Our "tip" this month is a gentle reminder to all those that utilize staffing services to remember your responsibility to include all OSHA recordable injuries experienced by employees supplied by temp help companies at your facility on your company's OSHA 300 log.
To some there is a misconception that these injuries should be recorded on the staffing company's log. According to OSHA Section 1904.31 the party that provides the employee day to day supervision is responsible for the record-keeping of the injury/accident.
The reason this is more important than ever to get it right is because OSHA on September 30, 2009, initiated a National Emphasis Program on Injury and Illness Record-keeping (NEP). The scope of NEP was increased this past September and will not expire until February 2012.
OSHA has determined that under reporting may exist in some industries that have traditionally high accident rates. Their goal is to make sure employers are accurately completing the OSHA 300 log.
OSHA has targeted employers mainly in the manufacturing and health services industries, but all need to be aware.
Inspections can be very detailed and time consuming. They can include inspection of medical records, workers compensation files, insurance records, payroll/attendance reports, safety reports, disciplinary records and just about anything else related to documenting employee activities. The OSHA inspector will use this information to recreate an OSHA 300 log and then will compare it to the one posted by the company.
The inspector can even conduct interviews with the person that supervises the activities just out lined and is REQUIRED to conduct a limited walk-around inspection of your facility.
Hefty fines can be levied. Lowe's Home Centers in Dayton/Cincinnati were hit with $182,000 in proposed penalties earlier this year for record-keeping violations. Enough said.
You might be wondering why I used the term "gentle reminder" in reference to this subject matter. Several years ago I had a discussion about this subject with one of our larger clients in the area. That person insisted the record-keeping was our responsibility and not theirs. Honestly, I tried to be very gentle in my persuasion and I even gave the individual the OSHA representative to contact to confirm my story. The rep had just provided our company with training on this subject. To make a long story short this client dropped us like a rock because they did not like my "help" on this matter. As it turned out, this was a good thing because they had lots to record concerning our employees if you know what I mean. I sometimes wonder if that former client ever got busted....but I don't spend a lot of time on it.
Remember you can easily visit the Department of Labor/OSHA website to obtain a copy of this requirement. Good luck.
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