Temporary Worker Day-to-Day Supervision FAQ for OSHA Recordkeeping
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.
The answer up front
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. Payroll status and contract wording do not decide it, and only one employer records the case.
Day-to-day supervision decides many host versus staffing agency recordkeeping questions.
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.
Applying it to real cases
Record a temp or contractor case on the log of the employer that supervises the work day to day. 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.
Staffing coordinators sit between host and agency, so a standard way to share incident details is the most valuable thing you can set up.
Where teams go wrong
Teams rely on payroll status or contract language without checking who directs the work.
Whoever records the case also counts it in their 300A totals and rates, and supervised workers' hours belong in that employer's hours worked.
Situations that change the answer
- Only one employer should record a temp worker case for OSHA recordkeeping.
- Corporate officers who are employees are covered, even though owners of sole proprietorships and partnerships are not.
A worked example
A staffing agency places a data technician at a client, where the client's manager assigns the work and approves hours, while the agency sends a monthly check-in email. The client supervises day to day and records any injury. The agency's monthly check-in is not day-to-day supervision.
A checklist you can reuse
- Document the supervision facts.
- Coordinate with the other employer.
- Record the case on one log.
- Avoid duplicate entries.
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 1904.29: OSHA Forms 300, 300A, and 301Occupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.7: General recording criteriaOccupational 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.