How to write a safety program for temporary workers

Last updated 2026-07-10

Why temporary workers need their own safety program section

Temporary workers get hurt more often, and the pattern is old news to anyone who reads the data. The Bureau of Labor Statistics has tracked for years that workers in their first month on a job have injury rates well above those of longer-tenured employees, and staffing workers spend a lot of time in that high-risk window ^[1]. A 2013 joint report from OSHA and NIOSH found that temporary workers reported more injuries than permanent workers in the same facilities, often because nobody had clearly owned their training ^[2].

The root cause is the two-employer setup. A staffing agency hires the worker on paper. A host employer runs the worker's daily tasks. Each assumes the other handles safety, and the worker drops through the gap. OSHA's answer was a formal policy: both employers can be cited, and shared responsibility is the rule.

Your written safety program almost certainly covers your direct employees already. The job here is to close the gap for temps so the same hazard controls, training, and incident reporting reach them on day one. This is not a second program. It is a dedicated section that clarifies roles and sets a standard for how temps get folded into what you already run.

What does OSHA actually require for temporary workers?

OSHA has no single standard titled "temporary worker safety." What it has is a set of guidance letters and a formal initiative that started in 2013, the Temporary Worker Initiative (TWI), which tells compliance officers to treat both the staffing agency and the host employer as covered employers under the OSH Act ^[2].

The agency's position, laid out across several letters of interpretation, is that each employer answers for the working conditions it controls. The host employer controls the physical hazards, the equipment, the chemicals, and the workflow. The staffing agency controls the employment relationship and has to make sure workers are not placed into conditions that break OSHA standards.

Under 29 CFR 1904.31, the host employer records work-related injuries and illnesses of temporary workers on its OSHA 300 log if it supervises the worker day to day ^[3]. Most host employers miss that one. If your foreman is telling a temp what to do and how to do it, that worker's injuries go on your log.

Hazard communication under 29 CFR 1910.1200 applies fully to temporary workers ^[4]. They must be trained on every chemical they could be exposed to, in a language they understand. Lockout/tagout under 29 CFR 1910.147 applies to temps who service or maintain equipment ^[5]. Respiratory protection, PPE, confined space entry, every other standard applies the same way. OSHA put it plainly in its TWI materials: host employers must treat temporary workers like any other workers for training and safety ^[2].

How do staffing agencies and host employers split safety responsibilities?

The split is simple to state: the staffing agency handles the general, the host employer handles the specific.

The staffing agency should run general safety orientation before a worker ever sets foot on a client site. That covers basic rights under the OSH Act, how to report an injury, who to call if something feels unsafe, and any general-industry training that travels with the worker regardless of site (basic PPE use, hazard communication awareness). The agency should also confirm, in writing, that the host employer has a program covering site-specific hazards before placing anyone.

The host employer owns everything tied to the actual worksite. Site-specific hazard training, hands-on equipment instruction, chemical-specific SDS review, emergency evacuation routes, PPE selection and provision, and the OSHA 300 log entry when an incident happens. You cannot hand those off to the agency, because the agency does not know your machines, your floor layout, or what sits in drums in the back room.

Responsibility	Staffing Agency	Host Employer
General safety orientation	Yes	Optional (but recommended)
Site-specific hazard training	No	Yes
PPE provision	Negotiable (put it in the contract)	Default responsibility
OSHA 300 recordkeeping	No (in most cases)	Yes, if supervising day-to-day
Injury investigation	Shared	Yes, initiates investigation
Right-to-know / SDS training	General awareness	Site-specific chemicals
Pre-placement site assessment	Should perform	Should cooperate with

Who pays for PPE is the one spot that trips people up. OSHA's general rule under 29 CFR 1910.132(h) is that the employer who requires PPE provides it at no cost to the worker ^[6]. In practice, staffing contracts sometimes push this onto the host. Spell it out in the contract. Do not leave it fuzzy.

What should a written safety program for temporary workers include?

A written program for temporary workers is short. It is specific. Here is what it needs, section by section.

Scope and purpose. One paragraph saying this section applies to all workers supplied through staffing agencies and defining them as covered employees under your safety program.

Roles and responsibilities. Name the internal person (use a supervisor title, more than a name) responsible for temp onboarding. Name who verifies that incoming temps got their general orientation from the agency. This is where you write the split-employer framework in your own words.

