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Safe+Sound Blog Series: Part Two

This Safe+Sound Week, TempForce is bringing you must-know information about how temporary staffing agencies and staffing clients should work together to protect our temporary workforce. This is Part One in our Safe+Sound Week Blog Series!

Working Safe with a Temporary Agency
Part 2: P.P.E. and Hazard Communications

Today, we’re going to look at OSHA’s recommendations for how Staffing Agencies and their Clients, also called Host Employers, should handle two essential elements of Workplace Safety: Personal Protective Equipment and Hazard Communications.

 

Contracts Define Our Roles!

As we are about to see, for Host Employers and Staffing Agencies, questions regarding employer responsibility for particular safety and health protections are common. OSHA recommends that Staffing Agencies and Host Employers use a Contract to define each of our roles and responsibilities with regards to safety.

 

PPE’s Role In The Workplace!

Personal Protective Equipment is required to minimize workers’ exposure to hazards when all other controls cannot reduce hazard exposure to acceptable levels. But who is responsible for providing PPE… the host employer, or the staffing agency?

 

The Host Employer’s Responsibilities

According to OSHA, since the Host Employer is most familiar with their workplace and generally controls the worker’s activities around and interaction with hazards, the Host will usually have the “primary responsibility for selecting, providing, and ensuring the use of adequate P.P.E. for the work assigned.” (Source)

For example, a Host Employer may control a sander at their worksite that emits sawdust and loud noise, so they would provide safety glasses and ear plugs for all workers who are exposed to these hazards. Remember, in the case of safety and health protections, “Host employers must treat temporary workers like any other workers.” (Source)

Furthermore, Host Employers are usually best-suited to perform the workplace hazard assessment required to determine what type and class of P.P.E. is needed, and may have already done an assessment to make these important P.P.E. decisions for their permanent workforce.


The Staffing Agency’s Responsibilities

The Staffing Agency is responsible for making sure “the host employer conducts the appropriate hazard assessment and provides adequate P.P.E.” (Source)

At TempForce, we know that when it comes to safety, communication is key! The Staffing Agency should maintain communication with Host Employers, to learn about work hazards and P.P.E. required; and should communicate regularly with workers, to make sure they are provided with the right P.P.E.

 

Are Employers Required to Pay for PPE?

The Temporary Worker Initiative reports that in general,“neither the host nor the staffing agency can require workers to provide or pay for their own PPE.” (Source)

But there are some important exceptions!Employers are usually not required to pay for “certain safety-toe shoes and boots, prescription safety eyewear, and logging boots,” and a few other exceptions, because “[this] equipment is very personal [and] is often used outside the workplace.” (Source)

See all the exceptions and more on this rule at this link.


What About Hazard Communications Training?

Another important element of a Workplace Safety Program is making sure workers understand the hazardous properties of the chemicals they may be exposed to.

According to OSHA, Staffing Agencies and Host Employers are “jointly responsible for ensuring that these employees are effectively informed and trained regarding exposure to hazardous chemicals.” (Source)

 

Host Employer Responsibilities

The Host Employer “uses or produces the hazardous chemicals and creates and controls the work process,” (Source) so they tend to hold the primary responsibility for training on site-specific chemical hazards.

This responsibility includes communicating information about relevant hazards, as well as “appropriate labeling of chemical containers, providing [all employees] access to Safety Data Sheets, and providing appropriate personal protective equipment.” (Source)

According to OSHA, Hazard Communication training provided to temporary workers should be identical or equivalent to the training given to Host’s permanent employees!

 

Staffing Agency Responsibilities

The Staffing Agency’s responsibilities usually include basic training, familiarity with the chemical hazards at the Host’s worksite, and making sure that the Host Employer adequately fulfills its Hazard Communication training responsibilities.

We also see it as part of our duty to ensure that our clients are training employees on the most current hazard communication standards. Here are some of the recent changes in HCS that should be part of employees’ site-specific training:

 

How Has Hazard Communication Changed?

In recent years, we have seen important changes to OSHA’s Hazard Communication Standard. Employers are now required to communicate any hazardous chemical information to employees using a newly standardized system of labeling that is aligned with the United Nations’ GHS (Globally Harmonized System of Classification and Labeling of Chemicals).

This change includes new Hazard Classifications, new Labels, and the new Safety Data Sheet, which replaces the older Material Safety Data Sheet. (Source) Employers must train workers on the new label elements and the new format of the Safety Data Sheet.

 HCS Pictograms

This Chart shows the 9 new HCS Pictograms. See more information about the new labeling standards that employees must be trained on at this link! See information about the new SDSs at this link!

 

In tomorrow’s Blog, we will cover the third and final topic in our Safe+Sound Week Series: how Joint Employers should handle Safety Incident Recordkeeping and Reporting!

Posted on 06/14/2017