Staffing agency vs host employer OSHA training responsibility: who owes what

Last updated 2026-07-10

What is OSHA's basic rule on training responsibility for temp workers?

Both companies own the safety of a temp worker. When a staffing agency places someone at a host employer's site, each organization carries legal responsibility for that worker's health and safety. This is the joint employer doctrine, and OSHA has applied it to temporary workers since at least the early 1990s. Your staffing contract does not change it. You can agree in writing that the host covers all training, but that agreement does not transfer or erase the agency's regulatory duty in OSHA's eyes.

The legal foundation comes from Section 2(b)(1) of the Occupational Safety and Health Act of 1970, which says every employer has a general duty to provide a workplace free from recognized hazards. OSHA has consistently read "employer" to include any entity with the right to control a worker's activities, even when a staffing firm cuts the paycheck. ^[1]

In 2014, OSHA issued a policy memorandum titled "Protecting Temporary Workers," making clear that host employers and staffing agencies share compliance obligations and cannot contract them away. The memo states: "Both the host employer and the staffing agency have roles to play in ensuring worker safety and health." ^[2] That document has shaped every enforcement action involving temp workers since.

The practical split looks like this. The host controls the physical space, the equipment, the chemicals, and the daily work processes, so OSHA expects the host to deliver the hazard-specific and job-specific training. The agency controls the employment relationship and places workers across many sites, so OSHA expects the agency to provide general safety orientation and, critically, to verify that the host is actually training before workers start. The agency sets the floor. The host builds the house.

What training must the host employer provide to temporary workers?

The host owns the worksite hazards, so the host must train for them. That is not a soft suggestion. OSHA's training standards apply to whoever controls the work, and the host is the controlling employer for purposes of 29 CFR 1910 (general industry) and 29 CFR 1926 (construction) training requirements. ^[3]

Here is what that means on the ground. If temp workers will run forklifts, the host must provide forklift certification training under 29 CFR 1910.178(l) before those workers touch the equipment. If the host uses chemicals covered by hazard communication rules under 29 CFR 1910.1200, the host trains temps on those specific chemical hazards, the SDS sheets on site, and the labeling system in that facility. If the host has lockout/tagout procedures, the host trains temps on those procedures under 29 CFR 1910.147.

OSHA's 2014 memorandum says host employers should treat temp workers the same as permanent employees for training. Same content, same language accessibility, same documentation. A host cannot tell a temp to "watch the regular employees and pick it up" and call that training. ^[2]

Site-specific emergency action plan training under 29 CFR 1910.38 falls on the host too. Temp workers need to know the evacuation routes, the alarm signals, the muster points, and who to report to in an emergency at that particular building. A staffing agency sitting in its own office two towns over cannot deliver any of that.

What training is the staffing agency responsible for?

The agency owes two things: general safety orientation and oversight of host employer compliance. Neither is optional.

General orientation usually covers the agency's own safety policies, how to report a workplace injury (including reporting to the agency under its workers' comp policy), the worker's right to refuse unsafe work, how to contact OSHA, and a basic overview of hazard recognition. It does not need to be deep, but it needs to happen before placement, and the agency needs a record of it. ^[2]

The bigger obligation is verification. Before placing workers, the agency should ask the host which specific OSHA standards apply to the work, what training the host will provide, and when. Then the agency follows up to confirm it happened. OSHA has cited staffing agencies that claimed ignorance of a host's training failures, because OSHA's position is that the agency had a duty to inquire. Plenty of agencies genuinely do not know they carry this exposure.

Agencies should also watch for red flags when vetting a host. A host that cannot name which standards apply, refuses to share its safety program, or has a poor inspection history is a risk the agency is placing its workers into. Some agencies now build site safety audits into their service agreement, which protects workers and shrinks the agency's own citation exposure.

One more duty: recordkeeping. Under 29 CFR 1904, the employer who supervises the daily work (usually the host) records injuries on its 300 log, but the agency must provide injury and illness information to OSHA on request. Both parties need to know who is the "primary" recorder for temp worker injuries at that site. OSHA's recordkeeping rule puts it on the entity that directs the work day to day. ^[4] If you run the agency, make sure your contracts spell out that the host will log injuries and share those records with you.

How does OSHA actually split enforcement between the two employers?

