OSHA Recordkeeping: Our Log or Theirs?

Your company hires temporary workers to complete a task.  One of the workers has a work related injury.  Let’s assume for this discussion that the injury is recordable.  Whose OSHA 300 Log is the injury recorded on?

This is a common question that we get during OSHA Recordkeeping training or while in the field reviewing a client’s OSHA logs.    Some of the criteria to consider when making this decision include:

  • Who supervises the employee?
  • Who provides tools and equipment for the employee?
  • Who provides instructions for the employee?
  • Who has the authority to assign work?

Generally, temporary employees are supervised by the host employer’s supervisor, assigned work  and instructions by the host employer, and provided tools and equipment by the host employer.  If this is the case, OSHA would expect to see this injury recorded on the host employer’s OSHA 300 Log.  In this example, the host employer would probably also be in the best position to correct the hazard that caused the injury.  Because of this, temporary workers’ injuries should almost always be recorded on the host employer’s OSHA Log.

But what if instead the injury occurred to a contractor working on site.  Would the injury still be recorded on the host employer’s log, or should it instead go on the contractor’s log?  We usually hire contractors because they know how to do something we either do not know how to do or do not want to do.  Contractors usually have their own equipment and supervision, and generally their injuries need to be recorded on their own logs.

We have created an OSHA Recordability Flow Chart that you can download to assist you with your record keeping.

One thought on “OSHA Recordkeeping: Our Log or Theirs?

  1. This becomes an even bigger issue because those companies that do not understand the reporting requirements for temporary workers aren’t implementing the necessary corrective actions for conditions and behaviors that cause injuries and illnesses to those workers, thus exposing their “own” employees to a higher level of risk.

    Additionally, they may be sending the wrong message about their safety program by reporting lower numbers and creating a “false sense of security” among the workforce.

    Like the blog, keep it going!

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