In general, it is the responsibility of the staffing agency to ensure that employees have received proper training. In practice, even when the staffing agency has provided basic training, the host employer provides the workplace-specific training appropriate to the employees’ particular tasks. For example, a staffing agency can provide general Hazard Communication (Hazcom) training, but only the host employer can train where the Safety Data Sheets (SDSs) are kept in the facility, the chemicals used, etc.

Both the temporary agency and the host employer are responsible for ensuring that employees are effectively informed and trained regarding exposure to hazardous chemicals. The directive titled Inspection Procedures for the Hazard Communication Standard, 29 CFR 1910.1200, CPL 02-02-038, specifically discusses this issue:

• [Hazard Communication Standard] training of temporary employees is a responsibility that is shared between the temporary agency and the host employer. The host-employer holds the primary responsibility for training since the host employer uses or produces chemicals, creates and controls the hazards, and is, therefore, best suited to inform employees of the chemical hazards specific to the workplace environment. The temporary agency, in turn, maintains a continuing relationship with its employees, and would be, at a minimum, expected to inform employees of the requirements of the standard. (CPL 02-02-38, Appendix A, Section h, March 20, 1998)