OSHA looks at control. When it inspects a site and finds a training violation involving a temp worker, it asks who controlled the work, who had authority to fix the hazard, and who had the duty to train for it. Whoever had the most practical control over the specific hazard gets the citation. ^[5]

Most of the time the host gets cited for substantive training failures because the host controlled the worksite. The agency is more likely to get cited for failing to verify training happened, or for placing workers at a site with known hazards without confirming those hazards were addressed.

OSHA does cite both parties in a single inspection. A 2016 enforcement case from OSHA Region 5 involved a temp worker injured by a machine guarding hazard the host had not trained workers to avoid. The host was cited under 29 CFR 1910.212 for the guarding failure and under the general duty clause for the training failure. The staffing agency was cited for failing to inquire about site hazards before placement. The citations were separate, and neither party's citation reduced the other's penalty.

Penalties for serious training violations have climbed since OSHA raised its maximums in 2016 under the Federal Civil Penalties Inflation Adjustment Act. As of 2024, the maximum penalty for a serious violation is $16,131 per instance. Willful or repeated violations reach $161,323 per instance. ^[6] A training failure that kills someone can draw willful-level treatment.

If you run a staffing agency or a business that uses temps, the safest move is a written joint safety agreement with the host that names exactly who owns each training element. It does not eliminate your OSHA duty, but it creates clarity, closes gaps, and hands you a paper trail when OSHA comes asking.

Does the staffing agency or host employer need to document temp worker training?

Both should document, but the host must document for any standard that requires written records. Most major OSHA training standards include a recordkeeping requirement, and it lands on whoever delivers the training.

Take 29 CFR 1910.178(l)(6): forklift operators must be evaluated by a trained evaluator, and that evaluation must be documented. Since the host delivers forklift training, the host holds that record. Same logic for lockout/tagout training records under 29 CFR 1910.147, confined space entry training under 29 CFR 1910.146, and respiratory protection training under 29 CFR 1910.134.

The agency should document its general orientation: dates, topics, the trainer's name, and the worker's signature or acknowledgment. Agencies running a digital onboarding system have an edge here, because every click is timestamped.

My honest recommendation: agencies should require the host to send a copy of each temp worker's training completion records within the first week of placement. Put it in the staffing contract as a hard requirement. It protects the agency, confirms the host actually trained, and builds one clean file per placed worker. Most hosts will not push back if you frame it as a compliance formality rather than an audit.

Training records have no single OSHA retention period, because different standards demand different things. Forklift evaluations should be kept for the length of employment. HAZWOPER training records under 29 CFR 1910.120 must be kept at least three years. When in doubt, keep records three years minimum, because that is the typical OSHA lookback window for records-related violations.

What happens when a temp worker is injured and neither party trained them properly?

Shared liability. And it gets expensive fast.

BLS data from 2022 shows workers in temporary help services had an incidence rate of 2.0 nonfatal occupational injuries and illnesses per 100 full-time workers, roughly in line with the private sector average of 2.7. But injuries among temps tend to be more severe, because temps get assigned to hard physical work in manufacturing, warehousing, and construction during their first days on the job, before they have learned the site's hazards. ^[7]

When an injury happens and OSHA investigates, the agency will subpoena training records from both the host and the staffing firm. If records are missing or show training did not happen before the injury, OSHA can cite both parties under the relevant standard and, for the host, under the General Duty Clause (Section 5(a)(1) of the OSH Act). The staffing agency faces citation under the same clause if it failed its verification duty.

There is more than OSHA to worry about. The injured worker may bring a tort claim against the host, which is not shielded by workers' compensation exclusivity the way the staffing agency usually is. In many states the host is a "statutory employer" under workers' comp rules, which complicates things further. That is a legal question specific to each state's statute, and a business attorney who knows your state's law is the right person to answer it.

The lesson is simple. A training gap is a financial and legal exposure for both companies. Full onboarding training for a temp worker costs a fraction of the average workers' compensation claim, which NCCI pegged at $41,353 for lost-time claims in 2020. ^[8]

How should staffing agencies and host employers divide training responsibilities in a contract?

A staffing agreement is not a compliance document, but it is a useful coordination tool. The contract should spell out, in plain language, which party owns which training categories and how each documents completion. It should also state that both parties understand a contractual division of responsibilities does not alter their individual obligations under OSHA regulations. That sentence matters. It signals both parties have read the law, and it kills the argument that one side believed it had handed off all liability.