Pre-placement checklist. A list of what the host employer confirms before a temp starts: the hazards they will face, the PPE required, the equipment they will run, the chemicals they may touch. Some companies send this to the agency ahead of time so workers can be screened for the right qualifications.

Site-specific training requirements. List every training topic a temp must finish before working alone, with an estimated time for each. Include hazard communication training for all chemicals they will use, equipment-specific instruction, emergency egress, and any process-specific hazards. Reference the applicable CFR standards.

Training documentation. Every session gets documented with the worker's name, date, topics covered, and the trainer's name. Keep the records. Compliance officers will ask for them.

Incident reporting. Temps must know who to report an injury to and that they will not be punished for it. Section 11(c) of the OSH Act protects all workers, temps included, from retaliation for reporting injuries. Put the procedure in writing and make sure supervisors know that discouraging injury reports is a federal violation.

Recordkeeping. State outright that the host employer records qualifying injuries on its OSHA 300 log per 29 CFR 1904.31 ^[3].

Staffing agency coordination. Add a section describing how you pass safety requirements to agencies, including any written agreement or addendum attached to the staffing contract.

If you want a starting point instead of a blank document, SafetyFolio's safety program generator walks you through these sections in about 15 minutes and produces a written program you can actually hand to a compliance officer.

What training do temporary workers need before they start work?

Short answer: the same training any new employee doing that job would get, delivered before they work alone on any task with a recognized hazard.

OSHA training is not generic. A temp in a warehouse needs training on the specific forklifts in that warehouse, not a general forklift awareness video. Forklift certification under 29 CFR 1910.178(l) requires evaluation on the actual equipment in the actual workplace ^[7]. A temp working around chemicals needs the specific SDS sheets for your site, not a general hazcom overview.

A handful of training requirements hit almost every industrial temp:

• Hazard communication (29 CFR 1910.1200): required for any worker who may be exposed to a hazardous chemical ^[4]
• Emergency action plan (29 CFR 1910.38): every worker must know evacuation routes and procedures ^[8]
• PPE use (29 CFR 1910.132): workers must be trained to don, doff, adjust, and care for whatever PPE they are required to use ^[6]
• Lockout tagout (29 CFR 1910.147): required for any worker who could be exposed to unexpected energization of equipment ^[5]

Language is a real issue. OSHA has been explicit that training must be given in a language and vocabulary the worker can understand. An English-only handout to a worker whose first language is Spanish does not satisfy the requirement. A Spanish-language version of your materials is not a courtesy. It is a compliance requirement if that is the language your workers speak.

Timing matters. Training happens before the worker performs the task. Not at the end of the first shift. Before the task. Build that into your pre-placement checklist.

Who is responsible for recording a temporary worker's injury on the OSHA 300 log?

This one has a clean answer. Under 29 CFR 1904.31, the employer who supervises the worker day to day records the injury ^[3]. In nearly every host arrangement, that is the host employer. The staffing agency rarely has a supervisor on your floor directing the work.

The rule also bars two employers from recording the same injury. So if you as the host employer log it, the agency does not log it too. Say this clearly in the staffing contract so there is no argument after an incident.

A recordable injury is one that goes beyond first aid: a work-related injury or illness with days away from work, restricted duty, medical treatment beyond first aid, loss of consciousness, or a significant condition diagnosed by a healthcare professional ^[3]. First-aid-only cases, like cleaning and bandaging a small cut, go on an internal log but not the OSHA 300.

One practical step: your temp section should tell supervisors to report any injury involving a temp to your safety coordinator within 24 hours, the same as a direct employee. The incident report process should be identical. Supervisors sometimes assume temp injuries are the agency's problem. They are not.

Can you be cited by OSHA for a temporary worker's injury even if the staffing agency hired them?

Yes. This is the part that catches most host employers off guard.

OSHA's multi-employer citation policy, and the Temporary Worker Initiative on top of it, make clear that both the staffing agency and the host employer can be cited from the same inspection ^[2]. OSHA treats the host as a "controlling employer" because it controls the physical conditions of the worksite. A controlling employer can be cited for hazards it created, or for hazards it knew about and did not fix, even when those hazards hit workers it never directly hired.

In practice, inspections triggered by a temp's injury almost always land citations on the host. The agency may also be cited if it never asked about hazards before placing the worker. Penalties match any other OSHA violation: serious violations up to $16,550 each (as of 2024, adjusted annually for inflation), and willful or repeat violations up to $165,514 each ^[9].

