Temporary Workers and Lockout/Tagout

The Joint Responsibilities of Temp Staffing Agencies and Host Employers

The Temporary Worker Initiative defines the responsibilities of temporary-worker staffing agencies and host employers to protect temporary workers under the federal Control of Hazardous Energy (Lockout/Tagout) Standard (29 CFR 1910.147).

What is the LOTO Standard?

The Lockout/Tagout (LOTO) Standard identifies the control of energy hazards for all forms of energy:

Electrical
Mechanical
Hydraulic
Pneumatic
Chemical
Thermal

Contract Language & the LOTO Standard

The temp agency and the host agency are joint employers, and both are responsible for ensuring that temporary employees are properly protected against the sudden release of stored energy. Host employer and temp agency jointly review the task assignments, identify job hazards, and define the details of the protections and training to be provided.

Temp Agency Responsibilities

Inquire about the hazards to which its employees will be exposed
Ensure the host employer has a site-specific lockout/tagout program that protects temporary workers
Ensure the host employer provides site-specific training to the workers
Communicate all lockout/tagout policies and procedures to temporary workers
Ensure that affected employees (temp employees who do no service/maintain hazardous energy devices BUT work in an area where lockout/tagout procedures are in place) are trained in the purpose and use of energy control procedures (see 29 CFR 1910.147(c)(7)(i)(B))

Host Employer Responsibilities

Inform the staffing agency of training requirements the staffing agency is expected to provide temporary workers (including affected employees) regarding:
- exposure to uncontrolled energy
- lockout/tagout policies and procedures
Confirm the staffing agency is aware of any changes in workplace hazards

The Importance of Communication

Avoid an OSHA citation for noncompliance with the Lockout/Tagout standard. BEFORE the temporary assignment starts:

Clearly define staffing agency and host employer roles
Ensure adequate lockout/tagout training will be provided and who will provide the training
Identify all equipment requiring hazardous energy controls

Questions or Need Help? Give us a call at (512) 301-1451 and we’ll be happy to assist in answering your questions.

Additional Resources: OSHA’s guidance bulletin