A workable template for the contract language divides training this way:

Training Category	Responsible Party	Documentation Holder
General safety orientation	Staffing agency	Staffing agency
Site-specific hazard training	Host employer	Host employer
Equipment-specific training (forklifts, etc.)	Host employer	Host employer
Chemical/HazCom training for on-site substances	Host employer	Host employer
Emergency action plan / evacuation	Host employer	Host employer
Lockout/tagout procedures	Host employer	Host employer
PPE selection and fit	Shared (agency for general, host for site-specific)	Both
Injury reporting procedure	Staffing agency	Staffing agency

The contract should also require the host to notify the agency of any change in work scope that introduces new hazards. A temp placed to do light assembly who then gets reassigned to chemical handling mid-placement needs updated training neither party may have planned for.

If you want a written safety program that formalizes your agency's obligations, SafetyFolio's safety program generator can build a staffing agency safety program in about 15 minutes, covering orientation requirements, host employer verification checklists, and injury reporting procedures.

Are there specific OSHA standards that apply differently to temp workers versus permanent employees?

No. OSHA has no separate tier of standards for temporary workers. Every training standard that applies to a permanent employee doing a job applies equally to a temp doing the same job. The 2014 policy memo made this explicit: "Host employers should treat temporary workers like any permanent worker in terms of training, hazard communication, and access to required protective equipment." ^[2]

What differs is the enforcement focus. OSHA's national emphasis programs and regional targeting have, at various times, named temporary worker safety as a priority. OSHA's Temporary Worker Initiative, launched in 2013, directs compliance officers to examine temp worker conditions during inspections of host employers. That initiative is still active. ^[9]

One area that catches both agencies and hosts off guard is osha training for industry-specific standards. If a host operates under the PSM standard (29 CFR 1910.119) for highly hazardous chemicals, that standard requires the host to train temporary employees and contract workers on the specific process hazards. The PSM rule has its own contractor safety management section (29 CFR 1910.119(h)) that puts affirmative obligations on the host to evaluate the safety performance of contractors and their employees, including temps. ^[10] That is a harder compliance job than most hosts realize.

Same goes for HAZWOPER (29 CFR 1910.120). A temp sent to a hazardous waste site needs the same HAZWOPER training as a permanent employee. The host cannot shortcut this by claiming the temp is "just doing general labor." If the work involves hazardous waste operations, the training requirement follows the work.

What is OSHA's Temporary Worker Initiative and does it affect my business?

OSHA launched the Temporary Worker Initiative (TWI) in April 2013, a multi-year enforcement and education effort aimed at the roughly 3 million temporary workers employed in the U.S. on any given day. ^[9] If you use temp workers or place them, this affects you.

Under TWI, compliance officers inspecting host employer sites are told to ask specifically about temp workers, review their training records, and check whether the host has a formal relationship with its staffing agencies that addresses safety. Officers also look at whether temps are assigned to more dangerous tasks than permanent employees, which OSHA treats as a red flag.

OSHA has published a series of TWI bulletins on specific hazard categories: amputations, musculoskeletal disorders, hexavalent chromium, and more. They are free on OSHA's website and worth reading if your host operations touch any of those hazards. ^[9]

For staffing agencies, TWI guidance encourages pre-placement site visits to assess hazards, a direct line to the host safety manager, and a copy of the host's written hazard assessment before workers arrive. Agencies that can show OSHA this kind of proactive structure come out of inspections far better than agencies leaning on a checkbox in the staffing contract.

How does language access factor into OSHA training for temporary workers?

This is where a lot of businesses carry real legal exposure, especially in agriculture, meatpacking, and construction. OSHA's general industry training standards require training in a manner and language employees can understand. The language is explicit in standards like 29 CFR 1910.1200(h)(1) for hazard communication: "Employers shall provide employees with effective information and training on hazardous chemicals in their work area." ^[11] OSHA reads "effective" to mean the worker can actually comprehend the content.

For temp workers who are not native English speakers, that puts an affirmative duty on whoever delivers the training (usually the host for site-specific content) to train in the worker's primary language or use an interpreter who can convey the technical content accurately. Playing an English video for a Spanish-speaking worker and checking a box is not compliant training under OSHA's interpretation.

