physical harm, 

which includes ergonomic hazards. To protect 

their workers, employers should implement an 

ergonomic process with the following elements:

y Management Commitment: Management 

should define the goals, objectives and steps for 

the ergonomic process, discuss them with their 

workers, assign responsibilities to designated 

staff, and communicate openly with the 

workforce.

y Involve Workers: Encourage workers to 

participate in worksite assessments, solution 

development and implementation. 

y Hazard Assessments: Identify ergonomic 

risk factors at each task or job through hazard 

assessments or job hazard analyses.

y Implement Solutions to Control Hazards: 

There are many possible solutions that can be 

implemented to reduce, control, or eliminate 

workplace MSDs.

y Provide Training: A program of initial and 

refresher training ensures that workers are 

aware of ergonomics and its benefits, informed 

about ergonomics-related concerns in the 

workplace, and understand the importance of 

reporting early symptoms of MSDs. Provide 

on-the-job training for new workers to become 

conditioned to the physical demands of the job. 

y Encourage Early Reporting of MSD Symptoms: 

Early reporting can accelerate the job assessment 

and improvement process, helping to prevent 

or reduce the progression of symptoms, the 

development of serious injuries, and subsequent 

lost-time claims. Ensure injured workers receive 

care from a healthcare provider who is trained 

and experienced in treating MSDs within the 

scope of their license. OSHA’s injury and illness 

recording and reporting regulation (29 CFR Part 

1904) require employers to record and report 

work-related fatalities, injuries and illnesses.

y Evaluate the Ergonomic Process and 

Progress: Evaluation and corrective action 

procedures are needed to periodically assess 

the effectiveness of the ergonomic process 

and to ensure its continuous improvement and 

long-term success.

Host Employer Responsibilities

The host employer is usually in the best position 

to develop an ergonomic process in the facility 

because it generally controls the means, methods, 

and processes by which the work is accomplished. 

The host employer should take the lead on the 

worksite hazard assessment or job hazard analysis 

because it is most familiar with the associated 

hazards of each task or job. The results of the 

assessments should be shared with the staffing 

agency, and the staffing agency should have the 

ability to conduct its own assessment as necessary. 

Any controls to mitigate ergonomic hazards should 

be instituted and installed by the host employer. 

The host employer is responsible for ensuring 

temporary employees are trained on the purpose 

and proper use of the controls in place to mitigate 

the ergonomic hazards. 

Staffing Agency Responsibilities

The staffing agency shares responsibility 

for its workers’ safety and health and has an 

obligation to become familiar with the various 

tools mentioned above and to review the host 
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employer’s worksite policies and procedures to 

control ergonomic hazards prior to assigning 

workers. The staffing agency should be permitted 

by the host employer to conduct a walkthrough 

of the worksite to identify tasks temporary 

employees will be conducting and controls in 

place to mitigate ergonomic hazards. The staffing 

agency can conduct a hazard assessment for tasks 

that temporary employees will be performing or 

review the hazard assessments conducted by the 

host employer. Any controls to mitigate ergonomic 

hazards instituted by the host employer should be 

verified by the staffing agency prior to assigning 

workers and at various later times to ensure the 

controls are maintained. 

Joint Responsibilities

The OSH Act under section 5(a)(1) requires 

employers to provide a safe and healthful 

workplace for all workers. When OSHA’s 

investigations reveal that a temporary worker is 

exposed to a recognized hazard, and the worker 

is employed by both a staffing agency and a host 

employer, we will consider issuing citations to 

either or both of the employers, depending on 

the specific facts of the case. OSHA will make 

an assessment of whether both employers have 

fulfilled their respective compliance responsibilities 

in each individual case.

Training is an important element in the ergonomic 

process. In most cases, the host employer is 

responsible for site-specific training and the staffing 

agency is responsible for generic safety and health 

training. Training must be conducted in a language 

and vocabulary that all workers understand. 

