OSHA's recent decision to hold both host employers AND staffing agencies jointly responsible for employee safety had more than a few of us scratching our heads. It's not that safety has never been important to us, because it has, but when any one office can literally send hundreds of workers to dozens of different clients using only a few internal staffers, how in the world are we supposed to keep track of what every single client is up to? Its impossible, right? Just like when OSHA pays someone a visit, couldn't a client just spiff things up for our plant tour, slap some duct tape here and there, hide the skateboards and exposed electrical wire, then then go back to their old bad habits when we leave?
Turns out, the key here seems to be agencies doing their due diligence when it comes to ensuring a safe workplace for their employees, which ultimately boils down to effective and consistent communication between agencies and the host employer. This communication is best conducted when staffing agency reps are physically at the facility. Clients who think they can utilize temps without letting agency reps in beyond the initial plant tour need to think again. Think of it as a value added, another set of eyes that protects both sides. We are, in a way, partners with our clients after all. We both have skin in the game of safety, something to gain and something to lose. OSHA has made it clear that ignorance of hazards is no excuse, so we need to make finding and fixing those hazards our business, to the very best of our ability.
And that all comes down making sure we are physically inside our client facilities on a regular basis. Sure, you should always conduct a walk-through before even agreeing to do business with a client. If a potential new client calls and just needs somebody you could send tomorrow in a pinch, but doesn't have time to let you do a plant tour, the absolute last thing you should do is even dream of staffing that client. However, even if the services you are providing your client allow you to be in the facility regularly (and especially if not), you should also conduct quarterly or semi-annual walkthroughs where you are entirely focused on safety and nothing else.
Remember, we don't have to become experts, but we do need a working knowledge of where we are sending our temps and what they will encounter. Here are a few practical tips for conducting a great client walkthrough. Do this right and regularly, and you are well on your way to the necessary, OSHA required business of due diligence when it comes to the safety of your temporaries.
1.) Housekeeping - Always remember, poor housekeeping is a sign of poor management. If the facility is in disarray, not only will there likely be safety problems, but there very well could be other issues, even financial ones that could land your potential new client in the collection file.
2.) Morale - Do the regular employees seem reasonably happy? Do they make eye contact with you and the person giving the tour? Does your guide know and address their employees by name? This has more to do with safety than you might think. In fact, it's probably safe to say that if employees are miserable at their work they are more likely to get injured.
3.) OSHA log - While you're there, ask for the client's OSHA Form 300. Taking into consideration the business they are in and the rate you will give them to account for that, how many injuries do they have versus employees in the plant? Do the numbers line up with your other clients in similar industries? Do the recorded injuries have a pattern or are they really random occurrences? For example, are there several injuries on one machine, and is that machine still running without modifications? Don't be afraid to ask questions. A good client partner will answer them and appreciate your due diligence.
4.) Safety training - Does your client conduct safety training? How often? Most importantly, are temporary and contract employees always included in this training? If not, we have a huge problem that, if not corrected, would be worth severing the business relationship over.
5.) Make a list and check it twice - In the hustle and bustle of a plant tour, it's easy to get distracted and forget what you're looking for. Having a list of things to check off will help you focus on the task at hand. If you don't already have one, your insurance provider should be able to help you put a checklist together that's fairly easy for us "non-experts" to complete.
BONUS - Know your client's worker comp mod - If you ask someone in HR, they may not even know this. However, you can purchase it for a small fee through the NCCI (National Council on Compensation Insurance). If the mod is above 1, that indicates their experience is worse than the norm for that class code in their state. If it's above 1.3, take a hard look at whether you want to do business with them, taking your plant tour experience as well as the rate you will be giving them into consideration, of course. Additionally, if the client has undergone any OSHA inspections, you can drill down on the data section of OSHA's website to get those results and more information.
Doing our due diligence on the staffing end can help ensure we not only meet OSHA requirements, but also give our employees the best possible shot to come home safe to their families at the end of every workday.