Protecting Temporary Workers: 

Best Practices for Host Employers

Beyond 

Compliance 

for a 

Safer, 

Healthier 

Workforce
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SUGGESTED CITATION

National Institute for Occupational Safety and 

Health, National Occupational Research Agenda 

Services Sector Council, American Society for Safety 

Professionals, American Staffing Association, Safety 

and Health Assessment and Research for Prevention 

Program [2022]. Protecting temporary workers: 

best practices for host employers. Cincinnati, OH: 

U.S. Department of Health and Human Services, 

Centers for Disease Control and Prevention, 

National Institute for Occupational Safety and 

Health, DHHS (NIOSH) Publication No. 2022-126, 

https://doi.org/10.26616/NIOSHPUB2022126.

ACKNOWLEDGMENTS

Special thanks to the members of the NORA 

Services Sector Council Contingent Workers 

Workgroup and all who reviewed this document 

and provided feedback for their contributions (see 

Background section on pages 13–15 for a full list of 

contributors).

 DHHS (NIOSH) Publication No. 2022

 DOI: https://doi.org/10.26616/NIOSHPU

 JULY 202

Publication illustrations by Getty Images
Table of 

Contents

Introduction and Overview 1

Best Practices 3

Evaluation and Contracting 3

Evaluation 3

Contracting 3

Example—Evaluation and Contracting 5

Training for Temporary Workers and Their Worksite Supervisors 6

Temporary Worker Training 6

Supervisor Training 7

Example—Training for Temporary Workers and Their Worksite Supervisors 8

Injury and Illness Reporting, Response, and Recordkeeping 9

Reporting 9

Response 9

Recordkeeping 9

Example—Injury and Illness Reporting, Response, and Recordkeeping 10

Summary and the Need for Proactive Safety Management 11

More Information and Resources 12

OSHA Temporary Worker Initiative Bulletins 12

ASSP Z10 Guidance Manual 12

ANSI/ASSP A10.33 Standard 12

Background 13

Appendix 16
Protecting Temporary Workers: Best Practices for Host Employers

1

Protecting Temporary Workers: 

Best Practices for Host Employers

INTRODUCTION AND OVERVIEW

The future of work brings new challenges to 

occupational safety and health, including how to 

best protect and promote the safety and health 

of a workforce employed through a variety of 

non-standard work arrangements. Temporary 

agency workers (hereafter "temporary workers" 

or "TWs") are those who are paid by a staffing 

company (SC) and assigned to work for a host 

employer1 (HE), including both short- and long-term 

assignments. This document is intended to apply 

to HEs across all industries that employ (or are 

planning to employ) TWs at their worksites. 

Analysis of workers’ compensation data indicates that the 

risk of experiencing work-related injuries may be higher for 

TWs than for non-TWs.2,3,4

Many factors may contribute to an elevated risk of work-related 

injuries among TWs, including these:

• Newness to the workplace and unfamiliarity with 

the job/tasks

• Insufficient or lack of communication between the HE, 

SC, and TWs

• Insufficient or lack of training

• Unexpected changes to TW job duties that are not 

reported to the SC

• Issues related to subcontracted, dual employment 

arrangements

1. Host employers may also be referred to as worksite employers, clients 

of staffing companies, or secondary employers.

2. Al-Tarawneh IS, Wurzelbacher SJ, Bertke SJ [2020]. Comparative 

analysis of workers' compensation claims of injury among temporary 

and permanent employed workers in Ohio. Am J Ind Med 63:3–22.

3. Foley M [2017]. Factors underlying observed injury rate differences 

between temporary workers and permanent peers. Am J Ind Med 

60(10):841–851.

4. Howard J [2017]. Nonstandard work arrangements and worker health 

and safety. Am J Ind Med 60:1–10.

Having a safe, healthy, 

productive workforce leads to an

increased competitive advantage.
INTRODUCTION AND OVERVIEW

According to the Occupational Safety and Health Administration (OSHA), the HE and the SC are joint employers of TWs 

and, therefore, are both responsible for providing and maintaining a safe work environment for those workers (https://

www.osha.gov/temporaryworkers). The HE is usually the 

supervising employer because it provides day-to-day supervision and controls the means and manner of the work of TWs. 

Whether workers are permanent or temporary, unsafe working 

conditions, unclear job assignments, inadequate training, and 

poor hazard communication put all workers at risk for being 

injured or becoming ill at work. In addition to the sometimes 

devastating impact of work-related injuries and illnesses 

on the workers themselves, they can also negatively impact 

a company’s bottom line due to production disruptions, 

high injury costs and absenteeism rates, poor product or 

service quality, and negative media exposure. In the event 

of a TW injury or illness, OSHA could hold both the HE and 

the SC responsible for violations of workplace standards. In 

some cases, the HE has been fined more heavily for violations because it is the supervising employer. See examples 

from an automotive manufacturer (https://www.osha.gov/

news/newsreleases/region4/02032014) and a packaging company (https://www.osha.gov/news/newsreleases/

region1/10242017). 

In 2014, OSHA and the National Institute for Occupational 

Safety and Health (NIOSH) issued Recommended Practices: 

Protecting Temporary Workers, which includes recommended 

practices HEs and SCs should follow in order to better protect 

TWs (https://www.cdc.gov/niosh/docs/2014-139/) and to 

ensure the Occupational Safety and Health (OSH) Act of 1970 

(https://www.osha.gov/laws-regs/oshact/toc) requirements 

are fully met (see 29 U.S.C. § 651). This document includes 

best practices for HEs based, in part, on the 2014 OSHA/

NIOSH recommendations (see Background section on pages 

13—15 for a description of the other sources these best practices are based on). 

The best practices in this document are organized into 

three sections: 1) Evaluation and Contracting, 2) Training for 

Temporary Workers and Their Worksite Supervisors, and 3) 

Injury and Illness Reporting, Response, and Recordkeeping 

(see Figure 1). Each section includes a set of best practices 

followed by a real-life scenario. This example presents a situation or problem faced by an HE and a summary of steps the 

HE should take (labeled "Best Practices"). Checklists for each 

of the three sections that can be printed or completed electronically are included in the Appendix on pages 16—20. The 

person who completes the checklists should be knowledgeable about the work tasks, worksites, and hazards as well as 

the necessary hazard controls, training, PPE, and supervision 

to keep TWs safe and healthy on the job.

Though this document is primarily intended for HEs, SCs can 

use it to educate HEs on best practices using a complementary slide deck. Another document with best practices for 

SCs will be forthcoming.

By integrating these best practices into their safety management systems and going beyond compliance with OSHA 

laws and regulations, HEs can do their part to ensure a safe, 

healthy, and productive workforce, which may ultimately contribute to an increased competitive advantage. 

Disclaimers: This is considered a general set of best practices 

that is meant to be applicable across industries and occupations. It is not meant to replace the formal elements of 

an occupational safety and health program or legal requirements. These best practices may need to be modified in 

certain situations, such as when the HE is contracting with 

multiple SCs or rare cases in which the SC is the supervising 

employer. Laws vary in states with OSHA-approved state 

plans, so it is important to check state-specific occupational 

safety and health laws (https://www.osha.gov/stateplans/).

