By Brent I. Clark and Craig B. Simonsen

The OSHA National Advisory Committee Workgroup will meet to continue its discussion of issues relating to the protection of temporary workers.

The Workgroup will be discussing issues that include perceived gaps in workplace protection for temporary workers, differences between temporary workers and contract workers, and joint responsibility of host employers and staffing agencies. The purpose of the meeting is to enable and equip the Workgroup to develop recommendations for the National Advisory Committee to consider in OSHA’s ongoing regulatory mission.

We had blogged previously about OSHA’s recent emphasis on temporary workers. For instance, Administrator David Michaels published an op-ed piece on the topic. This was followed by the Agency’s publication of its first in a series of “Temporary Worker Initiative Guidance Documents,” this one on injury and illness recordkeeping requirements. OSHA had announced the temporary worker initiative in a memorandum last year. See our detailed analysis of the initiative in this article on “All Employees Are Created Equal: OSHA’s New Initiative on Temporary Employees.”

All staffing agencies and employers utilizing temporary workers should take heed. The temporary employee initiative will be another tool employed by the Agency in its mission of imposing additional obligations on host employers to ensure that all employees, temporary or full time, are provided adequate health and safety training and protected from unsafe working conditions. Thus, host employers should more closely scrutinize their use of temporary employees and whether those employees are receiving sufficient training and protection. The attention of federal and state agencies and lawmakers is on this issue and employers should be taking steps to ensure that all employees, whether they are full time or temporary, are aware of and properly protected from workplace hazards.

The OSHA Workgroup meeting will take place on July 28, 2014, in Washington, DC. The meeting is open to the public.