Staffing agencies have a role here too. Agencies often know the language backgrounds of the workers they place, so they can flag it to the host during placement and, in some cases, supply language-specific orientation materials themselves. Agencies that place large numbers of workers who speak a specific language may want to build orientation materials in that language as standard practice.

OSHA has cited employers for training conducted in English when the workforce was largely non-English speaking. These citations are not rare in industries with big immigrant workforces. Professional translation or a bilingual trainer costs almost nothing next to the citation exposure.

What should a host employer do before a temp worker's first day on site?

The day-one gap is where most injuries happen. New workers, whatever their employment status, are statistically most vulnerable during their first days on a job. A 2018 analysis published in the American Journal of Industrial Medicine found injury rates for workers in their first month were significantly higher than for workers with more tenure, and temp workers hit that "new worker" risk over and over as they move between placements. ^[12]

Before a temp worker's first day, the host should do four things.

First, run a hazard inventory for the specific tasks the temp will perform. This is not a general facility hazard assessment. It is a task-level analysis that names the specific risks the person doing that exact job will face.

Second, schedule and deliver all required OSHA training for those tasks. "Delivering on day one" often is not compliant, because many standards require training before the worker begins the work. Forklift operators must be trained and evaluated before operating the equipment, for instance, under 29 CFR 1910.178(l).

Third, assign a named contact person (more than "your supervisor") the temp can approach with safety questions or concerns without fear of retaliation. OSHA's anti-retaliation provisions under Section 11(c) of the OSH Act protect temp workers just as they protect permanent employees. ^[1]

Fourth, confirm with the staffing agency that the worker got the agency's general orientation and that the agency knows the specific hazards at the site. Document that confirmation.

If your host operation is complex, with multiple shifts, multiple departments, or high hazard work like confined spaces or lockout tagout, consider putting an osha 30 trained supervisor in charge of onboarding every new worker, including temps. That supervisor's training pays for itself the first time it prevents a citation or an injury.

Can a staffing agency be cited if the host employer caused the training failure?

Yes. This surprises a lot of staffing agency owners, but the answer is clear under OSHA's multi-employer citation policy. The policy, first set out in a 1999 compliance directive, describes four categories of employers on a multi-employer worksite: creating, exposing, correcting, and controlling. A staffing agency is typically the "exposing" employer, because it exposes its employees to the hazard. An exposing employer can be cited even when it did not create the hazard, if it knew or should have known of the hazard and failed to take reasonable protective action. ^[5]

So "we didn't know the host wasn't training" is not a defense if the agency had no process for verifying training in the first place. OSHA expects the agency to ask. If the agency asks and the host lies, the agency has a stronger defense. If the agency never asks at all, that silence is itself the failure.

OSHA letters of interpretation back this up. A 2003 letter confirmed that staffing agencies placing workers at host sites are responsible for making sure those workers are not exposed to recognized hazards, including training-preventable hazards, and that this obligation cannot be waived by contract. ^[2]

For agencies, the practical defense is a documented verification process: a written checklist you complete before every placement, signed by the person who did the verification, and kept on file. If OSHA asks what you did to confirm training, you should be able to hand over a document in under two minutes. If you cannot, you are exposed.

How do state-plan states handle temp worker training responsibility differently?

Twenty-nine states and two territories run their own OSHA-approved safety and health programs, known as state plans. ^[13] These plans must be "at least as effective" as federal OSHA, but many go further on specific issues, and some have issued their own guidance on temporary worker protections.

California's state plan (Cal/OSHA) is especially active here. California Labor Code Section 6400 and the regulations under Title 8 impose employer duties that apply to both staffing agencies and host employers, and Cal/OSHA has published guidance stating that both entities share responsibility for temp worker safety training. California also has a specific Injury and Illness Prevention Program (IIPP) requirement under Title 8 CCR Section 3203 that applies to the host and effectively requires temp workers to be folded into the IIPP.

Washington State's WISHA program (Division of Occupational Safety and Health) uses similarly strong language on joint employer responsibility.

If you operate in a state-plan state, check your state's specific guidance, because in some states the split of training responsibility between agencies and hosts has been written into rule more explicitly than under federal OSHA. Your state department of labor website is the right starting point, and OSHA's state plan page lists every approved program with direct links. ^[13]

For companies operating in both federal and state-plan jurisdictions, the safest approach is to meet the stricter standard everywhere. Training programs built to California or Washington standards will be compliant in every location.