Protecting Temporary Workers: Best Practices for Host Employers

2

Figure 1. Combining three domains of best practices to protect 

temporary workers.
SECTION 1 : Evaluation and Contracting

BEST PRACTICES

Evaluation and Contracting 

Evaluation

Prior to writing and signing a contract, HEs and SCs should 

evaluate all facets of safety and health related to each organization and the jobs TWs are being hired to perform. As part of 

this process, HEs should take the following steps:

• Conduct a joint risk assessment. Jointly review with 

the SC all task assignments, written job descriptions, 

anticipated exposures, job hazard analyses, equipment and/or machinery, and worksites to identify 

potential safety and health hazards and necessary 

training and personal protective equipment (PPE) for 

each TW. (Under federal law, employers are responsible for paying for and supplying required PPE. 

However, there are some exceptions [see https://www.

osha.gov/sites/default/files/Handout_2_Employers_

Must_Provide_and_Pay_for_PPE.pdf]; state laws vary, 

so check your state-specific regulations: https://www.

osha.gov/stateplans/.)

• Provide information. Provide the SC with requested 

safety data (such as OSHA 300 Logs for the last three 

years with injured workers' names redacted, an Experience Modification Rate letter from your workers’ 

compensation carrier, and safety data sheets [SDSs]); 

safety and health program materials (such as safety 

policies and procedures, incident prevention program 

materials, site- and task-specific training materials, 

and drug-free workplace policy); and other information that will allow the SC to evaluate the safety and 

health of the worksites. 

• Allow site visits. Invite a representative from the SC 

to visit the worksites and conduct a walk-through 

to assess the safety conditions, observe workers 

engaged in their tasks, and see your safety program 

in action.

• Ensure commitment to safety and health. Ensure the 

SC has a commitment to safety and health, including 

having a process in place to evaluate job candidates 

for the qualifications and/or experience necessary for 

the tasks they will perform. The HE should also ask to 

review the SC’s safety and health program materials 

to ensure they are adequate; these should include a 

general safety and health awareness training provided 

to TWs prior to placing them on an assignment (see 

Evaluate staffing company training materials on page 

7 for more information about what should be included 

in this training).

Contracting

The joint employment structure requires effective communication and a common understanding of the division of 

responsibilities for safety and health at all required levels within 

each organization. These responsibilities should be reviewed 

regularly and set forth in a written contract between the HE and 

the SC to encourage proper implementation of and accountability for all pertinent safety and health protections. The written 

contract should clearly specify the following information:

• Pertinent job details

- Approved tasks and qualifications. The tasks the TWs are 

approved to perform (including any hazardous tasks they 

will NOT perform and any equipment and/or machinery 

they are NOT allowed to operate), as stated in the written 

job descriptions and the necessary qualifications and/or 

experience they must have to perform the job

- Hazards and controls. All anticipated hazards that may 

be encountered by the TWs and hazard controls that will 

be in place, including information about SDSs

- Training. The training each employer will provide to the 

TWs before they start their assignment and in which 

language(s) it will be offered (according to OSHA, in 

most cases the HE is responsible for providing site- and 

task-specific safety and health training, and the SC is 

responsible for providing general safety and health 

awareness training)

- Personal protective equipment. What PPE will be needed 

and which employer will: 1) pay for and supply it; 2) 

ensure it's the appropriate type and fits correctly; 3) 

conduct a medical evaluation and fit test for all types 

of PPE that require it; and 4) train the TWs on how to 

properly use and maintain it before they start their 

assignment; usually the HE has the primary responsibility for selecting, providing, and ensuring the adequate 

use of PPE because they are the most familiar with the 

workplace hazards, control the hazards and worker's 

activities, and are best able to perform the hazard 

assessment to determine if PPE is needed. If any PPE is 

provided by the SC, the HE should assess its quality to 

ensure provision of adequate protection.

• Communication and documentation responsibilities

- Qualifications and experience. What documentation the 

SC will provide to the HE regarding each TW’s specific 

qualifications and/or experience relevant to the tasks to 

be performed

- Ongoing risk assessment. Specific time intervals (such as 

quarterly) at which the HE and the SC will jointly review 

Protecting Temporary Workers: Best Practices for Host Employers

3
SECTION 1 : Evaluation and Contracting

all work conducted by the TWs and worksites in order to 

identify potential safety and health hazards and necessary training and PPE for each TW on an ongoing basis

- Changes to job tasks. The process for making changes to 

job tasks when there is a change of assignment, including providing an updated written job description to the SC 

and the TWs, providing an updated job hazard analysis 

to the SC, and updating PPE and training requirements 

accordingly; the HE should give the SC sufficient notice 

to allow time to evaluate the new tasks (and worksites 

if applicable) and the ability of the TWs to take on the 

new tasks. The HE should receive written approval of the 

changed tasks from the SC, and the TWs should receive 

any additional training and PPE needed, before the new 

tasks are undertaken. Undisclosed changes to job tasks 

could adversely impact worker safety and health and 

result in higher workers’ compensation premiums for the 

SC, which could cause higher mark-ups for the HE and 

increased liability and exposure for both employers.

- Changes to hazards. The process for providing the SC 

with written disclosures of any changes to hazards that 

occur during the duration of the contract 

- Training. The procedures for maintaining and sharing 

documentation of safety and health training provided by 

both the HE and the SC

- OSHA investigation. The HE’s responsibility to inform 

the SC when it is under OSHA investigation and the 

nature of the complaint.

• Injury and illness reporting, response, and recordkeeping responsibilities 

- Reporting by temporary workers. Procedures for TWs to 

report work-related injuries, illnesses, and close-calls 

and to communicate safety and health concerns to 

the HE and the SC without fear of retaliation (such as 

through an anonymous safety hotline), as well as the 

procedures for both employers to inform one another 

immediately after an injury, illness, close-call, or concern 

is reported

- OSHA reporting and recordkeeping. The HE’s responsibility 

to report serious TW injuries and illnesses to OSHA and to 

record TW injuries and illnesses on their OSHA 300 Log 

- Coordinating medical treatment and return to work. The 

general procedures for coordinating medical treatment 

and return to work (if applicable) following a work-related 

injury or illness

- Fulfilling record requests. Which employer will make 

injury and illness records available upon request of a TW 

or a worker representative.

• Other aspects of workplace safety and health

- Supervision. Which employer is responsible for providing direct supervision of the TWs (usually the HE); 

in general, supervision of TWs should be identical or 

equivalent to that provided to the HE's own employees 

performing the same or similar work. That said, there 

may be a need to provide extra mentoring and supervision to new TWs who may be inexperienced with the 

assigned tasks and unfamiliar with the worksite.

- Peer mentors. The process by which each TW may be 

paired with an experienced and knowledgeable permanent worker to serve as their mentor/"go to" person; peer 

mentors can be beneficial because TWs may feel more 

comfortable speaking up to their peers (as opposed to 

supervisors) about safety and health concerns. The peer 

mentoring process should be overseen and periodically 

reviewed by mid- and senior-level managers from both 

employers to ensure successful implementation.

- Workers’ compensation. Which employer is required to 

verify and pay for workers’ compensation coverage for the 

TWs during the duration of the contract (usually the SC)

- Infectious disease prevention and response. How the HE 

and the SC will protect TWs from infectious diseases 

(such as COVID-19, influenza, and tuberculosis); HEs 

should apply the same infectious disease prevention 

and response policies and protections to TWs that are 

applied to the HEs’ own employees (such as including 

TWs in universal precautions and company vaccination 

programs).

