Injury and Illness Recordkeeping Requirements

This is the first in a series of guidance documents issued under the Occupational Safety and Health Administration’s (OSHA’s) Temporary Worker Initiative (TWI). This Initiative focuses on compliance with safety and health requirements when temporary workers are employed under the joint (or dual) employment of a staffing agency and a host employer

When a staffing agency supplies temporary workers to a business, typically, the staffing agency and the staffing firm client (also known as the host employer) are joint employers of those workers. Both employers are responsible to some degree for determining the conditions of employment and for complying with the law. In this joint employment structure, questions regarding which employer is responsible for particular safety and health protections are common. This bulletin addresses how to identify who is responsible for recording work-related injuries and illnesses of temporary workers on the OSHA 300 log. 

Injuries and illnesses should be recorded on only one employer’s injury and illness log (29 CFR 1904.31(b)(4)). In most cases, the host employer is the one responsible for recording the injuries and illnesses of temporary workers. 

Injury and illness recordkeeping responsibility is determined by supervision. Employers must record the injuries and illnesses of temporary workers if they supervise such workers on a day-to-day basis (29 CFR 1904.31(a)). Day-to-day supervision occurs when “in addition to specifying the output, product or result to be accomplished by the person’s work, the employer supervises the details, means, methods and processes by which the work is to be accomplished.” See OSHA FAQ 31-1 at (Essentially, an employer is performing day-to-day supervision when that employer controls conditions presenting potential hazards and directs the worker’s activities around, and exposure to, those hazards.) In most cases, the host employer provides this supervision.

While the staffing agency may have a representative at the host employer’s worksite, the presence of that representative does not necessarily transfer recordkeeping responsibilities to the staffing agency. As long as the host employer maintains day-to-day supervision over the worker, the host employer is responsible for recording injuries and illnesses.

Read the full article here: Osha Temporary Worker And Recordkeeping Nov 2016


If your company is impacted by the changes in the Fair Labor Standards Act (FLSA) Overtime rules and you are now confused due to the election results, the PIA HR Listserve Networking Groups has been atwitter since the results of the Presidential Election this past Tuesday and we would like to share the comments with you.

President-Elect Trump has made many references to reexamining and possibly eliminating many onerous rules and regulations and this has given some of our members hope that the December 1st implementation date for the new rules will be delayed or rescinded.

Some of our member companies have voiced the opinion that they should delay or even overturn decisions that they have already implemented. However, the prevailing opinion of the many HR managers throughout the country who commented on the topic, as well as the VP of HR for PIA, Adriane Harrison, is that you should apply any required changes by the December 1 deadline. President-Elect Trump does not take office until January 20th and even if he is inclined to make changes in the FLSA Overtime rule there is no indication at this point that he will make it his first or even one of the top priority of his administration.

The HR Listserve Networking Group is available to all members and is a valuable benefit of PGAMA membership. The subjects that are initiated, and the opinions rendered, vary and are offered from print colleagues from all over the country. To join the HR listserv and see what other listservs are available see:

If you have any questions and would like to discuss this or any other matter, please contact This email address is being protected from spambots. You need JavaScript enabled to view it. or call, 410-319-0900 or Toll Free 1-877-319-0906

FLSA Webinar See It Here

PGAMA is always on the lookout for new and improved member benefits to offer.  Sometimes however there are a suite of benefits that are already available to our members but are not as aggressively promoted as some and that is the case with our “financial insurance” package of Slow Pay, PGAMA Credit Check and PICB Collections Service.  Each, in their own right, are powerful tools to help your business but taken as a package they create a best practices process and could make a major difference to your cash flow and bottom line.

slowpay Slow Pay is a repository of member reports on clients that have not paid their invoices.  Once you enroll, you should regularly monitor the site and make sure that a new customer has not been reported as a late pay.  This service is free to PGAMA members and could be considered your first line of defense in deciding if and how to do business with a new client or perhaps a client that is returning after an absence of some time.  If you are unfortunate enough to have a slow pay client, this is where you would report it.  Contact Esther Slansky at PGAMA office or email her at This email address is being protected from spambots. You need JavaScript enabled to view it. and she will enroll you in the program and explain how it works. 