Your best protection is a written program that shows you took training and hazard assessment seriously before anything went wrong. Compliance officers hunt for documentation. If you have none, the working assumption is that the training never happened.

How do you handle PPE for temporary workers?

Start with the staffing contract. It should name exactly who provides what PPE. If it says nothing, OSHA's default under 29 CFR 1910.132(h) is that the employer requiring the PPE provides it at no cost ^[6]. Since you are the host directing the work, that is usually you.

Run a hazard assessment before temps start. 29 CFR 1910.132(d) requires a written hazard assessment to decide what PPE each task needs ^[6]. That assessment should cover temp workers' tasks specifically, since those tasks sometimes differ from what your regular crew does.

Stock PPE for temps on day one. Obvious, and still a common failure: a temp shows up, nobody has their glove size, and they start work without the right protection. Keep a buffer stock of common sizes and document that each temp got their PPE and knew how to use it before starting.

Do not skip fit testing for respirators. If your workplace requires respiratory protection, every worker, temp or not, who must wear a tight-fitting respirator needs a fit test before use, per 29 CFR 1910.134 ^[10]. Agencies cannot do this for you, because fit testing is tied to your site and the specific respirator model.

What should go in the staffing agency contract to protect both sides?

The staffing contract is your best tool for heading off disputes after an incident. Most standard contracts say almost nothing about safety, which is exactly how the gaps open up.

Attach a safety addendum that spells out these points:

• The agency provides general safety orientation before placement, covering worker rights, injury reporting, and basic hazcom awareness
• The host provides all site-specific safety training and documents it
• The host records qualifying injuries on its OSHA 300 log
• The host provides PPE (or the addendum names which items the agency provides)
• The agency cooperates with incident investigations and shares worker medical history relevant to a claim where legally permissible
• Either party may pull a worker from a task they believe is unsafe without it counting as a contract breach
• The agency notifies the host of any safety concern a placed worker raises

Some larger staffing firms have their own safety program templates they will share. Ask for them. Compare them to your requirements. Where they clash, settle it before placement, not after an incident.

OSHA has published guidance on what these contracts should cover in its TWI bulletins, available on OSHA.gov ^[2]. Read the one-page summary before your next staffing negotiation.

How is a safety program for temp workers different from the regular employee program?

On protection, it should not differ at all. The difference is in the logistics of onboarding and the clarity about who does what.

Your regular program assumes a person is hired, goes through HR onboarding, trains over the first week, then starts supervised work. Temps often show up Monday morning and are expected to produce by Monday afternoon. The training window is shorter and the responsibility for it is split.

That is why the temp section has to be more explicit about timing and sequence than the regular section. "Complete all required training before beginning independent work" means something different when a person is only on site for three days.

For longer stints, treat them like a new hire on the training timeline. Someone placed for three months should go through the same hazard-specific training as a new direct employee in that role. The OSH Act does not tell the difference between a six-month temp and a six-month probationary hire.

One structural difference is worth flagging: a temp who raises a safety concern may feel less job security than a direct hire. Your written program should state plainly that temps have the same right to refuse unsafe work and the same anti-retaliation protection under Section 11(c) of the OSH Act. Put it in writing, and make sure supervisors know it too.

How do you verify that safety training actually happened?

Documentation is the only verification that survives an OSHA inspection. A supervisor saying "I told them" is not documentation.

For every training session with a temp, keep a record with five elements: the worker's full name, the date, the topics covered (reference the CFR standard where it applies), the trainer's name and title, and the worker's signature confirming they got the training. Some companies add a short competency check, a few questions to confirm the worker understood, especially for high-hazard tasks.

For bigger placements, build a simple onboarding checklist a supervisor signs off before the temp works alone. The checklist should mirror the training requirements in your written program.

Shared digital tracking works well when you have multiple temps cycling through. Some companies hand temps a laminated card listing completed training items to carry on the floor. That is not a replacement for the formal record, but it helps supervisors confirm a worker's status fast.

Inspectors will ask to see training records during any inspection tied to a temp injury. If you cannot produce them, the default assumption is that the training never happened, and the citation follows. Keep these records for at least three years, in line with the 29 CFR 1904 recordkeeping retention requirement ^[3].