- Medical surveillance and screening. The responsibility of 

the HE to conduct medical surveillance and screening of 

the TWs (such as audiometric testing, medical evaluations, and fit testing for respirators) if they are exposed 

to a workplace condition that requires it and share the 

results with the SC and the TWs 

- Secure sites. If the TWs will be placed at secure 

worksites, how the HE and SC will work together to 

establish a protocol for the TWs and SC representatives 

to gain access to the sites, including protocols to ensure 

personal security when entering the sites

- Ensuring standard and consistent work practices. Processes in place to ensure that standard and consistent 

work practices are documented, taught, and enforced

- Tracking effectiveness. Ways to track the effectiveness 

of safety and health policies and practices of both 

employers.

Protecting Temporary Workers: Best Practices for Host Employers

4
SECTION 1 : Evaluation and Contracting

E X A M P L E— E VA L U AT I O N A N D C O N T R AC T I N G 

Scenario

Jean Finder, a hiring manager with MPQZ Logistics, 

is working on securing a temporary staffing provider. 

She knows her company, which recently opened a 

new warehouse and distribution center, needs TWs 

for picking, packing, and crating services for its busy 

season. Jean had hoped to quickly finalize an agreement with Prize Staffing, Inc., an SC that provides a 

wide range of TWs, including many to other distribution 

centers in the area. However, Prize Staffing reached out 

with requests for internal documents; a revised, lengthier contract that included detailed job descriptions of 

what tasks TWs will and will not be permitted to do; and 

a request to inspect the MPQZ Logistics warehouse 

before an agreement is signed. Jean has been in touch 

with other SCs that have offered similar services and 

competitive prices, and they seemed easier to onboard. 

Best practices

Although the requests from Prize Staffing go above 

and beyond those made by other SCs, it is clear to Jean 

that Prize Staffing is a partner that values the safety of 

its TWs and the workplaces where they are assigned. 

In order to allow Prize Staffing to assess the safety of 

the worksite, Jean should provide Prize Staffing with 

the requested safety data, including an Experience 

Modification Rate letter from her company's workers’ 

compensation insurer; OSHA 300 Logs for the last three 

years (injured employees’ names redacted); a list of 

anticipated hazards; SDSs for all chemicals present 

at the worksite; and a copy of her company's safety 

program materials. Jean should also schedule a time for 

Prize Staffing to visit the warehouse location in order to 

appraise the safety conditions and to conduct a general 

job hazard analysis to identify potential safety and 

health hazards and necessary training and PPE requirements for the TWs. 

Jean should request a copy of Prize Staffing’s safety 

and health management program materials, including 

the general safety and health awareness training Prize 

Staffing provides to new TWs, so she understands what 

foundational knowledge TWs will have when they walk 

in the door. Jean should also ensure Prize Staffing has a 

process in place to evaluate job candidates for the necessary qualifications and/or experience they must have 

relevant to the tasks to be performed.

Jean should then collaborate with Prize Staffing to 

clearly define job descriptions and training requirements 

in the written contract in order to fully address each 

employer's respective responsibilities and to adequately 

protect the TWs and the overall safety of the workplace 

at MPQZ Logistics. The contract should also specify the 

process for modifying job tasks when there is a change 

of assignment, including providing an updated written 

job description to the SC and the TWs, providing an 

updated job hazard analysis to the SC, and updating PPE 

and training requirements accordingly.

Taking these steps during the pre-contract/evaluation 

stage will help avoid unnecessary confusion by ensuring 

MPQZ Logistics and Prize Staffing have a clear understanding of their joint safety and health roles and 

responsibilities, ultimately contributing to a safe workforce and increased profit margins for both parties. 

Protecting Temporary Workers: Best Practices for Host Employers

5
SECTION 2 : Training for Temporary Workers and Their Worksite Supervisors

Training for Temporary Workers and Their 

Worksite Supervisors

Temporary Worker Training

According to OSHA, in most cases the HE is responsible for 

providing site- and task-specific safety and health training, and 

the SC is responsible for providing general safety and health 

awareness training. Site- and task-specific safety and health 

training should be provided for all TWs before they start new 

assignments or start new jobs/tasks on existing assignments. 

As stated in the 2014 OSHA/NIOSH Recommended Practices: 

Protecting Temporary Workers document, “HEs should provide 

TWs with safety and health training that is identical or equivalent 

to that provided to the HEs’ own employees performing the same 

or similar work” (p. 4). Site- and task-specific safety and health 

training must be in a language and vocabulary TWs understand 

and should include information on the following:

• Approved tasks. The tasks the TWs are approved to 

perform (including any hazardous tasks they will NOT 

perform and any equipment and/or machinery they 

are NOT allowed to operate), as stated in the written 

job descriptions, with an emphasis that the TWs 

should not perform any new tasks without the HE first 

obtaining approval from the SC

• Hazard identification and control. How to recognize 

site- and task-specific hazards and understand the 

best ways to reduce and/or eliminate them (such 

as those related to equipment and/or machinery the 

worker will be using), including the location of SDSs 

and how to obtain copies

• Personal protective equipment. Required PPE (such 

as respirators, hearing protection, gloves, eye protection), including the following:

- Which employer will pay for and supply it (Under federal 

law, employers are responsible for paying for and 

supplying required PPE. However, there are some exceptions [see https://www.osha.gov/sites/default/files/

Handout_2_Employers_Must_Provide_and_Pay_for_PPE.

pdf]. Also, state laws vary, so check your state-specific 

regulations: https://osha.gov/stateplans/.); who will 

ensure it's the appropriate type and fits correctly; and 

who will conduct a medical evaluation and fit test for all 

types of PPE that require it (such as protective eyewear, 

respirators)

- How to properly don, doff, adjust, and maintain it, as 

well as its limitations and shelf life (or provide a review 

of this information if the SC has already provided this 

training to the TWs as stated in the written contract)

• OSHA laws. Employer responsibilities and workers’ 

rights and responsibilities under OSHA law, including 

the Right to Refuse Dangerous Work (https://www.

osha.gov/workers/right-to-refuse) and Whistleblower 

Protection Rights (https://www.osha.gov/Publications/OSHA3781.pdf), with an emphasis that TWs 

have the same rights and responsibilities as non-TWs

• First aid. How to obtain first-aid treatment

• Emergency procedures. Site- and task-specific emergency procedures, including exit routes 

• Reporting safety and health incidents and concerns. 

The responsibility of the TWs to report all work-related 

injuries, illnesses, and close-calls and to communicate safety and health concerns as soon as possible 

to both the HE and the SC, including procedures for 

how to do so, what to expect after reporting, and an 

emphasis that they will not be punished or looked 

down upon for doing so (Safety and health law prohibits retaliation against a worker for reporting a 

work-related injury, illness, or close-call or for communicating a safety and health concern.)

