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Showing posts with label Long Island OSHA training. Show all posts
Showing posts with label Long Island OSHA training. Show all posts

Tuesday, March 05, 2024

That Time of Year! Conferences, Posting Requirements, and OSHA Violations Increased!

It's that time of year again. We're between conferences.  February 15-16, 2024 was the Professional Abatement Contractors of New York (PACNY) Environmental Conference and the Environmental Information Association (EIA) National Conference & Exhibition is March 18 - 21, 2024.  This year we have the honor of speaking at both conferences.  We are speaking on the "Fallacy of PCM Clearance" in other words 5 reasons PCM should not be used for clearance.  We are speaking on Wednesday, March 20, 2024, at 1:00 PST if you happen to be in San Diego, California come down and say hello!  We're looking forward to arriving early and seeing the San Diego Wildlife Park and the Zoo, two different areas.  Our speech was very well received at the PACNY Environmental Conference.  If you would like to see the posts from the PACNY Conference visit PACNY's Linkedin page.


FEDTC's Booth at PACNY Conference

There are other things also happening at the beginning of the year.  For example, remember to post your Occupational Safety and Health Administration (OSHA) 300A if you have 10 or more employees, see last month's post for more information.  The 300A, which is the summation of injuries and illnesses your company had in 2023, should be posted from February 1st, 2024 to April 30, 2024.  Also, remember certain employers must electronically submit the OSHA 300A information directly to OSHA by March 2, 2024.

300a Must Be Posted & For Some Must be Submitted

On January 16, 2024, the OSHA maximum penalties for serious and other-than-serious violations increased from $15,625 per violation to $16,131 per violation.  The maximum penalty for willful or repeated violations also increased from $156,259 per violation to $161,323 per violation.  These increases happen every January 15th.  This year's increase was delayed because January 15th was a Federal holiday (Martin Luther King Day).

Looking Forward to EIA's Conference in San Diego & Visiting the Wildlife Park




Monday, November 21, 2022

Top 10 Most Frequently Cited Standards for Fiscal Year 2021 (Oct. 1, 2020, to Sept. 30, 2021)

The Occupational Safety and Health Administration (OSHA) annually posts the top ten frequently violated standards.  The purpose of this posting is to give employers the opportunity to fix these violations before OSHA inspects your project site.  When we discuss these with our clients and students we call these violations the low-hanging fruit for OSHA.  

  1. Fall Protection, construction (29 CFR 1926.501) [related safety resources]
  2. Respiratory Protection, general industry (29 CFR 1910.134) [related safety resources]
  3. Ladders, construction (29 CFR 1926.1053) [related safety resources]
  4. Hazard Communication, general industry (29 CFR 1910.1200) [related safety resources]
  5. Scaffolding, construction (29 CFR 1926.451) [related safety resources]
  6. Fall Protection Training, construction (29 CFR 1926.503) [related safety resources]
  7. Control of Hazardous Energy (lockout/tagout), general industry (29 CFR 1910.147) [related safety resources]
  8. Eye and Face Protection, construction (29 CFR 1926.102) [related safety resources]
  9. Powered Industrial Trucks, general industry (29 CFR 1910.178) [related safety resources]
  10. Machinery and Machine Guarding, general industry (29 CFR 1910.212) [related safety resources]
OSHA in a sense is providing you with fair warning that during an OSHA inspection these are the first thing they will be looking at.  Many of these items can be easily resolved before OSHA arrives, such as respiratory protection, hazard communication, ladders, fall protection training, scaffolding, and powered industrial trucks.  Remember these items must be documented and this can be easily done, also.



Future Environment Designs together with SiteDocs can handle the documentation and training requirements for the above safety hazards and have this information easily documented.  With SiteDocs this documentation is readily available on multiple devices allowing inspections in the field to be documented, stored, and made available upon request.  Future Environment Designs can not only provide your staff the training and documentation required either in-person, virtual, or through e-learning, but we can also create the written programs and inspections required under the various standards.  So visit our website and click on Contact to start discussing how we can help you be better prepared for an OSHA inspection.



Saturday, December 26, 2020

A Merry Holidays and a Happy New Year! We wish you a New Year better than the last one and the best one yet!

Future Environment Designs Training Center (#FEDTC) wishes you and your family a Merry Holidays and a Happy New Year.  As we say goodbye and good riddance to 2020.  At the same time, we enter 2021 with hope and faith that the rest of the decade will be better than it started.  As we discussed, in December's Safety Suzy Newsletter this year the asbestos training industry was shut down from March to May, until we were allowed to do refresher classes virtually/online.  Then in-person training for initial training was opened in June and refresher classes were opened in July.  Since July, we were only allowed to hold classes at 50% capacity.  We're still running at 50% capacity and will continue to run at this level and follow our pandemic policy in our in-person classes until the pandemic is over.

