Contractor Injuries and the OSHA 300 Log: Avoiding Duplicate or Missing Cases
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.
Quick answer
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. Coordinate with the contractor so each case is recorded exactly once.
Contractor injuries can create duplicate records or no record at all depending on communication.
The rule in plain English
You record the injuries and illnesses of everyone on your payroll: labor, executive, hourly, salaried, part-time, seasonal, and migrant workers (29 CFR 1904.31). You also record cases for workers who are not on your payroll if you supervise them day to day, such as temporary or leased workers; if a contractor supervises its own people day to day, the contractor records. Each case is recorded once, by the employer that provides day-to-day supervision. Self-employed people are not covered, and owners or partners of a sole proprietorship or partnership are not employees for recordkeeping purposes.
What this looks like in practice
Focus on whether the worker is an employee for recordkeeping purposes and who supervises day-to-day work. Cases slip through when the host site and the staffing agency each assume the other will log them, and get counted twice when both do. The fix is to decide supervision at the start of each engagement, put it in writing, and agree how incident details reach the employer that records.
Site leaders control who is on site and who supervises them, which is exactly the fact that decides many contractor and temp cases.
The mistake to avoid
Teams sometimes log every contractor injury on the host log regardless of supervision.
Whoever records the case also counts it in their 300A totals and rates, and supervised workers' hours belong in that employer's hours worked.
Edge cases worth checking
- Construction and multi-employer sites may still have separate reporting and investigation duties.
- Supervised temporary workers belong in the host's hours worked as well as its log, which affects the rates.
Example
A plant hires a cleaning contractor whose crew is supervised by the contractor's own site lead. A crew member's chemical burn goes on the contractor's log. When the plant later brings in a leased welder who works under the plant's maintenance supervisor, the welder's injury goes on the plant's log.
Step by step
- Confirm the employment relationship.
- Establish who supervises day to day.
- Agree who records the case.
- Share incident facts with the recording employer.
What to keep in the case file:
- Who directs the worker's tasks, schedule, and methods each day
- The staffing or contractor agreement and what it says about recordkeeping
- Notes from coordination with the other employer about who records the case
- Whether the worker's hours are included in your hours-worked total
Where 300log helps
300log records each case against an establishment, so once you have decided that a supervised temp or leased worker's case belongs on your log, it lands on the right establishment's log and in its 300A totals.
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Frequently asked questions
Are volunteers covered?
Part 1904 covers employees. A true volunteer who receives no compensation is generally not an employee, but stipends and employer control can change that, so document the relationship.
Do we record injuries to self-employed contractors?
No. Self-employed individuals are not covered by the OSH Act or Part 1904.
Who records a temporary worker's injury?
The employer that supervises the worker day to day, usually the host. Only one employer records the case.
Do owners go on the OSHA log?
Owners and partners of a sole proprietorship or partnership are not employees for recordkeeping. Corporate officers who are employees are covered.
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.31: Covered employeesOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]29 CFR 1904.30: Multiple business establishmentsOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.29: OSHA Forms 300, 300A, and 301Occupational Safety and Health Administration · osha.gov(opens in a new tab)
Written and reviewed by the 300log Editorial Team. Guidance, not legal advice: confirm edge cases with OSHA or counsel.