• Secure sites. If the TWs will be placed at secure 

worksites, how to gain access to the sites, including 

protocols to ensure personal security when entering 

the sites

• Safety and health program participation. How the 

TWs can participate in the HE’s safety and health 

program, including safety meetings/committees, 

toolbox talks, scheduled trainings, and hazard-specific 

programs (such as prevention of infectious diseases 

such as COVID-19, hearing conservation, respiratory 

protection, lock-out/tag-out).

In relation to safety and health training for TWs, HEs should 

also do the following: 

• Assess knowledge. After training has been provided 

but before starting the assignment, HEs should 

ensure TWs understand key concepts from the 

training by having them complete a knowledge 

assessment that is also in a language they understand; if gaps in knowledge are found, HEs should 

repeat the training and reassess the workers’ 

knowledge.

HEs should provide TWs with 

safety and health training 

that is identical or equivalent 

to that provided to the HEs’ 

own employees performing 

the same or similar work

Protecting Temporary Workers: Best Practices for Host Employers

6
SECTION 2 : Training for Temporary Workers and Their Worksite Supervisors

• Document training. Document when site- and 

task-specific training for the TWs is completed, the 

names of workers trained, and the names of the 

instructors; upon request from the SC, the HE should 

provide copies of site- and task-specific training 

documentation.

• Evaluate staffing company training materials. Review 

the general safety and health awareness training 

provided by the SC to determine if it is adequate; at a 

minimum, this training should cover specific details 

of the assigned job, a basic overview of employer 

responsibilities and workers' rights and responsibilities, and common hazards and protections including 

any PPE provided by the SC. If the general safety and 

health awareness training provided by the SC is not 

sufficient, the HE should document and communicate 

this to the SC with a recommendation for what additional training the SC should provide.

Supervisor Training

In addition to providing site- and task-specific training to TWs, 

it is also critical that HEs provide training to those who will 

be supervising the work of TWs. This training should include 

information about the following topics:

• Approved tasks. The tasks the TWs are approved to 

perform (including any hazardous tasks they will NOT 

perform and any equipment and/or machinery they 

are NOT allowed to operate), as stated in the written 

job descriptions, with an emphasis that the TWs 

should not perform any new tasks without the HE first 

obtaining written approval from the SC

• Changes to job tasks. The process for modifying 

job tasks when there is a change of assignment as 

described in the written contract

• Mentoring and supervision. Their responsibility to 

provide the TWs with supervision that is identical or 

equivalent to that provided to the HEs’ own employees performing the same or similar work and the 

potential need to provide extra mentoring and supervision to new TWs who may be inexperienced with the 

assigned tasks and unfamiliar with the worksite

• OSHA laws. Employer responsibilities and workers’ 

rights and responsibilities under OSHA law, including 

the Right to Refuse Dangerous Work (https://www.

osha.gov/workers/right-to-refuse) and Whistleblower 

Protection Rights (https://www.osha.gov/Publications/OSHA3781.pdf), with an emphasis that TWs 

have the same rights and responsibilities as non-TWs

• Communication and reporting. How to communicate 

with the TWs about their performance and safetyrelated behavior and encourage them to report all 

work-related injuries, illnesses, close-calls, and safety 

and health concerns as soon as possible

• Joint responsibilities. The safety and health responsibilities of the HE and the SC, including those 

pertaining to training, PPE, hazard communication, 

and injury and illness reporting, response, and recordkeeping as specified in the written contract.

Occupational safety and health 

responsibilities should be reviewed 

regularly and set forth in a written 

contract between the host employer and 

the staffing company to encourage proper 

implementation of and accountability for all 

pertinent safety and health protections.

Protecting Temporary Workers: Best Practices for Host Employers

7
SECTION 2 : Training for Temporary Workers and Their Worksite Supervisors

EXAMPLE—TRAINING FOR TEMPORARY WORKERS AND THEIR WORKSITE SUPERVISORS

Scenario

A furniture manufacturer, All Frames Co. (AFC), 

needs machine operators in production. The company 

contracts with Must Staffing to provide TWs. Must 

Staffing hires ten TWs as power press operators and 

sends them to work on-site at AFC. Must Staffing 

also hires an on-site staffing representative to coordinate payroll and other administrative functions, but 

this representative has no supervisory role. Before 

sending the TWs to the AFC worksite, Must Staffing 

plays a general safety and health awareness training 

video for them, including a brief section on machine 

guarding. At the worksite, a supervisor from AFC 

assigns each of the TWs to a particular work area 

and machine, instructs them to begin working on their 

assigned tasks, and checks on their work throughout 

the shift. On the assumption that the TWs have experience working with mechanical power presses, no 

site- or task-specific instruction is provided by AFC. 

Best practices 

Although Must Staffing played a general safety and 

health awareness training video with a brief section on 

machine guarding, it is still necessary for the TWs to 

receive site- and task-specific training from AFC. Siteand task-specific training must be provided regardless 

of how much prior experience the TWs have had 

working with mechanical power presses. AFC supervises and controls the day-to-day work of the TWs at 

its facility. Therefore, AFC is in the best position to 

provide the TWs with site- and task-specific training. 

The responsibility of providing site- and task-specific 

training does not shift to Must Staffing just because 

they hired an on-site staffing representative. For this 

failure to provide appropriate site- and task-specific 

training, AFC may be subject to an OSHA citation. 

AFC should provide the TWs with site- and task-specific training that is identical or equivalent to that 

provided to AFC’s own employees performing the 

same or similar work. This training should include 

instructions on how to operate the mechanical power 

presses safely, pursuant to the American National 

Standards Institute (ANSI) B11 standards and OSHA 

standard 29 CFR 1910.217(f)(2), and how to properly 

don, doff, adjust and maintain any required PPE, as 

well as its limitations and shelf life. This training 

should also include site-specific information on who 

to contact regarding safety and health issues and 

concerns; how to report work-related injuries, illnesses, 

and close-calls to AFC and Must Staffing and what 

will happen after doing so; emergency procedures, 

including exit routes and how to obtain first aid; and 

information on how TWs can participate in various 

aspects of AFC’s safety program. After site- and 

task-specific training has been provided, AFC should 

have the TWs complete a knowledge assessment to 

ensure they understand key concepts from the training 

and then should re-train the TWs if needed. 

AFC should also provide training to its own employees 

who will be supervising and controlling the work of 

TWs, and employees who will interact with the TWs. 

Supervisory training should include information on the 

approved tasks to be performed by TWs and emphasize that TWs should not be asked to perform new 

tasks without first obtaining written approval from 

the SC and providing the TWs with additional training 

and PPE if needed. Supervisors of TWs should also 

be trained on 1) the potential need to provide extra 

mentoring and supervision to new TWs who may be 

inexperienced with the assigned tasks and unfamiliar 

with the worksite; 2) employer responsibilities and 

workers' rights and responsibilities under OSHA law; 

3) how to communicate with TWs about their performance and safety-related behavior; 4) the safety 

and health responsibilities of AFC and Must Staffing 

as they pertain to PPE and hazard communication 

for TWs; 5) AFC’s responsibility to provide site- and 

task-specific training to TWs as well as the contents 

of this training; and 6) AFC’s responsibility to report 

serious TW injuries and illnesses to OSHA and to record 

TW injuries and illnesses on their OSHA 300 Log. 

By following these best practices related to safety 

and health training, AFC will ensure both new TWs and 

their worksite supervisors are well-prepared to contribute to an optimally safe and effective workforce.