Rockefeller Christmas Tree

In our December Safety Suzy, we announced an increase in our loyalty discount for students who trained with us in 2020.  The loyalty discount for 2021 has been increased to 25% (from 15%).  We thank all of you for your continued support of our business.  For those paying for a subscription or purchasing training services in advance, we are increasing the discount you receive for purchasing training services in advance.  See our Patreon website for more information.

Socially Distanced Asbestos Initial Class

We are proud to announce the addition of a new instructor at #FEDTC.  Mr. Ramon De Los Santos who is an Occupational Safety and Health Administration (OSHA) Outreach Training Instructor has over 15 years of construction experience in road construction safety.  Mr. De Los Santos is bilingual and speaks English and Spanish fluently.  #FEDTC will be adding Spanish OSHA 10-hour & 30-hour construction safety courses to our schedule.  We look forward to adding this training to our schedules along with Spanish versions of hazard communication/right-to-know; excavation, and fall protection courses.  Welcome aboard Mr. De Los Santos!

Fifth Avenue Star

Since the pandemic started we have added new on-demand/e-learn courses to our catalog.  We have added a two-hour Covid-19 awareness course, a 4-hour bloodborne pathogen course, and newly added to the catalog the AHERA designated person course.  The AHERA designated person course is required by the Environmental Protection Agency (EPA) under the Asbestos Hazard Emergency Response Act (AHERA) for the person that the Local Education Agency (LEA) designated as the individual responsible for ensuring the requirements of the AHERA regulation are properly implemented.  To register for this course or any of our on-demand/e-learning courses visit FEDTC's online training website.     

Socially Distanced Initial Mold Class

We are looking forward to seeing all of you in 2021.  We are also excited about the changes and opportunities coming our way.  Again, we wish you & your family a Merry Holidays and a Happy New Year!!!

Friday, December 28, 2018

Merry Holidays and a Happy New Year From Future Environment Designs Training Center. The Only Constant is Change!

We wish all of you who read our blog and attend our classes a Merry Holidays and a Happy New Year!  We hope your 2019 is better than your 2018 and may it be healthy, prosperous, and joyful!

Rockefeller Center Christmas Tree
2019 will bring some changes to Future Environment Designs Training Center (#FEDTC).  The first change is to continue to grow our online training by providing training tokens to our clients who attend our asbestos & mold courses.  This added value to our current courses continues to distinguish us from our competitors.  So we can add training courses our clients/students would be interested in, we are asking our attendees for suggestions for classes we can develop into online training courses.  In addition, we are strongly considering becoming a New York State Education facility (we hope to have the financing for this undertaking within 2-3 weeks of the New Year).  This would allow us to offer the New York City training courses and provide the Site Safety Training cards.  It would also require us to expand the number of training instructors we use.  This will be a major undertaking and as many of you who know me, will take tremendous courage on my part to overcome my fears related to trusting others with my business.   2019 is already starting on a good beginning with several courses almost fully booked in the first quarter.

Bergdorf Goodman Window
No sooner than the New Year of 2019 rings in, New York City will be going through several changes.  The asbestos amendments to Title 15 will go into effect January 6, 2019, and the Indoor Allergen Rule goes into effect on January 16, 2019.  In New York State before the New Year hits (December 31) the minimum wage will go up.  In addition, don't forget to save the date for the Professional Abatement Contractors of New York's  (PACNY) 23rd Annual Environmental Conference on February 27-28 & March 1, 2019, at Turning Stone Resort & Casino in Verona, New York.  We will be your host for the February 27th, the proficiency day, where we will be discussing asbestos inspections/survey among other things.  We hope to see you there!  Again, we wish you a Merry Holidays & a Happy New Year!

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Tuesday, May 15, 2018

OSHA Fines Increase - Silica Rule Enforcement Ramps Up

On January 2, 2018, the Occupational Safety and Health Administration (OSHA) has increased the maximum civil penalties (fines) for serious, other-than-serious, and posting requirements to $12,934, from $12,471.  Failure to Abate violations have increased to $12,934 per day beyond the abatement date from $12,471 and Willful/Repeat violations have increased to $129,336 from $124,709.  These civil penalty increases were mandated by Congress, on November 2, 2015, through legislation that required all federal agencies to adjust their civil penalties to account for inflation.  OSHA increased their penalties on August 1, 2016, the link to our previous blog post discussing that increase is below.  Moving forward, as the legislation requires, the penalties will be adjusted each year based on the Consumer Price index.  OSHA will continue to do penalty reductions based on the size of the employer and other factors.