Effective training should at least include:

y The principles of ergonomics and their 

applications to the assigned tasks.

y The proper use of equipment, tools, and 

machine controls.

y Good work practices, including proper lifting 

techniques.

y Recognition of early symptoms of MSDs.

y Understanding the importance of reporting and 

addressing early indications of MSDs before 

serious injuries develop. 

y The procedures for reporting work-related 

injuries and illnesses. 

Ergonomic training is best provided by individuals 

who have experience with ergonomic hazards 

and controls within the particular industry. The 

specific type of training to be performed by the 

host employer and staffing agency can be clearly 

stated in the language of the contract between the 

employers. Both employers should ensure that the 

other is providing effective and proper training 

so that the employees have the basic knowledge 

listed above. 

Both the host employer and staffing agency should 

conduct thorough investigations of reported 

MSDs that occur on the job, including injuries, 

illnesses, and symptoms, in order to determine 

the root cause(s) and what opportunities exist to 

improve injury and illness prevention programs. It 

is critical that both the host employer and staffing 

agency are jointly engaged and communicating 

when conducting these investigations. For OSHA’s 

requirements on reporting and recording injuries 

and illnesses, see TWI Bulletin #1 - Injury and 

Illness Recordkeeping Requirements.

State Plans

Twenty-nine states and U.S. territories operate 

their own OSHA-approved occupational safety and 

health programs, called State Plans. These State 

Plans have and enforce their own occupational 

safety and health standards that must be at least 

as effective as OSHA’s but may have different or 

additional requirements. For a list of the State 

Plans and more information, see this webpage: 

State Plans.

How Can OSHA Help?

Workers have a right to a safe workplace. If you 

think your job is unsafe or you have questions, 

contact OSHA at 1-800-321-OSHA (6742) or visit 

OSHA’s website. It’s confidential. We can help. 

For other valuable worker protection information, 

such as Workers’ Rights, Employer Responsibilities, 

and other services OSHA offers, see this webpage: 

OSHA Worker Rights and Protections. 

For information on Temporary Workers, see this 

webpage: Protecting Temporary Workers.
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Example Scenarios*

HEALTHCARE: 

A long-term nursing home provides 24-hour care to many residents in their buildings. Employees who assist 

residents include nurses and certified nursing assistants (CNAs). The job duties of the CNAs include ensuring 

residents in the facility complete daily activities of living (bathing, brushing hair and teeth, toileting, dressing, 

eating, etc.) and assisting residents out of bed or rotating residents in bed. The host employer, Best Nursing 

Home, has a Patient Handling Program for ergonomics that includes hazard assessments, controls, employee 

training, and a no-lift policy. Employee training is provided to new employees and annually thereafter during 

their safety week in July. Best Nursing Home has sit-to-stand lifts, full-body lifts, and transfer boards to assist 

CNAs with their required job duties. 

Due to recent employee departures, Best Nursing Home contracted with CNA Staffing Agency to have CNAs 

work in the facility for about two weeks. Best Nursing Home requested that CNA Staffing Agency ensure that 

the CNAs have their appropriate certifications prior to starting at the facility. When the temporary workers 

arrived, Best Nursing Home provided the CNAs with a brief tour of the facility and instructed them that they 

each had 10 residents to assist in the morning prior to their 9 am breakfast. This included toileting and getting 

them to the dining room if the resident was able to. After breakfast, the residents were transferred to a bed or 

chair. The same routine was repeated before lunch. On the fourth day of working at the facility, a CNA felt a 

sharp pain in his back while transferring a resident from the bed to a wheelchair without using any of the lift 

assist devices. The CNA continued to work because he thought he could work through it, and the pain would go 

away. At the end of the shift, the CNA was unable to stand or walk without significant pain in his lower back.