Protecting Temporary Workers: Best Practices for Host Employers

8
SECTION 3 : Injury and Illness Reporting, Response, and Recordkeeping

Injury and Illness Reporting, Response, 

and Recordkeeping

Effective injury and illness reporting, response, and recordkeeping are vital to preventing future incidents. 

Reporting

With regards to reporting of TW injuries and illnesses, 

HEs should do the following: 

• Promote injury and illness reporting. Ensure TWs are 

aware of procedures to report work-related injuries, 

illnesses, and close-calls and are encouraged to communicate safety and health concerns without fear of 

retaliation (such as through an anonymous safety 

hotline). 

• Inform staffing company. Inform the SC immediately 

if a TW experiences a work-related injury, illness, or 

close-call so they are aware of the hazards facing 

their workers and can start the workers’ compensations claims process without delay.

• Report to OSHA. Report fatalities to OSHA within 8 

hours and injuries and illnesses involving amputation, 

loss of an eye, or in-patient hospitalization within 

24 hours. Reporting requirements vary in states with 

OSHA-approved state plans, so it is important to 

check state-specific occupational safety and health 

laws (https://www.osha.gov/stateplans/).

Response

With regards to responding to TW injuries and illnesses, 

HEs should do the following:

• Conduct joint incident investigations. Engage in 

partnership with the SC to conduct thorough investigations of TW injuries, illnesses, and close-calls, 

including involvement of the affected workers, in 

order to determine the root causes, what immediate 

corrective actions are necessary, and opportunities to 

improve their respective injury and illness prevention 

programs.

• Coordinate medical treatment and return to work. 

Ensure TWs and their supervisors are aware of the 

general procedures for coordinating medical treatment and return to work (if applicable) following a 

work-related injury or illness.

Recordkeeping

With regards to recordkeeping of TW injuries and illnesses, 

HEs should do the following:

• Record on OSHA 300 Log. Record TW injuries and 

illnesses on their OSHA 300 Log; OSHA requires that 

injury and illness records be kept by the employer 

who is providing day-to-day supervision and controlling the means and manner of the work, which in 

most cases is the HE (see 29 CFR 1904.31(b)(2)).

• Complete staffing company documentation. Complete 

SC documentation of the incident as required by the 

SC's workers' compensation carrier (for example, a 

Supervisor's Report of Injury/Illness Form).

• Fulfill records requests. Coordinate with the SC 

to make injury and illness records available upon 

request of a TW or worker representative, as indicated in the written contract.

Protecting Temporary Workers: Best Practices for Host Employers

9
SECTION 3 : Injury and Illness Reporting, Response, and Recordkeeping

E X A M P L E— I N J U R Y A N D I L L N E S S R E P O R T I N G , R E S P O N S E , A N D R E C O R D K E E P I N G 

Scenario 

WXY Staffing has 125 TWs working at Generic Assembly, 

a manufacturing facility. The SC provides an on-site 

manager at Generic Assembly’s facility to manage the 

TWs’ payroll and attendance and to provide counseling 

when needed. Generic Assembly provides day-to-day 

supervision of the TWs. One of the TWs sustains a back 

strain while lifting a 25-lb part. Generic Assembly contacted WXY Staffing immediately to inform them of the 

injury. The TW went to a clinic and returned with a work 

restriction of no lifting over 20 lb. WXY Staffing placed 

the TW in a job with a different HE that did not require 

lifting over 20 lb until she recovered and was able to 

return to her original job at Generic Assembly.

Best practices 

Because the restriction keeps the TW from performing one or more of their “routine job functions” 

(activities the TW regularly performs at least once 

per week), the injury is considered recordable. Since 

Generic Assembly provides day-to-day supervision 

of the TWs, the injury should be recorded on their 

OSHA 300 Log, including the number of restricted 

days worked. According to the 2014 OSHA/NIOSH 

Recommended Practices: Protecting Temporary 

Workers document, day-to-day supervision occurs 

when the employer controls “the means and 

manner of the temporary employee’s work” (p. 3). 

Even though WXY Staffing provided the injured 

TW with restricted duty outside of Generic Assembly’s facility, the injury is still recorded on Generic 

Assembly’s OSHA 300 Log, including the number 

of restricted days worked. If no restricted duty 

was provided by either Generic Assembly or WXY 

Staffing, it would be classified as a case involving 

days away from work, with the days away counted 

on Generic Assembly’s OSHA 300 Log. 

Generic Assembly did the right thing by informing 

WXY Staffing of the injury immediately. In addition, 

both parties should engage in a partnership to 

conduct a thorough investigation, including involvement of the affected workers, in order to determine 

the root causes of the injury and agree on a course 

of corrective steps both parties can take to prevent 

similar injuries from occurring in the future.

By following these best practices, Generic Assembly 

will adhere to and go beyond compliance with OSHA’s 

reporting and recordkeeping requirements and reduce 

the likelihood that other workers, including both temporary and permanent, will experience back strain injuries 

(which can be very costly) in the future. 

Protecting Temporary Workers: Best Practices for Host Employers

10
SECTION 4 : Summary and the Need for Proactive Safety Management

Summary and the Need for Proactive 

Safety Management

By following the best practices outlined in this 

document, HEs can do their part to optimize the safety, 

health, and productivity of their workers, both permanent 

and temporary. However, as stated in the Disclaimers on 

page 2, this document is not meant to replace the formal 

elements of an occupational safety and health program.

In a joint-employer environment, implementing a comprehensive occupational safety and health management system is 

the most effective way to anticipate risk, leverage teamwork, 

and drive continual improvement toward keeping workers 

safe and healthy. Such a system enables an organization to 

integrate critical safety controls and management processes 

to maintain safe operations and acceptable levels of risk. 

When a business makes occupational safety and health a 

priority, workers return home safe to their loved ones, quality 

and productivity flourish, and the company can achieve sustainable growth, meet social responsibilities, and be viewed as 

a reputable employer. Organizations of any size can adapt the 

principles of these systems related to hazard identification, risk 

management, effective training, management leadership, and 

workforce participation. The ASSP Z10 Guidance Manual is a 

free, quick-start guide to implementing occupational safety 

and health management systems in small and medium-size 

organizations (see ASSP Z10 Guidance Manual under More 

Information and Resources on the next page).

Protecting Temporary Workers: Best Practices for Host Employers

11
SECTION 5 : More Information and Resources

More Information and Resources

OSHA Temporary Worker Initiative Bulletins

OSHA has issued a series of bulletins outlining recommended 

practices regarding the joint safety and health responsibilities 

of HEs and SCs pertaining to the following:

• Injury and Illness Recordkeeping Requirements

• PPE

• Whistleblower Protection Rights

• Safety and Health Training

• Hazard Communication

• Bloodborne Pathogens

• Powered Industrial Truck Training

• Respiratory Protection 

• Noise Exposure and Hearing Conservation 

• Safety and Health in Shipyard Employment

• The Control of Hazardous Energy (Lockout/Tagout)

Visit https://www.osha.gov/temp_workers/ to access these 

bulletins as well as the 2014 OSHA/NIOSH Recommended 

Practices: Protecting Temporary Workers document. 

