Who Trains Temporary Workers? (and more……)

1. Who Trains Temporary Workers? (and more……)

2. Do hard hats work? If you don’t wear yours your head could end up looking like this

4. Objectives • Temporary help facts, history and info • Definitions important to the subject • Recordkeeping (OSHA Part 1904) • Training: who, what, why, when, where and how • Rumpke training and partnership • Class participation exercise

5. Temporary Worker History • William Russell Kelly- 1946 • “The Kelly Girl” (1956) • Kelly coined the phrase “temp helper” • Today Kelly Svcs. chooses clients very carefully (safety record/hazards and nature of business) 1956

6. Temporary Help, History and Info • Temp worker’s increased due to revised “independent contractor” tax laws in mid 1980’s • 0.6% of US workforce in 1982 (80K)* • 11% of US work force in 2009 (14M)* • Federal governmentemployment was up in April 2010 (66,000 temporary workers for the decennial census)** * Source- www.kiplinger.com ** Source- www.bls.gov

7. Definitions • Host employer - The client (Rumpke, etc.) of a Worker Leasing Company or a Temporary Service Provider who is using leased or temporary employees. • Temporary Service Provider – Staffing provider that provides workers to a client by contract and for a fee on a temporary or unknown period of time. • Professional Employer Organization (PEO)-Provides workers for a predetermined period of time by contract and for a fee to work for a client.

8. OSHA Recordkeeping • OSHA 1904.31- From OSHA recordkeeping handbook roadmap (www.osha.gov) • (2) If I obtain employees from a temporary help service, employee leasing service, or personnel supply service, do I have to record an injury or illness occurring to one of those employees?YES!You must record these injuries and illnesses if you supervise these employees on a day-to-day basis.

9. Training Who, what, when, where, why and how?

10. Challenges to Training • Possible language barriers (Latino, Samoan, etc.) • Dedication (employer and employee-opinion/morale) • Host employer (The water faucet theory or “Not my ee” • Temp employee “They have other assignments for me” • Temporary employer safety training is usually very generic • Hazard assessment performed by temporary employers are generally not sufficient to indicate all hazards at host employer sites • Management using temps for unknown tasks

11. Training Excerpt from- OSHA Interpretation letter 9/21/2000- • “Although the host employers would, in most situations, provide the workplace-specific training that is necessary and appropriate for the employees' job assignments and tasks, the temporary agency employer would still have the responsibility to ensure that the employees had been properly trained. Therefore, if a host employer provides any training, the temporary agency employer would have to have a reasonable basis for assessing that the host employer's training is adequate.”

12. Training- What & How • Training should be specific to the type, size and source of the hazard and or task • PPE training must be thorough (when, wear, care, limitations, replacement) • Some training may require classroom and practical (PIT, AWP, Cranes, etc.) • What- Based on job hazard assessment (JSA) • Must be in a manner that is understood!

13. Understood?? WWE- Rey Mysterio video

14. Training Excerpt from OSHA CPL 2-2.38 (1998) “Furthermore, the training must be comprehensible. If the employees receive job instructions in a language other than English, then the training and information to be conveyed under the HCS (Haz-Com) will also need to be conducted in a foreign language.”

15. Training- Who & When • All employees (temps included) • Some OSHA regs require prior to assignment (Ex: PIT, AWP, conf space, etc) • Some require on 1st day (Ex: EAP, Warning signs and tags, right to know, fire ext, etc.) • Some require refresher (Ex: Hearing cons, Respirator, BBP, fire ext, etc)

16. Fire Extinguishers • OSHA 29 CFR1910.157(g)(1)- • Where the employer has provided portable fire extinguishers for employee use in the workplace, the employer shall also provide an educational program to familiarize employees with the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting.

17. Why and Where? • The why is evident!! • Where, this is up to you… • Host employer’s site (General, Specific and Advanced) • Temporary Employers Site (General) • Shared (Recommended) • Temporary employers site (General) • Host Employer’s site (Specific and Advanced)

18. Example of no training… The next slides are graphic and could be upsetting. If you are offended by scenes of injuries please look away now

19. Simple training (15 minutes) This simple training may have prevented this incident: • Never: • Stand on the traffic side of the truck when using the controls to cycle the packer body • Walk across into incoming traffic • Be on a roadway without your reflective PPE • Look into the rear sill of the packer body or stand where items being compacted can fly out can hit you

20. Paint spray can burst and paint hits helper in the face

21. What did we do? • Developed job/task list for temp laborers • Developed general Rumpke safety training programs • Strict responsibilities in service contract with temporary labor companies • Required temporary employer to conduct “Rumpke general safety training” • Temporary labor company trainers must attend train-the-trainer course at Rumpke • Must sign off on Rumpke training form and fax to Rumpke before temp laborer reports

22. Temporary Employee Training for Recycling Operations

23. Temporary Employment Agency completes generic training per line of business. • Both temp agency trainer and temporary employee sign form. • Copy faxed to Rumpke for filing.

24. Average Retention Rates * Source: OSU Psychological Study- 2005

25. Rates of Forgetting Content * Source: OSU Psychological Study- 2005

26. Work shop • Case #1- Garbage Truck • Case #2- Hospital • Case #3- Printing company

27. Summary • Temporary employees must be treated as host employer employees • Training must be performed based on hazards • Training responsibilities may be shared (Temp company-general/Host employer- Specific) • Service contract should set clear direct responsibilities of both parties

28. Questions?

29. Assistance (day 1 comments) • Checklist for new, rebuilt, altered, modified equipment (Rumpke form) • Baler, Shear, C/S training programs (will share) • Free trng programs- siri.uvm.edu • JSA’s (safety manager software) • Selling safety to the money men (OSHA safety pays) • Toolbox talks (dhoward@esiwaste.com) • Safetyinfo.com • Safteng.net

30. Thank you for your time and attention!! Jerry Peters, RSM gerald.peters@rumpke.com (740)207-0905