OSHA Recordkeeping for Nonprofits: Volunteers, Employees, and BLS Requests
Nonprofit status does not exempt an employer from OSHA recordkeeping; the same size and industry tests apply, and paid staff are covered employees.
4 min readUpdated
Topic · 9 guides
Your OSHA 300 Log can cover more people than your payroll list, and sometimes fewer. Under 29 CFR 1904.31 you record the recordable injuries and illnesses of every employee on your payroll, whether they are labor, executive, hourly, salaried, part-time, seasonal or migrant workers. You also record cases for workers who are not on your payroll if you supervise them on a day-to-day basis, which is the usual situation with temporary and leased workers from a staffing agency.
~4 min average readUpdated

The test is supervision, not who issues the paycheck. If a contractor's employees are supervised day to day by the contractor, the contractor records their cases. The host employer and the agency or contractor should coordinate so that each case is recorded once, on one log. Self-employed people are not covered, and in a sole proprietorship or partnership the owners and partners are not employees for recordkeeping purposes.
The guides below cover temporary workers, staffing agencies, contractors, volunteers, owners and partners, seasonal crews and nonprofits, including how the headcount and hours for each group flow into the 300A.
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Covered employees
9 guides
Nonprofit status does not exempt an employer from OSHA recordkeeping; the same size and industry tests apply, and paid staff are covered employees.
4 min readUpdated
Seasonal workers on your payroll are covered employees: their cases go on the log, and they count toward headcount tests, average employees, and hours worked.
4 min readUpdated
When a staffing agency places a worker with a client that supervises them day to day, the client records the injury, and the agency does not.
4 min readUpdated
Record a temp or leased worker's case on the log of the employer that directs their work day to day: assigns tasks, sets methods, and oversees the shift.
4 min readUpdated
Owners and partners of sole proprietorships or partnerships aren't employees for OSHA logs; corporate officers who are employees are.
4 min readUpdated
Self-employed people are not covered by the OSH Act or Part 1904, so a genuinely self-employed contractor's injury does not go on your log.
4 min readUpdated
True volunteers, who receive no compensation, are generally not employees under the OSH Act, so their injuries do not go on your OSHA log.
4 min readUpdated
A contractor's employee goes on the contractor's log when the contractor supervises them day to day, and on yours only if you do.
4 min readUpdated
The employer that supervises a temporary worker day to day records their injuries, and in most staffing arrangements that is the host employer…
4 min readUpdated
From guide to log
300log turns each case into its OSHA 300 Log entry and 301 report, keeps privacy cases off the shared log, totals the 300A and files it with OSHA's ITA for you as soon as you authorize it.