ASSP Z10 Guidance Manual

The ASSP Z10 Guidance Manual outlines a proven approach 

to managing safety and health risks, and provides resources, 

tools, and practical examples tailored to the needs of smaller 

organizations. You will find useful forms and checklists to 

help you assess your safety program and identify areas for 

improvement, as well as information on hazard identification, 

emergency preparedness and response, and safety metrics. Of 

particular interest to both HEs and SCs alike are sections on 

management/workforce participation and leadership, hazard 

assessment, and communications for a joint-employer environment. Table T-2 provides a starting point and allows flexibility 

to scale and approach contributions by each employer. 

Visit https://store.assp.org/PersonifyEbusiness/Store/

Product-Details/productId/201243100 to access this free 

resource.

ANSI/ASSP A10.33 Standard

The ANSI/ASSP A10.33 Standard addresses multi-employer 

worksites for construction and demolition industries.

Protecting Temporary Workers: Best Practices for Host Employers

12
SECTION 6 : Background

BACKGROUND

This document was created by NIOSH and the National Occupational Research Agenda (NORA) Services Sector Council 

(https://www.cdc.gov/nora/councils/serv/default.html) 

Contingent Workers Workgroup (CWW). NORA is a partnership program, stewarded by NIOSH, that aims to stimulate 

innovative research and improved workplace practices. 

NORA consists of ten industry sectors based on major 

areas of the U.S. economy, and seven safety and health 

cross-sectors organized according to the major safety and 

health issues affecting the U.S. working population. 

The NORA Services Sector is a large and highly diverse sector 

with over 68 million U.S. workers distributed across 11 major 

North American Industry Classification System (NAICS) 

industry groups (https://www.cdc.gov/nora/sectorapproach.

html). It ranges from teachers to hotel housekeepers, movie 

producers to building cleaners, landscapers to librarians, 

and bank tellers to restaurant cooks, among many other 

occupations. The work environments in the services sector 

are varied and, as such, so are the occupational hazards.

Each NORA industry sector and safety and health cross-sector 

has a council that aims to 1) develop a national research 

agenda to reduce injuries and illnesses within the sector/

cross-sector and 2) address the research agenda through 

information exchange, partnership building, and enhanced 

dissemination and implementation of evidence-based 

solutions. The NORA Services Sector Council comprises 

more than 50 members from industry, professional and 

trade associations, government, academia, and worker 

organizations. 

An important priority for the services sector is to address 

the needs of workers who experience disproportionate incidences of occupational injuries and illnesses. In July 2018, 

a subset of the NORA Services Sector Council formed the 

CWW with the goal of protecting and promoting the safety 

and health of TWs. The CWW has members representing 

HEs, SCs, and worker organizations, among others, allowing 

for diverse and inclusive viewpoints on how to best protect 

and promote the safety and health of TWs (see below for a 

full list of CWW members).

Given HEs’ high level of control over the work and work 

environment, the CWW decided to start with a campaign 

focusing on HEs. Specifically, the workgroup identified a 

need for an in-depth set of best practices for HEs to follow 

to ensure they are going beyond compliance to protect 

the safety and health of TWs. An initial draft was based, 

in part, on the guidance issued through the OSHA Temporary Worker Initiative, including the 2014 OSHA/NIOSH 

Recommended Practices: Protecting Temporary Workers

document and the Temporary Worker Initiative bulletins 

on various safety and health topics (these resources can 

be found at https://www.osha.gov/temp_workers/). Other 

sources considered when drafting these best practices 

Protecting Temporary Workers: Best Practices for Host Employers

13
SECTION 6 : Background

include resources from the National Safety Council (NSC) 

and Business and Legal Resources (BLR) and the knowledge and expertise of the workgroup members. The CWW 

solicited feedback on the initial draft from HEs and other 

stakeholders (see list below) and modifications were made 

based on the feedback received. The American Society 

of Safety Professionals (ASSP), the American Staffing 

Association, and the Safety and Health Assessment and 

Research for Prevention (SHARP) Program located within 

the Washington State Department of Labor and Industries 

also provided feedback, which was incorporated into the 

final draft.

Contingent Workers Workgroup members

• Tim Bell, Chicago Workers’ Collaborative

• Anasua Bhattacharya, NIOSH

• Scott Bicksler, Aerotek, Inc.

• Diana Ceballos, Boston University

• Jacqueline Chan, California Department of Public Health

• Ron Chylinski, EmployBridge Workforce Specialists

• Amanda Crim, American Hotel and Lodging Association

• Tom Cunningham, NIOSH

• Sharon Davis, Elwood Staffing

• Scott DeBow, Randstad

• Dave DeSario, Temp Worker Justice

• Michael Foley, SHARP Program, Washington State 

Department of Labor and Industries

• Rebecca Guerin, NIOSH

• Matt Gunter, U.S. Bureau of Labor Statistics

• Sarah Hughes, NIOSH

• John King, OSHA

• Robert Lewellen, AtWork

• Carmen Martino, Rutgers Occupational Training and 

Education Consortium

• Lauren Menger-Ogle, NIOSH

• Christopher Mundschenk, Building Service Contractors 

Association International

• Jack Nunes, Lear Corporation

• Carol Pariente Lippi, EmployBridge Workforce Specialists

• Ketki Patel, Texas Department of State Health Services

• Donna Pfirman, NIOSH

• Michael Quinn, Department of the Interior

• Maggie Robbins, Worksafe

• Nancy Romano, NIOSH

• Marie-Anne Rosemberg, University of Michigan, 

School of Nursing

• Gary Roth, NIOSH

• Brittany Sakata, American Staffing Association

• Kirk Sander, National Waste and Recycling Association

• Adam Seidner, The Hartford

• Katie Shahan, NIOSH

• Eric Sygnatur, U.S. Bureau of Labor Statistics

• Jennifer Topmiller, NIOSH

• Jora Trang, Worksafe

• Paul Vescio, Aon

• Joe Zanoni, University of Illinois at Chicago

Provided feedback

• American Staffing Association Safety Committee 

(via Brittany Sakata)

• Sherry Baron, Queens College

• Stan Brubaker, Liberty Mutual Insurance

• Megan Casey, NIOSH

• Cammie Chaumont-Menendez, NIOSH

• Seleen Collins, NIOSH (Retired)

• EmployBridge clients (via Ron Chylinski)

• Tim Fisher, ASSP

• Amy Harper, National Safety Council

• Lou Kimmel, New Labor

• Marsha Love, University of Illinois at Chicago, School 

of Public Health

• Joyce Matson, All StarZ Staffing and Consulting

• Susan Moore, NIOSH

• Andrea Okun, NIOSH

Other support

• Kofi Arhin, OSHA — Former Contingent Workers 

Workgroup member

• Bryan Beamer, Former NIOSH — Former Contingent 

Workers Workgroup member

• Linda Delp, University of California, Labor Occupational Safety and Health (LOSH) Program — Former 