Analysis

Best Nursing Home supervises and controls the day-to-day work of the temporary workers in its facility and 

was aware of the ergonomic hazards because they had established an ergonomic program. Best Nursing 

Home verified that all the CNAs had certifications prior to arriving at the facility but as the host employer, 

they should have verified the temporary workers’ prior work histories and experiences on the use of the 

specific ergonomic equipment available at this facility. As the host employer, Best Nursing Home was 

responsible for providing site-specific training on preventing ergonomic hazards, including but not limited to, 

the no-lift policy, the ergonomic equipment available at the site, how and when to use the equipment, as well 

as how to report early signs and symptoms of ergonomic injuries. An effective ergonomic program includes 

a planned method of employee oversight. The host employer has a basic obligation to have a reasonable 

method and frequency of inspecting/observing work to determine if safety and health work rules and 

procedures are being followed and is in the best position to correct any observed activities that do not follow 

their ergonomic program and reinforce the use of any ergonomic controls they have in place. In this scenario, 

Best Nursing Home may be subject to OSHA citations for not implementing their ergonomic controls and 

failure to provide site-specific ergonomic training.

CNA Staffing Agency did provide their temporary workers with general safety and health training such as 

hazard communication and how to report injuries. CNA Staffing Agency ensured that all the CNAs had the 

appropriate certifications but did not ensure they were provided with general ergonomic training, including 

signs and symptoms of MSDs and the reporting requirements. Since the staffing agency was aware the 

workers would be exposed to ergonomic hazards while conducting their daily duties, it should have inquired 

about what provisions the host employer had in place so that the temporary workers would be adequately 

protected. CNA Staffing Agency failed to ensure and confirm that Best Nursing Home had provided sitespecific training and the use of the ergonomic controls was enforced for the temporary workers. In this 

scenario, CNA Staffing Agency may be subject to OSHA citations for not providing general ergonomic 

training to employees.
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Warehousing:

A general warehousing facility stored non-perishable grocery items on pallets in a racking system and picked 

orders that are sent to local stores. A picker was required to operate a high-low powered industrial truck 

and pick individual items from the pallets and boxes in the racking system. The picking job task occurred 

during the 10-hour overnight shift so trucks were ready to leave in the morning. A picker was expected to 

meet a standard pace of work and was only retrained or coached if they did not meet that pace. The host 

employer, Greater Foods Warehousing, has an ergonomics program including employee participation, 

hazard assessments, equipment, and training. Pick sticks are available on the powered industrial trucks for 

employees to use when applicable. New employees are provided initial ergonomic training and periodic 

training during pre-shift meetings throughout the year.

Recently Greater Foods Warehousing acquired some new accounts and stores that require additional 

pickers. Because the accounts are short-term, Greater Foods Warehousing contracts with Work Ready 

Staffing Agency (WRSA) to have 25 additional employees to pick each night for at least 3 months. Upon 

arrival, the temporary employees were given a tour of the facility and general training on the job tasks 

required. WRSA employees were expected to meet a standard pace of work by the second week. After 

the third week of working at the facility, a WRSA employee told his supervisor from Greater Foods 

Warehousing that he had pain in his lower back and difficulty standing up. The WRSA employee stated that 

the pain had been gradually building since the second day of work and was treating it by using ice at night 

and over-the-counter pain medications.

Analysis

Greater Foods Warehousing supervises and controls the day-to-day work of the temporary workers in its 

facility and was aware of the ergonomic hazards because they had established an ergonomic program. 

Greater Foods Warehousing verified that all WRSA employees had powered industrial truck certifications 

prior to arriving at the facility and watched the employees operate the powered industrial trucks onsite. 

But as the host employer, Greater Foods Warehousing was also responsible for providing site-specific 

training on preventing ergonomic hazards, including but not limited to, the ergonomic equipment available 

at the site, how and when to use the equipment, as well as how to report early signs and symptoms of 

ergonomic injuries. The host employer has an obligation to exercise oversight of work and determine if 

safety and health rules and procedures are being followed. In this scenario, Greater Foods Warehousing 

may be subject to OSHA citations for not implementing their ergonomic controls, and failure to provide 

site-specific ergonomic training.

