Temporary Healthcare Workers – A Shared Responsibility

Many medical and dental practices rely on temporary staff to help manage busy schedules, staff shortages, or seasonal increases in patient volume. While temporary employees can be an essential part of maintaining operations, it is important to remember that they must receive the same workplace safety protections as permanent staff, especially regarding exposure to bloodborne pathogens.

When a staffing agency provides temporary workers to a healthcare facility, both the staffing agency and the healthcare facility are considered joint employers under OSHA. This means that both parties share responsibility for ensuring workers are protected from occupational hazards.

Although responsibilities can be divided through contracts or agreements, neither employer can transfer or avoid their obligations under OSHA regulations.

Healthcare Practice Responsibilities

Because healthcare practices control the work environment and daily operations, they typically have the primary responsibility for protecting workers at the job site. For medical and dental offices, this includes:

• Maintaining a written Exposure Control Plan
• Identifying job tasks that may involve contact with blood or other infectious materials
• Providing site-specific bloodborne pathogens training
• Supplying and enforcing the use of appropriate personal protective equipment (PPE)
• Ensuring sharps containers and biohazard disposal systems are properly maintained
• Recording exposure incidents and maintaining required injury and sharps logs

Staffing Agency Responsibilities

Staffing agencies also play an important role in protecting temporary workers. Their responsibilities include:

• Providing general bloodborne pathogen awareness training
• Offering healthcare workers the hepatitis B vaccination series
• Maintaining temporary employee records – both medical and training
• Coordinating post-exposure medical evaluations if an incident occurs

One of the most common compliance issues arise when responsibilities between the staffing agency and the host employer are not clearly defined. Before a temporary employee begins work, both parties should communicate and establish clear expectations regarding job duties, potential hazards, required training, and exposure response procedures. These responsibilities should be documented through written agreements to eliminate uncertainty and ensure both employers understand their respective obligations.

This coordination helps verify that workers receive proper protection and prevents gaps in safety procedures that could increase the risk of exposure.

What This Means for Your Practice

If your practice uses temporary workers for housekeeping, sterilization, or clinical support, make certain they are included in your safety programs. Protecting temporary workers is not only an OSHA requirement, it is also an important part of maintaining a safe environment for your entire healthcare team.