Temporary Workers and OSHA 300 Logs: Who Records the Case?
The employer that supervises a temporary worker day to day records their injuries, and in most staffing arrangements that is the host employer, not the agency.
The short answer
The employer that supervises a temporary worker day to day records their injuries, and in most staffing arrangements that is the host employer, not the agency. Only one employer records the case, so the host and agency should agree how case information is shared.
Temporary worker cases fall through the cracks when the host and the staffing agency each assume the other is logging them.
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.
How it plays out on site
The employer who supervises day-to-day work usually records the injury or illness. 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.
At the director level the question is less about one case and more about whether every site applies the rule the same way, with evidence you could show an inspector.
The common mistake
Teams sometimes rely on the payroll employer alone and miss OSHA's supervision focus.
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
- Shared worksites need a written process for who receives medical updates.
- A contract clause that assigns recordkeeping to the agency does not override the day-to-day supervision test.
Worked example
A temp assigned to a bottling line by an agency is directed by the host's line lead, follows the host's procedures, and works the host's shifts. When the temp's hand is caught in a guard and needs sutures, the host records the case; the agency handles the workers' comp claim but does not put it on its own log.
Checklist
- Define who supervises day to day.
- Exchange incident details with the staffing partner.
- Record the case on one log only.
- Reconcile logs with staffing partners.
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
Temporary Workers and OSHA 300 Logs: Who Records the Case?
The employer that supervises a temporary worker day to day records their injuries, and in most staffing arrangements that is the host employer, not the agency. Only one employer records the case, so the host and agency should agree how case information is shared.
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.
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.
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.