Who's Responsible for Training Temp Workers on GHS?

The work may be temporary, but the effects of an employee getting hurt or sick on the job can last a lifetime. OSHA’s safety standards for industry put the onus of ensuring worker safety on the employer. For temporary workers, this raises a unique question—who, exactly, “employs” these workers? Is it the staffing agency or the host business?

This question is especially important when it comes to GHS hazard communication, as the deadline for all employers to update their workplace HazCom systems is June 1, 2016.

To clarify this issue and help make sure temporary workers are protected from the chemical hazards they face while at work, OSHA has issued guidance on hazard communication training for temporary workers. In this guidance document, OSHA states that the staffing agency and the host employer share responsibility for making sure employees have the HazCom training needed to work safely.

Host Employer Responsibilities for HazCom Training

In the new guidance, OSHA says that host employers “hold the primary responsibility for providing site-specific hazard communication information and training on chemical hazards in the workplace to temporary employees. “ HazCom training for temp workers must be identical or equivalent to the training the host employer provides for its own employees.

Other site-specific responsibilities of the host employer include:

• Identifying and communication chemical hazard information to temp workers
• Ensuring appropriate labeling of chemical containers
• Providing access to Safety Data Sheets (SDS)
• Providing appropriate personal protective equipment (PPE)

OSHA goes on to stress that even when a staffing agency representative is present at the host employer’s site, the host employer is still responsible for providing the site-specific HazCom training.


Staffing Agency Responsibilities for HazCom Training

While the host employer must provide site-specific hazard communication training, the staffing agency has responsibilities too. Staffing agencies must:

• Provide generic hazard communication information and training for temp workers
• Explain the HazCom Standard (HCS) requirements applicable to work settings employees could encounter
• Inquire and verify that the host employer has met its end of the                                                       shared training responsibilities

OSHA recommends that staffing agency personnel complete a site walk-through at the host employers’ site(s) in order to become familiar with any hazardous chemicals in that workplace. This way, the staffing agency can verify that appropriate and sufficient HazCom training is provided.

See the full OSHA guidance on HazCom Training for Temporary Workers here.

For a look at OSHA safety regulations for multi-employer workplaces, like some construction sites, read OSHA Workplace Safety and Multi-Employer Workplaces.

Be Ready on June 1 With GHS HazCom Training

Whether you host temporary workers at your site or help temporary workers find jobs, meet your responsibilities for protecting those employees. The Managing Hazard Communication Online Course will help you prepare your site’s HazCom plan and prepare for the June 1 GHS deadline.

To train full-time, part-time, or temporary workers to recognize and use new Safety Data Sheets and chemical container labels, the Hazard Communication Online Course is available for $49 per student. Flexible access allows workers to stop and start the training as needed to fit their schedule. Train and protect employees without sacrificing production.  

Tags: GHS, hazard communication, new rules, osha