Frequently asked questions

Who is legally responsible if a temp worker is injured due to lack of training?

Both the staffing agency and the host employer can face OSHA citations and civil liability after a training-related injury to a temp worker. The host employer typically bears primary responsibility for site-specific training failures because it controlled the worksite. The staffing agency can be cited separately for failing to verify that training occurred before placement. OSHA can issue citations to both parties from a single inspection.

Does the staffing contract determine who is responsible for OSHA training?

No. A staffing contract can clarify internal division of duties and is useful for coordination, but it cannot transfer or eliminate either party's obligations under OSHA law. OSHA's 2014 Temporary Worker Initiative policy memo states explicitly that host employers and staffing agencies cannot contract away their regulatory responsibilities. If both parties fail to comply, both can be cited regardless of what the contract says.

Do temp workers have the same OSHA rights as permanent employees?

Yes. OSHA's anti-retaliation protections under Section 11(c) of the OSH Act apply to temporary workers. Temp workers have the right to refuse imminently dangerous work, to report unsafe conditions to OSHA, and to request an OSHA inspection without fear of retaliation from either the staffing agency or the host employer. Host employers must also give temps access to the same safety and health information available to permanent employees.

How should training records be handled when a temp worker moves between host employers?

The staffing agency should maintain records of its general orientation training. Each host employer keeps records of site-specific and hazard-specific training it delivered. When a worker is placed at a new host, the agency should share any prior training records that may be relevant, and the new host must assess whether that prior training is current, adequate, and applicable to the new site's specific hazards. Prior certification on equipment like forklifts may reduce but not eliminate retraining obligations.

What is OSHA's Temporary Worker Initiative?

OSHA's Temporary Worker Initiative (TWI), launched in April 2013, is an ongoing enforcement and outreach effort directing compliance officers to specifically examine temp worker conditions during host employer inspections. Under TWI, officers review training records for temps, assess whether temps are assigned disproportionately hazardous work, and examine the safety relationship between the host and its staffing agencies. OSHA has published TWI bulletins covering specific hazard categories like amputations and chemical exposures.

Does a temp worker need forklift certification from the staffing agency or the host employer?

The host employer is responsible for forklift operator training and evaluation under 29 CFR 1910.178(l), because the host controls the specific equipment and work environment. A forklift certification from a prior employer may be accepted if the host employer evaluates the worker on the host's specific equipment and site conditions, but the host must document that evaluation. Staffing agencies should not certify workers for equipment they have never operated on the host's actual forklifts.

Are temporary agricultural workers covered by the same OSHA training requirements?

Agricultural workers are covered by a different OSHA framework than general industry or construction workers. Field sanitation, pesticide handling, and other ag-specific standards apply under 29 CFR 1928. The joint employer doctrine still applies, meaning farm labor contractors (which function like staffing agencies) and the agricultural employer share responsibility. The Migrant and Seasonal Agricultural Worker Protection Act (MSPA) adds additional requirements for labor contractors that overlap with OSHA compliance duties.

What should a staffing agency checklist include before placing a worker at a new host site?

A pre-placement checklist should document: the specific tasks the worker will perform, which OSHA standards apply to those tasks, what training the host will provide and when, who at the host site is the safety contact, the host site's recent injury history or OSHA inspection record if available, and confirmation that the worker received the agency's general orientation. The checklist should be signed by the agency's placement coordinator and kept in the worker's placement file.

Can a host employer require a staffing agency to provide workers who are already trained to a specific standard?

Yes. A host can specify in its staffing contract that it only accepts workers with certain prior training, such as OSHA 10 or HAZWOPER 24-hour certification. However, even if a worker arrives with prior training, the host must still verify that training is current and deliver any site-specific content. Prior training reduces the onboarding burden but does not eliminate the host's obligation to cover hazards unique to its worksite.

Who files the OSHA 300 log entry when a temp worker is injured at a host site?

Under 29 CFR 1904.31, injuries to temp workers must be recorded by the employer who supervises the worker's day-to-day activities, which is typically the host employer. The staffing agency is not required to record the injury on its own 300 log if the host supervises the work, but both parties should have access to the records. Staffing agencies should require host employers to share 300 log entries involving placed workers as a contract condition.

