Special Topics in Safety Management

Temporary Workers and I2P2 Programs: Program Components

Temporary workers are a high-risk group for serious injuries and illnesses. One way to help ensure that they don’t fall through the cracks between the leasing agency’s safety program and the host employer’s safety program is for both employers to implement an effective I2P2 program.

Yesterday, we looked at the regulatory requirements that cover I2P2 programs and at the components of an effective program. Today, we’ll take a closer look at three components of an effective I2P2 program: hazard identification, training, and program evaluation.

Hazard Evaluation

In its guidance document, Recommended Practices for Protecting Temporary Workers, OSHA recommends that both leasing agencies and host employers conduct worksite hazard evaluations and include any identified hazards in their I2P2 program. OSHA emphasizes that some hazards may require the development of hazard-specific programs. Such programs include bloodborne pathogens, hearing conservation, hazard communication, respiratory protection, and control of hazardous energy (lockout/tagout).

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OSHA has identified training as an area that receives inadequate coverage for temporary workers. An I2P2 program will help both host employers and staffing agencies to ensure that workers receive adequate training.

Responsibilities for education and training are typically split between the host employer and the staffing agency. The staffing agency may provide basic subject matter training (for example, in confined space and lockout/tagout awareness), while the host employer provides the site-specific component (for example, showing temporary employees where permit-required confined spaces are located, and what energy control tags look like).

The employers’ safety programs should be communicated at the start of each new project, whenever new temporary workers are brought onto an existing project or whenever new hazards are introduced into the workplace.

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Program Assessments

For both staffing agencies and host employers, a quality program will be continually assessed to evaluate the consistency, timeliness, quality, and adequacy of the program. Leading indicators, such as training records and the number of hazards identified and corrected, should be included in the assessments.

OSHA recommends that these assessments take place at least on an annual basis and that they result in prioritized recommendations for program improvement.