For supervisors who want a firmer grip on the regulatory framework before they run these trainings, an OSHA 30 course gives a solid foundation in how OSHA standards work across the worksite.

What are the most common OSHA violations involving temporary workers?

Based on OSHA enforcement patterns and the focus areas of the Temporary Worker Initiative, a few violations keep showing up ^[2].

First is weak hazard communication training. Temps land in facilities full of chemicals they have never seen, and SDS training gets skipped because it feels like the agency's job. Neither party does it well, and the temp handles chemicals without knowing the hazards.

Second is failure to record injuries on the OSHA 300 log. Host employers sometimes report a temp injury to the agency and assume the agency handles the recordkeeping. Per 29 CFR 1904.31, if you supervised the worker, you record the injury ^[3].

Third is missing PPE hazard assessments for temp tasks. The written assessment required by 29 CFR 1910.132(d) often gets done once for the regular workforce and never updated when temps take on different tasks ^[6].

Fourth is forklift training that misses the site-specific requirement. A temp with a forklift card from a prior job still needs to be evaluated on your equipment in your facility. The card does not carry over on its own.

Fifth is retaliation, or the appearance of it. Supervisors who discourage temps from reporting injuries, even quietly, open the host up to Section 11(c) complaints. These cases have produced real back-pay awards and civil penalties.

Build your program around these five failure points and you handle most of the enforcement risk.

Frequently asked questions

Does OSHA treat temporary workers the same as permanent employees?

Yes. OSHA's Temporary Worker Initiative, launched in 2013, makes clear that all OSHA standards apply to temporary workers the same as they do to direct hires. Both the staffing agency and the host employer can be cited for violations. The host employer handles site-specific training and hazard controls; the staffing agency handles general orientation and pre-placement verification.

Who is responsible for temporary worker safety, the staffing agency or the host employer?

Both, in different ways. The host employer controls the physical worksite and is responsible for site-specific hazard training, PPE provision, and injury recordkeeping. The staffing agency is responsible for general safety orientation and for verifying the host employer has adequate safety measures before placing workers. OSHA can cite both parties from the same inspection.

Does a temporary worker's injury go on my OSHA 300 log?

Yes, if you supervise the worker day to day. Under 29 CFR 1904.31, the employer who provides daily supervision records qualifying work-related injuries and illnesses. In most host arrangements, that is the host employer. The staffing agency should not also record the same incident. Clarify this in your staffing contract.

Can I use the staffing agency's safety training instead of providing my own?

For general orientation, yes. For site-specific training, no. The staffing agency does not know your chemicals, equipment, floor layout, or emergency procedures. OSHA requires training relevant to the actual hazards the worker faces. Only the host employer can deliver that site-specific instruction. Relying on agency training alone is a common citation trigger.

What training must a temporary worker complete before operating a forklift?

Under 29 CFR 1910.178(l), forklift operators must be trained and evaluated on the specific type of forklift they will use, in the specific workplace where they will operate it. A certification from a prior job does not automatically transfer. The host employer must run a site-specific evaluation before the temp operates any powered industrial truck alone.

What does OSHA's Temporary Worker Initiative actually require host employers to do?

OSHA's TWI, active since 2013, directs compliance officers to evaluate both the staffing agency and host employer during inspections involving temp workers. Host employers must provide site-specific hazard training, PPE, injury recordkeeping, and the same anti-retaliation protections as for direct employees. OSHA published a series of TWI bulletins on OSHA.gov detailing these obligations.

Do I need to provide safety training in languages other than English for temporary workers?

Yes, if that is the language your workers understand. OSHA requires training in a language and vocabulary the worker can understand. Handing a Spanish-speaking worker an English-only handout does not satisfy the requirement. This applies to all covered standards, including hazard communication under 29 CFR 1910.1200 and emergency action plans under 29 CFR 1910.38.

Can a temporary worker refuse unsafe work without being sent back to the agency?

Yes. Section 11(c) of the OSH Act protects all workers, including temps, from retaliation for refusing work they reasonably believe poses imminent danger. Sending a temp back to the agency specifically because they raised a safety concern would likely count as retaliation. Your written program should state this protection and train supervisors on it.

How long do I need to keep safety training records for temporary workers?

OSHA's recordkeeping rule under 29 CFR 1904 requires retaining injury and illness records for five years. For training records there is no single universal period, but many OSHA standards specify three to five years (for example, 29 CFR 1910.1020 for medical and exposure records). Keeping training records for at least three years is a safe baseline.

