Temporary Workers and I2P2 Programs: A Critical Program for a Critical Group

Sometimes, two heads are better than one. It ought to be that way with temporary workers, who have essentially two employers, both of whom are supposed to be looking out for their safety. But in practice, miscommunication and poorly defined responsibilities lead to gaps in worker training, hazard identification, and supervision that have served to make temporary workers one of the most at-risk groups for workplace injuries—and a group whose safety OSHA is focusing on.

An injury and illness prevention program (I2P2) can help both leasing agencies and host employers ensure that there are no gaps in coverage.

I2P2 in the Rule Books

There is no federal I2P2 standard, although federal OSHA has an I2P2 rule on its long-term regulatory agenda. But there are some rules on the books that require either an I2P2 program or something very much like it:

• Construction contractors are covered by a federal OSHA standard (29 CFR 1926, Subpart C, General Safety and Health Provisions) that includes some requirements that could easily be fulfilled through a compliant I2P2 program. That standard requires each contractor/employer to initiate and maintain accident prevention programs, provide for a competent person to conduct frequent and regular inspections, and instruct each employee to recognize and avoid unsafe conditions and know what regulations are applicable to the work environment.

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• Many states have I2P2 requirements. Some require a written I2P2 program for certain industries, mostly as a requirement for workers’ compensation insurance coverage. Other states require them only for “high hazard” industries like those conducting a lot of electrical or hazardous chemical handling work, or for employers with high workers’ compensation experience modification rates (EMR). California and Washington require most workplaces to have a written plan regardless of workers’ compensation coverage. Each state calls them something different; common names are Injury and Illness Prevention Program, Accident Prevention Program, and Loss Control Program.

I2P2 and Temporary Employees

OSHA recommends, in its Recommended Practices for Protecting Temporary Workers, that staffing agencies and host employers each have a safety and health program in place. Both the staffing agency’s and the host employer’s plans should cover:

1. Hazard identification and assessment. Staffing agencies should have access to the worksite in order to conduct hazard assessments.

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2. Hazard prevention and control. Host employers are largely responsible for hazard control at the worksite. For staffing agencies, the priority should be on ensuring that the host employer is, in fact, adequately controlling hazards.
3. Education and training. OSHA has identified training as an area in which both staffing agencies and host employers often fail temporary workers, so it’s an area that the agency will pay close attention to during an inspection.
4. Program evaluation and improvement. Reviewing the program and determining how and where to improve it is a critical part of the I2P2 process.

Tomorrow, we’ll look more closely at hazard prevention, training, and program evaluation under an I2P2 program.