Contingent Workers Workgroup member

Protecting Temporary Workers: Best Practices for Host Employers

14
SECTION 6 : Background

• Cherie Estill, NIOSH — Former Council Co-Chair and 

Former NIOSH Services Program Coordinator

• Sarah Felknor, NIOSH — Former NIOSH Services 

Program Manager

• Joan Karr, NIOSH — Former Contingent Workers 

Workgroup member

• Sarah Mitchell, NIOSH — Former Contingent Workers 

Workgroup member 

• Emily Novicki, NIOSH — NORA Coordinator

• Michelle Owens-Gary, CDC

• Rene Pana-Cryan, NIOSH — Former Contingent 

Workers Workgroup member

• Nikki Trucco, NIOSH

• Vanessa Williams, NIOSH 

NORA Services Sector Council leadership

• Michael Foley, SHARP Program, Washington State 

Department of Labor and Industries — Council 

Co-Chair

• Lauren Menger-Ogle, NIOSH — Council Co-Chair, 

NIOSH Services Program Co-Coordinator

• Sarah Hughes, NIOSH — NIOSH Services Program 

Co-Coordinator

• Donna Pfirman, NIOSH — NIOSH Services Program 

Assistant Coordinator

• Paul Schulte, NIOSH (Retired) — Former NIOSH 

Services Program Manager

• Christine Whittaker, NIOSH — NIOSH Services 

Program Manager

Protecting Temporary Workers: Best Practices for Host Employers

15
SECTION 7 : Appendix

APPENDIX

Evaluation and Contracting—Best Practices Checklist for Host Employers

Evaluation

Prior to writing and signing a contract, HEs and SCs 

should evaluate all facets of safety and health related 

to each organization and the jobs TWs are being hired 

to perform. As part of this process, HEs should do the 

following:

 Conduct a joint risk assessment. Conduct a 

joint risk assessment with the SC, including 

a review of these items: 

F Task assignments

F Written job descriptions

F Anticipated exposures

F Job hazard analyses

F Equipment and/or machinery

F Worksites 

 Provide information. Provide the SC with 

requested safety data, safety and health 

program materials, and other information 

that will allow them to evaluate the safety 

and health of the worksites.

 Allow site visits. Invite a representative 

from the SC to visit the worksites and 

conduct a walkthrough.

 Ensure commitment to safety and health.

Ensure the SC has a commitment to safety 

and health, including the following:

F A process to evaluate job candidates 

for the necessary qualifications and/or 

experience

F An adequate safety and health program, 

which includes a general safety and health 

awareness training provided to TWs prior 

to placing them on an assignment

Contracting

The written contract between the HE and the SC should 

clearly specify the following information:

 Pertinent job details

F Approved tasks and qualifications. The 

approved tasks and qualifications as 

stated in the written job descriptions, 

including the following:

F The tasks the TWs are approved to 

perform

F Any hazardous tasks the TWs will NOT 

perform and any equipment and/or 

machinery they are NOT allowed to 

operate

F The necessary qualifications and/

or experience the TWs must have to 

perform the job

F Hazards and controls. All anticipated 

hazards that may be encountered by the 

TWs and hazard controls that will be in 

place, including information about safety 

data sheets (SDSs)

F Training. The training each employer will 

provide to the TWs before they start their 

assignment and in which language(s) it 

will be offered

F Personal protective equipment. What 

personal protective equipment (PPE) will be 

needed and which employer will: 1) pay for 

and supply it; 2) ensure it’s the appropriate 

type and fits correctly; 3) conduct a medical 

evaluation and fit test for all types of PPE 

that require it; and 4) train the TWs on how 

to properly use and maintain it before they 

start their assignment

 Communication and documentation 

responsibilities

F Qualifications and experience. What documentation the SC will provide to the HE 

regarding each TW’s specific qualifications 

and/or experience relevant to the tasks to 

be performed

F Ongoing risk assessment. Specific time 

intervals at which the HE and SC will jointly 

review all work and worksites to identify 

potential safety and health hazards and 

update necessary training and PPE for each 

TW on an ongoing basis

Protecting Temporary Workers: Best Practices for Host Employers

16
SECTION 7 : Appendix

F Changes to job tasks. The steps the HE will 

take in order to make changes to job tasks, 

including these:

F Providing an updated written job 

description to the SC and the TWs 

and providing an updated job hazard 

analysis to the SC

F Updating training and PPE 

requirements

F Giving the SC enough notice to 

evaluate the new tasks (and worksites 

if applicable) and the ability of the TWs 

to take on the new tasks

F Receiving written approval of the 

change from the SC before TWs undertake the new tasks

F Changes to hazards. The steps the HE will 

take for providing the SC with written disclosures of any changes to hazards that 

occur during the duration of the contract

F Training. The procedures for maintaining 

and sharing documentation of safety and 

health training provided by both employers

F OSHA investigation. The responsibility of 

the HE to inform the SC when it is under 

OSHA investigation and the nature of the 

complaint

 Injury and illness reporting, response, and 

recordkeeping responsibilities

F Reporting by temporary workers. Procedures for TWs to report work-related 

injuries, illnesses, and close-calls and to 

communicate safety and health concerns 

to the HE and the SC without fear of retaliation, as well as the procedures for both 

employers to inform one another immediately after a TW injury, illness, close-call, or 

concern is reported

F OSHA reporting and recordkeeping. The 

responsibility of the HE to report serious 

TW injuries and illnesses to OSHA and to 

record TW injuries and illnesses on their 

OSHA 300 Log

F Coordinating medical treatment and return to 

work. The general procedures for coordinating medical treatment and return to work (if 

applicable) following a TW injury or illness

F Fulfilling record requests. Which employer 

will make injury and illness records 

available upon the request of a TW or 

worker representative

 Other aspects of workplace safety 

and health

F Supervision. Which employer is responsible 

for providing direct supervision of the TWs

F Peer mentors. The process by which each 

TW may be paired with an experienced and 

knowledgeable permanent worker to serve 

as their mentor or ”go to” person and how 

the process will be overseen and periodically reviewed by mid- and senior-level 

managers from both employers

F Workers’ compensation. Which employer is 

required to verify and pay for workers’ compensation coverage for the TWs during the 

duration of the contract 

F Infectious disease prevention and response.

How the HE and the SC will protect TWs 

from infectious diseases; HEs should apply 

the same infectious disease prevention and 

response policies and protections to TWs 

that are applied to the HE's own employees.

F Medical surveillance and screening. The 

responsibility of the HE to conduct medical 

surveillance and screening of the TWs if 

they are exposed to a workplace condition 

that requires it and to share the results with 

the SC and the TWs

F Secure sites. If the TWs will be placed at 

secure worksites, how the HE and SC will 

work together to establish a protocol for 

the TWs and SC representatives to gain 

access to the sites, including protocols to 

ensure personal security

F Ensuring standard and consistent work 

practices. Processes in place to ensure that 

standard and consistent work practices are 

documented, taught, and enforced

F Tracking effectiveness. Ways to track the 

effectiveness of safety and health policies 

and practices of both employers.

Protecting Temporary Workers: Best Practices for Host Employers

17
SECTION 7 : Appendix

Training for Temporary Workers and Their Worksite Supervisors—Best Practices 

Checklist for Host Employers

Temporary Worker Training

Site- and task-specific safety and health training should 

be provided for all TWs before they start a new assignment or start new jobs/tasks on existing assignments. 