PGAMA Credit Check  At PGAMA we give you choices when it comes to credit checks.  Our in-house credit check service is free to members and easy to access.  Just contact Debbie Woolbright  This email address is being protected from spambots. You need JavaScript enabled to view it. or call the PGAMA office and she will send you a form to fill out. Once you return it, we spring into action checking the information that you obtained from your customer. Based on the information you learn from our credit check, you can make an informed decision about how you will handle the financial arrangements with your new customer.  If you want more, PGAMA has a partnership with Experian, a major international credit bureau.  This service has a cost associated with it, but all PGAMA members receive a discounted fee.  The major difference is that Experian provides you with a credit score and has a deeper reach than a normal credit check.  The choice is yours! 

picb logo  PICB – a Check-IT Company  If in spite of taking all the precautions available, you make the decision to turn an account over for collection, PGAMA has partnered with PICB, a firm with a long history of involvement in the printing industry. While PICB also offers credit check services, their uniqueness in our package for PGAMA members is the collection services.  

To learn more contact Jay at  This email address is being protected from spambots. You need JavaScript enabled to view it. or you may wish to contact Andrea Schlack  directly at PICB.  She can be reached at 847-265-0400 or at This email address is being protected from spambots. You need JavaScript enabled to view it.

PGAMA members working together and using best business practices can make for a stronger industry and enhanced bottom line for all.  Please don’t hesitate to contact any of us at PGAMA for further information.

by Jeff Tomlinson, President Atlantic Graphic Systems

For members of our industry, the DRUPA International Trade Fair in Düsseldorf, Germany can be described as a professional pilgrimage. The expo, which occurs every 4 years, is the “World’s Fair” of Graphic Communications Technology. 

DRUPA 2016 consisted of 19 exhibition halls, had 1,828 exhibitors and logged over 260,000 visitors from 183 countries. The industry equipment on display represented both the latest consumer-ready products as well as manufacturer prototyped technology. 

The weather in Germany is generally beautiful at this time of year and it doesn’t hurt that you can grab a beer and a brat and take in some sun in the open courtyard between exhibit halls. However, given the time and treasure required, that alone is not reason enough to attend.

So then why attend? As so often is the case in business, management is hunkered down in the day-to-day and as the idiom goes, “can’t see the forest for the trees.” The DRUPA Expo provides those print executives tasked with planning for the future, an opportunity to step out of the trees and gain perspective. At no other place and time is there such a gathering of industry peers, speakers, consultants, engineers, and manufacturers. Given the international flavor of this event, attendees from North America are also exposed to a broader take on our industry and its trends.

From my perspective as an equipment supplier, I attended in the hopes of getting a better understanding of where manufacturers are investing their R&D money and what was the overall theme of their exhibits. Here’s a quick overview of what I came away with:

Print Output Devices: While their current iterations were on display, both traditional and digital printing equipment manufacturers alike had their commercial grade inkjet print platforms featured front and center in their exhibits. Unlike currently available models, most of these second or third generation prototypes target higher quality, larger format and higher volume print segments that have traditionally been dominated by offset technology. These machines were impressive and great strides have been made in this technology since DRUPA 2012. It was evident, however, that we’re still in the pioneering phase of inkjet print technology as it relates to the general commercial and packaging segments of the market.

Binding & Finishing Machinery: As you’d expect, these manufacturers are also scrambling to keep up with developments in low and high volume digital print output. At DRUPA, most exhibits featured machinery design that focused on a very high level of automation and ease of operation. Whether it was cutting, folding, stitching, binding, die-cutting or foil-stamping, the theme was reducing the touchpoints and associated labor in the manufacturing process. Many brand new finishing platforms have been developed to replace antiquated machinery or to address processing needs not previously in existence. The varied array of these solutions was very impressive.

Perhaps the most important takeaway I had was the fact that while evolving quickly, the Graphic Communications industry is still very much a vibrant, exciting industry. New technologies were abound including expanded offerings in laser finishing, grand-format, and 3D printing. I gained a much better understanding of what is viable present-day technology and what the ultra-smart, thinkers of our industry envision in the not so distant future.

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"Developing a network of like-minded colleagues takes valuable time and energy. I’m so grateful that I am entrenched with PGAMA because they provide those important networking opportunities for me on a regular basis. I link up with colleagues, friends and make important connections that really make a positive impact on my business."

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