Sub Specialty Contractor

Good morning,

All hours worked should be included in your calculations and reported on OSHA form 300A, including temporary employees.  Here's the OSHA standard related to this: OSHA Standard Number: 1904.32

For kicks,  I posed your question to CoPilot and got the following response.

When calculating Total Recordable Incident Rate (TRIR), the inclusion of temporary labor hours depends on who has direct supervision and control over the temporary workers.

✅ Include Temporary Labor Hours If:

• The temporary workers are under your direct supervision.
• They are performing work on behalf of your company, at your site, and you control their day-to-day activities.
• You are responsible for reporting their injuries to OSHA.

In this case, both their hours worked and any recordable incidents involving them should be included in your TRIR calculation.

❌ Do Not Include Temporary Labor Hours If:

• The temporary workers are supervised by the staffing agency or another contractor.
• The staffing agency is responsible for OSHA recordkeeping and injury reporting.
• You do not control their daily work activities.

In this scenario, their hours and incidents would be tracked by the agency, not your company.

📊 Why This Matters:

TRIR is calculated as:

Including temporary labor hours without their incidents (or vice versa) can skew your TRIR, making it appear artificially high or low. That's why OSHA emphasizes consistency in who supervises and reports.

Joseph I Gravenstine, CPA

CFO

1424 Easton Road, Suite 400

Horsham, PA 19044

O: (215) 938-8880

C: (215) 888-8884

jgravenstine@ngmco.com