How often must temp workers be retrained when OSHA standards require periodic retraining?

The retraining schedule follows whichever OSHA standard applies to the task, and it applies equally to temp workers. Forklift operators must be evaluated at least every three years under 29 CFR 1910.178(l)(4)(iii), or sooner if a worker is observed operating unsafely. Hazard communication training must be updated when new chemicals are introduced. The host employer is responsible for tracking and scheduling retraining for temp workers on active placement.

What is the maximum OSHA fine for a training violation involving a temp worker?

As of 2024, OSHA's maximum penalty for a serious violation is $16,131 per instance. Willful or repeated violations can reach $161,323 per instance. Training failures that result in a worker fatality often draw willful-level penalties. Both the host employer and the staffing agency can receive separate citations from the same incident, meaning total combined penalties for a single training failure can exceed $320,000 if both parties are cited at the willful level.

Does OSHA require training to be in the worker's native language?

OSHA does not require training in a specific language but requires that training be "effective," meaning the worker can actually understand the content. Standards like 29 CFR 1910.1200(h)(1) for hazard communication make this explicit. OSHA has cited employers for conducting English-only training when workers were not English proficient. The host employer, as the training deliverer, must ensure comprehension, which may require materials in another language or a qualified interpreter.

Sources

1. OSHA.gov, OSH Act of 1970 full text: Section 2(b)(1) of the OSH Act establishes the general duty of every employer to provide a workplace free from recognized hazards; Section 11(c) protects workers from retaliation for exercising safety rights.
2. OSHA.gov, Temporary Worker Initiative policy and guidance: OSHA's 2014 policy states 'Both the host employer and the staffing agency have roles to play in ensuring worker safety and health' and that neither can contract away OSHA obligations.
3. OSHA.gov, 29 CFR 1910 General Industry Standards: 29 CFR 1910 training standards, including 1910.178(l) for forklifts, 1910.1200 for hazard communication, 1910.147 for lockout/tagout, and 1910.146 for confined spaces, apply to whoever controls the work.
4. OSHA.gov, 29 CFR 1904 Recordkeeping Rule: Under 29 CFR 1904.31, the employer who supervises the worker's day-to-day activities is responsible for recording that worker's injuries and illnesses on the OSHA 300 log.
5. OSHA.gov, Multi-Employer Citation Policy (CPL 02-00-124): OSHA's multi-employer citation policy defines exposing employers as those who expose workers to hazards; exposing employers can be cited even when they did not create the hazard if they failed to take reasonable protective action.
6. OSHA.gov, Civil Penalty Amounts: As of 2024, OSHA's maximum penalty for a serious violation is $16,131 per instance; willful or repeated violations can reach $161,323 per instance.
7. Bureau of Labor Statistics, Occupational Injuries and Illnesses Survey 2022: BLS 2022 data shows workers in temporary help services had an incidence rate of 2.0 nonfatal occupational injuries and illnesses per 100 full-time workers.
8. National Council on Compensation Insurance (NCCI), Workers Compensation Claim Costs 2020: NCCI pegged the average workers' compensation lost-time claim cost at $41,353 in 2020.
9. OSHA.gov, Temporary Worker Initiative overview and bulletins: OSHA launched the Temporary Worker Initiative in April 2013; it directs compliance officers to examine temp worker conditions during host employer inspections and has produced bulletins on specific hazard categories.
10. OSHA.gov, 29 CFR 1910.119 Process Safety Management standard: 29 CFR 1910.119(h) requires host employers operating under PSM to train temporary employees and contractor workers on process-specific hazards and to evaluate contractor safety performance.
11. OSHA.gov, 29 CFR 1910.1200 Hazard Communication Standard: 29 CFR 1910.1200(h)(1) states 'Employers shall provide employees with effective information and training on hazardous chemicals in their work area,' which OSHA interprets to require training in a language and manner the worker can understand.
12. American Journal of Industrial Medicine, new worker injury risk analysis 2018: A 2018 analysis found injury rates for workers in their first month on a job were significantly higher than for workers with more tenure; temporary workers face this elevated new-worker risk repeatedly as they move between placements.
13. OSHA.gov, State Plans overview: Twenty-nine states and two territories operate OSHA-approved state plans that must be at least as effective as federal OSHA; some states have issued more specific guidance on temporary worker training responsibilities.