Site- and task-specific training for TWs should include 

information on the following topics:

 Approved tasks and qualifications. The 

approved tasks and qualifications as stated 

in the written job descriptions, including:

F The tasks the TWs are approved to perform 

with an emphasis that the TWs should not 

perform any new tasks without the HE first 

obtaining written approval from the SC

F Any hazardous tasks the TWs will NOT 

perform and any equipment and/or 

machinery they are NOT allowed to operate

 Hazard identification and control. How to 

recognize site- and task-specific hazards 

and understand the best ways to reduce 

and/or eliminate them, including the 

location of SDSs and how to obtain copies

 Personal protective equipment. Required 

PPE, including this information:

F Which employer will: 1) pay for and supply 

it, 2) ensure it’s the appropriate type and 

fits correctly, and 3) conduct a medical 

evaluation and fit test for all types of PPE

that require it

F How to properly don, doff, adjust, and 

maintain it, as well as its limitations 

and shelf life (or provide a review of this 

information if the SC has already provided 

this training as stated in the written 

contract)

 OSHA laws. Employer responsibilities 

and workers’ rights and responsibilities 

under OSHA law, including the Right to 

Refuse Dangerous Work (https://www.

osha.gov/workers/right-to-refuse) and 

Whistleblower Protection Rights (https://

www.osha.gov/Publications/OSHA3781.

pdf), with an emphasis that TWs have 

the same rights and responsibilities as 

non-TWs

 First aid. How to obtain first-aid treatment

 Emergency procedures. Site- and taskspecific emergency procedures, including 

exit routes

 Reporting safety and health incidents and 

concerns. The responsibility of the TWs to 

report all work-related injuries, illnesses, 

and close-calls and to communicate safety 

and health concerns as soon as possible 

to both the HE and the SC, including the 

following:

F Procedures for how to do so

F What to expect after reporting 

F An emphasis that they will not be punished 

or looked down upon for doing so

 Secure sites. If the TWs will be placed at 

secure worksites, how to gain access to 

the sites, including protocols to ensure 

personal security

 Safety and health program participation. 

How the TWs can participate in the HE’s 

safety and health program, including safety 

meetings/committees, toolbox talks, 

scheduled trainings, and hazard-specific 

programs

In relation to safety and health training for TWs, HEs 

should also do the following:

 Assess knowledge. Have the TWs complete 

a knowledge assessment (in a language 

they understand) to ensure they understand 

key concepts from site- and task-specific 

safety and health training before starting 

the assignment.

F If gaps in knowledge are found, repeat 

training and reassess the workers’ 

knowledge.

 Document training. Document the datewhen site- and task-specific training for the 

TWs is completed, the names of workers 

trained, and the names of the instructors.

F Provide copies of site- and taskspecific training documentation to 

the SC upon request.

Protecting Temporary Workers: Best Practices for Host Employers

18
SECTION 7 : Appendix

 Evaluate staffing company training 

materials. Review the general safety and 

health awareness training provided by 

the SC to determine if it is adequate and 

includes these items:

F Specific details of the assigned job

F A basic overview of employer responsibilities and workers' rights and 

responsibilities 

F Common hazards and protections, including any PPE provided by the SC

F If the general safety and health awareness 

training provided by the SC is not 

sufficient, the HE should document 

and communicate this to the SC with 

a recommendation for what additional 

training the SC should provide.

Supervisor Training

In addition to providing site- and task-specific training 

to TWs, HEs should also provide training to those who 

will be supervising the work of TWs. This training 

should include information on the following topics:

 Approved tasks. The approved tasks as 

stated in the written job descriptions, 

including the following:

F The tasks the TWs are approved to perform 

with an emphasis that the TWs should not 

perform any new tasks without the HE first 

obtaining written approval from the SC

F Any hazardous tasks the TWs will NOT 

perform and any equipment and/or 

machinery they are NOT allowed to operate

 Changes to job tasks. The process for 

modifying job tasks as described in the 

written contract

 Mentoring and supervision. Their 

responsibility to provide the TWs with 

supervision that is identical or equivalent 

to that provided to the HE's own employees 

performing the same or similar work 

and the potential need to provide extra 

mentoring and supervision to new TWs who 

may be inexperienced with the assigned 

tasks and unfamiliar with the worksites

 OSHA laws. Employer responsibilities and 

workers’ rights and responsibilities under 

OSHA law, including the Right to Refuse 

Dangerous Work (https://www.osha.gov/

workers/right-to-refuse) and Whistleblower 

Protection Rights (https://www.osha.gov/

Publications/OSHA3781.pdf), with an 

emphasis that TWs have the same rights 

and responsibilities as non-TWs

 Communication and reporting. How to 

communicate with the TWs about their 

performance and safety-related behavior 

and encourage them to report all workrelated injuries, illnesses, close-calls, and 

safety and health concerns as soon as 

possible

 Joint responsibilities. The safety and 

health responsibilities of the HE and the 

SC, including those pertaining to training, 

PPE, hazard communication, and injury 

and illness reporting, response, and 

recordkeeping as specified in the written 

contract.

Protecting Temporary Workers: Best Practices for Host Employers

19
SECTION 7 : Appendix

Injury and Illness Reporting, Response, and Recordkeeping—Best Practices Checklist 

for Host Employers

Reporting

With regards to reporting of TW injuries and illnesses, 

HEs should do the following:

 Promote injury and illness reporting. Ensure 

the TWs are aware of procedures to report 

work-related injuries, illnesses, and closecalls and are encouraged to communicate 

safety and health concerns without fear of 

retaliation.

 Inform staffing companies. Inform the SC 

immediately if a TW experiences a workrelated injury, illness, or close-call.

 Report to OSHA. Report fatalities to OSHA 

within 8 hours and injuries and illnesses 

involving amputation, loss of an eye, 

or in-patient hospitalization within 24 

hours. Reporting requirements vary in 

states with OSHA-approved state plans, 

so it is important to check state-specific 

occupational safety and health laws 

(https://www.osha.gov/stateplans/).

Response

With regards to responding to TW injuries and illnesses, 

HEs should do the following:

 Conduct joint incident investigations. 

Engage in partnership with the SC to 

conduct thorough investigations of TW 

injuries, illnesses, and close-calls, including 

involvement of the affected workers, in 

order to determine the following:

F The root causes

F Corrective actions 

F Opportunities to improve their respective 

injury and illness prevention programs

 Coordinate medical treatment and return 

to work. Ensure TWs and their supervisors 

are aware of the general procedures 

for coordinating medical treatment and 

return to work (if applicable) following 

a work-related injury or illness.

Recordkeeping

With regards to recordkeeping of TW injuries and

illnesses, HEs should do the following:

 Record on OSHA 300 Log. Record TW 

injuries and illnesses on their OSHA 300 

Log. 

 Complete staffing company documentation. 

Complete SC documentation of the 

incident as required by the SC’s workers’ 

compensation carrier (for example, a 

Supervisor’s Report of Injury/Illness Form).

 Fulfill record requests. Coordinate with 

the SC to make injury and illness records 

available upon request of a TW or 

worker representative as indicated in the 

written contract.

Protecting Temporary Workers: Best Practices for Host Employers

20
 P R O M O T I N G P R O D U C T I V E W O R K P L A C E S 

 T H R O U G H S A F E T Y A N D H E A LT H R E S E A R C H 

DHHS (NIOSH) Publication No. 2022-126

DOI: https://doi.org/10.26616/NIOSHPUB2022126