WRSA did provide their temporary workers with general safety and health training such as hazard 

communication and how to report injuries. WRSA ensured that all the temporary employees had the 

appropriate certifications but did not ensure they were provided with general ergonomic training, including 

signs and symptoms of MSDs and the reporting requirements. Since the staffing agency was aware the 

workers would be exposed to ergonomic hazards while conducting their daily duties, it should have inquired 

about what provisions the host employer had in place so that the temporary workers would be adequately 

protected. WRSA failed to ensure and confirm that Greater Foods Warehousing had provided site-specific 

training and the use of the ergonomic controls was enforced for the temporary workers. In this scenario, 

WRSA may be subject to OSHA citations for not providing general ergonomic training to employees.

*Note: The company names in these scenarios are fictitious. Any resemblance to real companies is entirely coincidental.
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The OSH Act prohibits employers from retaliating 

against their employees for exercising their rights 

under the OSH Act. These rights include raising 

a workplace health and safety concern with 

either employer, reporting an injury or illness, 

filing an OSHA complaint, and participating in an 

inspection or talking to an inspector. If workers 

have been retaliated or discriminated against for 

exercising their rights, they must file a complaint 

with OSHA within 30 days of the alleged adverse 

action to preserve their rights under section 

11(c). For more information, see this webpage: 

Whistleblower Protection Program.

OSHA also provides help to employers. OSHA’s 

On-Site Consultation Program offers free and 

confidential advice to small and medium-sized 

businesses in all states and several territories, 

with priority given to high-hazard worksites. 

On-Site consultation services are separate from 

enforcement and do not result in penalties or 

citations. Consultants from state agencies or 

universities work with employers to identify 

workplace hazards, provide advice on compliance 

with OSHA standards, and assist in establishing 

and improving safety and health management 

systems. To locate the OSHA On-Site 

Consultation Program nearest you, call 1-800-

321-6742 (OSHA) or see this webpage: On-Site 

Consultation Program. 
Appendix A: Excerpts from the U.S. Bureau of Labor Statistics (BLS) Data on 

Musculoskeletal Disorders (MSDs) for Calendar Year 2020

Table 1: Top Ten Industries with the Highest MSD Incident Rates

NAICS Industry

Number of DAFW 

MSD Cases

Incidence rate 

of DAFW MSD 

Cases

Median 

DAFW 

All Industries 247,620 25.4 6

48-49 Transportation and warehousing 36,360 70.2 28

62 Health care and social assistance 60,320 41 18

44-45 Retail trade 35,090 32.1 17

42 Wholesale trade 16,810 30.5 53

11 Agriculture, forestry, fishing and hunting 2,990 30.1 12

31-33 Manufacturing 33,100 27.6 66

23 Construction 18,480 26.9 12

71 Arts, entertainment, and recreation 2,520 22.1 21

22 Utilities 1,100 20.3 15

53 Real estate and rental and leasing 3,910 20 15

Table 2: Top Occupations with the Highest MSD Incident Rates

Occupation

Number DAFW 

MSD Cases

Incident rate of 

DAFW MSD Cases

Transportation and material moving 70,730 71.5

Installation, maintenance, and repair 21,170 47

Production 27,780 37.3

Healthcare practitioners and technical 21,500 36.4

Construction and extraction 15,910 32.6

Service 54,080 32.5

Farming, fishing, and forestry 2,500 24

Sales and related 15,680 15.6

Office and administrative support 8,820 7.1

Educational instruction and library occupations 2,710 5.5

Management, business, financial 5,530 4.2

Computer, engineering, and science 1,090 1.7

Reference: See U.S Bureau of Labor Statistics webpage for Injuries, Illnesses, and Fatalities Databases.

OSHA 4382-10 2023

Disclaimer: This bulletin is not a standard or regulation, and it creates no new legal obligations. It contains 

recommendations as well as descriptions of mandatory safety and health standards. The recommendations are 

advisory in nature, informational in content, and are intended to assist employers in providing a safe and healthful 

workplace. The Occupational Safety and Health Act requires employers to comply with safety and health standards 

and regulations promulgated by OSHA or by a state with an OSHA-approved state plan. In addition, the OSH Act’s 

General Duty Clause, Section 5(a)(1), requires employers to provide their employees with a workplace free from 

recognized hazards likely to cause death or serious physical harm.