Temp workers offer employers flexibility and cost savings but when it comes to safety, it can’t be presumed that just temps, who are off company payroll, are also off a company’s radar screen. Workplace cost and safety concerns, as well as a decision last month by OSHA, means employers need to make sure their temps are fully involved in their safety programs.
Last month, OSHA made its position clear when it issued a memorandum to its regional administrators, which directed its field inspectors to make “concerted effort using enforcement, outreach and training to assure that temporary workers are protected from workplace hazards.” In the memo, Thomas Galassi, director of OSHA's Directorate of Enforcement Programs, directed inspectors to identify if temps are working at a jobsite and make sure they are receiving safety training "in a language and vocabulary" they understand, warning that:
Recent inspections have indicated problems where temporary workers have not been trained and were not protected from serious workplace hazards due to lack of personal protective equipment when working with hazardous chemicals and lack of lockout/tagout protections, among others.
The memo referenced an incident where the agency cited Bacardi Bottling Company for a workplace fatality which took place at their Jacksonville, Florida facility last year, as well as a report from the Bureau of Labor Statistics which found that:
Fatal work injuries involving contractors accounted for 542 – or 12 percent – of the 4,693 fatal work injuries reported. Hispanic/Latino contractors accounted for 28 percent of fatal work injuries among contractors, well above their 16 percent share of the overall fatal work injury total for the year.
In addition to the OSHA mandate, there are some other reasons to consider that companies should include temps in their safety program - and from my experience, it's not that hard to do.
While temps aren’t direct-hire employees, just like contractors and subcontractors, there are some distinct differences between temps and subcontractors with regard to the degree of oversight and interaction that takes place on a jobsite. Contractors and subcontractors are hired to perform specific kinds of work and generally the company is fairly limited into their ability to direct the work, while temps often work alongside and with employees and work under the direction of the company’s supervisors and managers.
It's also important to consider that a contractor/subcontractor generally performs specific kinds of work, which means they’re usually also familiar with the related hazards. That includes their own safety training and on-staff specialists while temp agencies generally provide employees for a wide range of work, including industrial sites, construction projects and offices. Most don’t have safety personnel and the few agencies that do usually just have them responsible for little more than filing incident/injury reports and Workers’ Comp claims. So if you don't do it for their employees, chances are that nobody will.
I’ve long made sure to provide general safety training, such as “toolbox” reviews”, as well as specific hazard training, to temps. I include the temps with direct employees in these training and review sessions and make sure they sign a separate sign-in sheet designated for temps to make sure we track their training. I also make sure their agency is aware of their training to help them qualify for future opportunities where safety training is a must.
Keeping in mind the knowledge that an unsafe worker is a danger to everyone around them, an unsafe temp is a threat to everyone in the workplace. Safety training for temps isn’t just a matter of complying with OSHA expectations. It’s a conscientious way to protect temps as well as your own workers and assets – and it usually won’t take any longer to include them anyway.
So how are you including your temps in your company’s safety program?