Seasonal Workers and OSHA Recordkeeping: Headcount, Logs, and Hours Worked
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.
Quick answer
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. Because ITA thresholds use peak headcount at any time in the year, one busy season can put an establishment over 20 or 250.
Seasonal staffing can affect exemptions, ITA thresholds, average employees, and hours worked.
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
Track seasonal employees as part of the recordkeeping population when they are covered by the employer log. 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.
HR usually holds the headcount, leave, and restriction paperwork that recordkeeping depends on, so the handoff to safety matters as much as the rule.
The mistake to avoid
Teams use year-end headcount and miss peak employment or hours-worked effects.
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
- Short operating seasons can make rates look extreme without context.
- Supervised temporary workers belong in the host's hours worked as well as its log, which affects the rates.
Example
An orchard employs 12 people year-round and 60 during harvest. Its peak of 72 means it keeps a log (well above 10) and, as an agricultural establishment on Appendix A with 20 to 249 employees, submits its 300A. Its annual average employees, calculated by pay period, is 31.
Step by step
- Track peak employment.
- Calculate average employees by pay period.
- Include seasonal hours worked.
- Assign each seasonal employee to an establishment.
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.
For a quick answer without an account, use the free ITA coverage checker.
Frequently asked questions
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.
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.
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 1904.32: Annual summary certification and postingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.1: Partial exemption for employers with 10 or fewer employeesOccupational 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.