Who must train temporary employees (temp workers) under the Hazard Communication (HazCom) standard?

Staffing agencies and host employers share control over temporary employees and are therefore jointly responsible for ensuring that they are effectively informed and trained regarding exposure to hazardous chemicals. When employees from a staffing agency are working at a site where hazardous chemicals are being used, the responsibility for training is shared by the staffing agency and the host employer. In order to ensure that employers have complied with all requirements of the Hazard Communication standard (HCS), contracts between staffing agencies and host employers should be examined to determine if they set out the training responsibilities of both parties.

The staffing agency must, at a minimum, provide generic training to its employees on the requirements of the HCS applicable to different occupational settings and have a duty to inquire and verify that the host, in turn, has adequately fulfilled its shared training responsibilities for assigned employees.

The host employer (the company using temporary employees) holds the primary responsibility for training since it 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 through site-specific training. This duty includes identifying and communicating site-specific hazards and providing appropriate protective equipment to temporary employees. The HCS training provided to temporary employees should be identical or equivalent to that given to the host’s own employees performing the same or similar work.

Refer to OSHA’s Temporary Worker Initiative (TWI) Bulletin No. 5 - Hazard Communication (OSHA 3860 - 2016) for further information.