Contractor and visitor incidents: who reports and records what
Short answer
Sort a non-employee incident by who was hurt and who supervised the work. OSHA logs cover employees and workers you supervise day to day. An injured visitor never goes on the 300 log. Patient-safety events go to QAPI. Premises claims go to your carrier. One incident can be all three.
Who records a contractor, temp or visitor injury?
The employer that supervises the worker day to day. You record your own employees and workers you supervise, once, on your log or the other employer's (29 CFR 1904.31). An injured visitor is not an OSHA log entry.
Day-to-day supervision means control over the details, means, methods and processes of the work. That employer also reports a death, in-patient hospitalization, amputation or loss of an eye (OSHA FAQ 39-9).
Where each person's incident goes
The table shows where each case lands.
| Person | OSHA log and reports | Patient safety and QAPI | Liability and premises |
|---|---|---|---|
| Your employee | Your 300 log | If a patient was involved | Workers' compensation |
| Temp you supervise day to day | Your log | If care was involved | Agency contract |
| Contractor's worker, directed by contractor | Contractor's log | If a patient was affected | Contract, insurance |
| Visitor or family member | None | Only if a patient was involved | Tell your carrier |
| Patient hurt by contractor's work | None for the patient | Yes, adverse event | Maybe, with the contractor |
Three questions for every incident
Ask three questions in order. Who is the person? What harm resulted? Who controlled the hazard?
OSHA's multi-employer policy names four roles: creating, exposing, correcting and controlling. A host or controlling employer can be cited for not taking reasonable care to find and fix hazards. That duty is lighter than for its own staff.
CMS counts contractors, volunteers and per diem staff as staff for training. The nursing home crime-reporting rule covers contractors.
| Scenario | Who records and reports | What you still do |
|---|---|---|
| A contractor's electrician, supervised by the contractor, falls from a ladder in your building | The contractor, who supervises | Document it, check your hazard, tell your carrier |
| An agency nurse, directed by your charge nurse, is hurt by a patient | You, if you control how the work is done | Treat as a staff injury; agree process with agency |
| A visitor slips on a wet floor and fractures a wrist | No OSHA entry or report | Tell your carrier, fix the hazard, brief the safety committee |
| A delivery driver is hurt on your loading dock | Usually the driver's firm | Document it; check your dock for hazards |
What to log for every non-employee incident
Log these six things every time.
- WhoName, employer, role, contact. For a contractor, add the supervising employer and site contact.
- What and whereTask and exact location.
- Who supervised, who controlled the areaThese answers decide the OSHA and multi-employer questions.
- Harm and careHarm, care given, any admission.
- NotificationsContractor's firm, your carrier, any agency, with times.
- Follow-up ownerWho checks your hazard, and who owns any contractor action.
Visitors and temporary staff
For a visitor, record name, contact, whether they came with a patient, the harm, witnesses and the condition behind it. Offer first aid. Say nothing about fault.
Settle in writing with the staffing agency who directs the work day to day. OSHA looks at control, not the contract label.
Contracts and liability
Settle reporting duties in the contract before work starts.
- Set reporting speed and contacts in contractor agreements.
- Keep insurance certificates on file.
- Read your liability policy's notice terms and meet them.
- Keep evidence, such as photos and camera footage, until resolved.
- Agree who investigates what before a contractor starts work.
- Give each contractor a one-page orientation: how to report, emergency numbers, who to tell.
Mistakes to avoid
These habits leave incidents unreported or unowned.
- Entering a visitor on the OSHA 300 log.
- Assuming the contractor will tell you.
- Using a form that demands an employee ID.
- Assigning corrective actions to a contractor with no contract term.
- Treating visitor falls as claims only. They show hazards patients share.
How IncidentKit changes the job
One intake covers employees, contractors, visitors and patients, by QR codes, email-to-incident or web form. Lauren asks who the person is and who supervised. A person reviews and signs.
Routing sends each case to the right owners. Roles and facilities limit who sees patient information. The Open plan is free for incidents without it. Patient information needs the Regulated plan, which includes a business associate agreement (BAA).
The parts of IncidentKit behind this
- Incident reporting: The full record holds who, what, where, harm, evidence and what happens next.
- QR and quick report: Scan a QR code, fill in three fields, and the incident is on record.
- Email-to-incident: Forward a complaint or vendor email and it becomes a draft incident.
- Routing and escalation: Severity decides who gets paged, and it escalates if nobody acts.
- Multi-site and roles: Run one program across many sites, with six roles and single sign-on.
- Analytics: See which rooms, shifts and equipment keep showing up in your incidents.
Frequently asked questions
Does a contractor's injury go on my OSHA 300 log?
Only if you supervise that worker day to day. Otherwise the contractor's employer records it, once only (29 CFR 1904.31).
Do I have to report a visitor's injury to OSHA?
No. OSHA's rules in 29 CFR Part 1904 cover employees. An injured visitor can still involve your carrier, state license rules and safety committee.
Is a visitor's fall a patient-safety event?
Not by itself, since QAPI tracks patients. But a visitor's fall can show a hazard patients share, such as a wet floor. Record it and trend it by location.
Who investigates a contractor injury at my facility?
Best case: both firms work it together. The contractor's firm handles its own incident and OSHA duties. You investigate the hazard you control.
Sources
- OSHA: 29 CFR 1904.31, covered employees
- OSHA: Recordkeeping FAQ 31-1, meaning of supervised
- OSHA: Recordkeeping FAQ 39-9, who reports for a temporary worker
- OSHA: CPL 2-0.124, Multi-Employer Citation Policy
- CMS: QSO-23-04-Hospitals, workplace violence memo, November 28, 2022
- CMS: State Operations Manual Appendix PP, F609 covered individuals
Reviewed against the sources above on Oct 5, 2026. Rules change: confirm current requirements with the issuing body or your counsel before relying on any summary.
Start with one incident.
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