What should I include in a staffing agency safety contract addendum?

At minimum: who provides general orientation versus site-specific training, who provides PPE and records injury data, how each party handles incident investigations, the worker's right to report unsafe conditions without retaliation, and that all placements fall under your site safety program. OSHA's TWI Bulletin No. 1 provides a framework for these terms. Settle it before the first placement.

Is a written safety program for temporary workers legally required by OSHA?

OSHA has no standard that says "you must have a written temp worker safety program." But several standards that apply to temps require written programs: hazard communication (29 CFR 1910.1200), lockout/tagout (29 CFR 1910.147), respiratory protection (29 CFR 1910.134), and others. A written program covering temps under all these standards is the practical way to meet those individual requirements.

What penalties can OSHA impose on a host employer for temporary worker violations?

OSHA's penalty structure (adjusted annually) allows up to $16,550 per serious violation and up to $165,514 per willful or repeat violation as of 2024. Host employers have faced both categories for temp worker safety failures, especially for weak training documentation and failure to record injuries. These figures are indexed to inflation under the Federal Civil Penalties Inflation Adjustment Act.

How do I document that a temporary worker completed safety training?

Keep a signed training record for each session with the worker's full name, date, specific topics covered with CFR references where applicable, the trainer's name and title, and the worker's signature. A supervisor sign-off checklist before the worker starts independent tasks is a good complement. Store these records for at least three years and keep them retrievable for an OSHA inspection.

Do the same OSHA rules apply to short-term temps, like someone working for one day?

Yes. OSHA standards have no minimum tenure threshold. A worker on site for one day must be trained on the hazards they face that day before they face them. The practical takeaway: you need a fast, streamlined onboarding process for short placements that still hits every required training topic for the tasks assigned.

Sources

1. Bureau of Labor Statistics, Injuries, Illnesses, and Fatalities: Workers in their first month on a job have injury rates that exceed those of longer-tenured employees; BLS tracks tenure-based injury data annually.
2. OSHA, Temporary Worker Initiative and TWI Bulletins: OSHA's Temporary Worker Initiative (2013) directs compliance officers to treat both the staffing agency and host employer as covered employers; TWI bulletins state host employers must treat temporary workers like any other workers for training and safety.
3. OSHA, 29 CFR 1904.31 Covered employees (Recordkeeping): Under 29 CFR 1904.31, the employer who supervises a temporary worker day to day must record that worker's qualifying injuries and illnesses on the OSHA 300 log.
4. OSHA, Hazard Communication Standard, 29 CFR 1910.1200: 29 CFR 1910.1200 requires training for any worker who may be exposed to a hazardous chemical, including temporary workers, in a language and vocabulary they understand.
5. OSHA, Control of Hazardous Energy (Lockout/Tagout), 29 CFR 1910.147: 29 CFR 1910.147 requires training for any worker who could be exposed to unexpected energization of equipment, including temporary workers assigned to servicing or maintenance tasks.
6. OSHA, Personal Protective Equipment, 29 CFR 1910.132: 29 CFR 1910.132(d) requires a written hazard assessment for PPE selection; 29 CFR 1910.132(h) requires the employer who mandates PPE to provide it at no cost to the employee.
7. OSHA, Powered Industrial Trucks, 29 CFR 1910.178(l): 29 CFR 1910.178(l) requires forklift operators to be trained and evaluated on the specific equipment type in the specific workplace; prior certification from another employer does not automatically satisfy this requirement.
8. OSHA, Emergency Action Plans, 29 CFR 1910.38: 29 CFR 1910.38 requires that every worker, including temporary workers, be trained on the emergency action plan, including evacuation routes and procedures.
9. OSHA, Penalties (Civil Penalty Adjustments): As of 2024, OSHA serious violation penalties reach up to $16,550 per violation; willful or repeat violations up to $165,514 per violation, adjusted annually under the Federal Civil Penalties Inflation Adjustment Act.
10. OSHA, Respiratory Protection Standard, 29 CFR 1910.134: 29 CFR 1910.134 requires fit testing for each worker required to wear a tight-fitting respirator, including temporary workers, before use.
11. NIOSH, Temporary Workers (CDC): NIOSH research supports that temporary workers face elevated injury risk, particularly in manufacturing and warehousing, due to gaps in site-specific safety training and supervision.