Properly Using Table 1 Will Avoid a Violation
According to April 24, 2018, article by Bloomberg Environment, OSHA and state programs have cited the silica rule 116 times since September 23, 2017.  With OSHA ramping up enforcement of the respirable crystalline silica rule (1926.1153) incorrectly following Table 1 procedures (cited 27% of the time), and not measuring worker exposures (cited 30% of the time), can result in a serious violation at the cost of $12,934 each.  Not training workers about silica or not having a silica exposure plan may result in other-than-serious violations that could cost $12,934 each.

Using this Equipment, we can Measure Silica Exposures

OSHA's website discussing the increase in civil penalties can be found here.  While the OSHA website discussing the silica rule requirements can be found here.

Monday, May 07, 2018

PACNY's Environmental Conference, Part Three - Bomb Cyclone Hits

Winter Storm Riley at Turning Stone Casino
On the final day of the Professional Abatement Contractors of New York (PACNY) 22nd Annual Environmental Conference, we awoke in the middle of Winter Storm Riley which turned into a Nor'easter and hit Turning Stone Casino between Thursday night & Friday Morning, March 1-2, 2018 with about 7 inches of snow.  Some attendees left before the storm hit putting a further dampener on attendance.  Because of the storm, there was some concern that New York State Department of Labor (NYSDOL) would not be able to attend.  Because of a good Samaritan who helped NYSDOL representatives who were in the area get to the conference and the technological genius of Bob Krell, of Healthy Indoors Magazine, and Kevin Hutton, of Cornerstone Training, Dr. Eileen Franko was also present.

Peter Delucia, of AAC Contracting, discussing Crystalline Respirable Silica
The last day of the conference started with Peter Delucia, AAC Contracting, discussing "Managing the Many Facets of the Silica in Construction Standard."  Mr. Delucia did a great job presenting on topic and provided some excellent references related to preventing exposures, sampling, and complying with the Occupational Safety and Health Administration (OSHA) silica standard 1926.1153.  Mr. Delucia's presentation helped us develop our training courses for silica and our blog post "OSHA's Silica Standard - What's All the Fuss About?, Part Two".

NYSDOL's Presentation with Dr. Franco on Screen

The final presentation of the conference was the managers from NYSDOL, the Director Dr. Eileen Franko, present by video conference; Program Manager of Asbestos Control Bureau, Mr.  James Meachum PE;  Program Manager of Licensing & Certification Unit, Mr. Kirk Fisher; and Program Manager of Engineering Services Unit, Mr. Ed Smith, PE.  Some of the major points included:

  • Mr. Smith, announcing that they are looking into releasing some Fast Track Variances that would speed up the process of filing for a variance.  These variances could be used as they are written with no changes and those could be approved faster.
  • Mr. Smith gave us an update on the changes to Industrial Code Rule 56, including a Senate Bill (S06492) and Assembly Bill (A08254) that would remove the 1974 date from regulation for demolitions.  Mr. Smith also discussed some of the changes to New York City Department of Environmental Protection (NYCDEP) asbestos regulation Title 15.
  • Mr. Fisher announced a change in filing for a mold license for assessment and remediation companies that will require separate applications for a company license and an individual license for owners.
  • After being questioned when the removal of social security numbers from asbestos application process would happen.  Mr.Fisher informed us that would not happen in the foreseeable future.  The system they have is antiquated and there is no funding for updating it.  The system uses social security numbers to identify the holders of the various certificates.
  • Mr. Meachum discussed full-time asbestos project monitoring and the responsibilities of the project monitors being added to asbestos variances.
  • Mr. Meachum discussed the mold fact sheets that NYSDOL developed and they strongly recommend the fact sheets be provided to mold assessment/remediation clients.  In addition, Mr. Meachum announced that the first violations were sent out under Article 32, the Mold Licensing Law.  The violations were for not having a license and performing work and/or advertising as a mold professional. 

Steve Winograd & me at the PACNY Conference 
Attendance on the last day was down but it was still an excellent conference with lots of useful information.  We cannot say this enough about the excellent and hard work that Ms. Deborah Sanscrainte, of Aramsco, the conference chairperson and Ms. Lisa Brown, of Summit Environmental, Administrator put in to make the conference as good as it is.  Congratulations to the PACNY Board, as they continue to show why they are leaders for the abatement industry in New York State.

Friday, January 12, 2018

OSHA Recordkeeping Webinar To Discuss Posting Requirements For 300A Form & Filing It Electronically!

On February 1, 2018, covered employers are required to post the Occupational Safety and Health Administration's (OSHA) 300A form.  To help you with this process Future Environment Designs and Keevily Spero & Whitelaw, an insurance services company, will be holding a webinar on the OSHA Recordkeeping requirements, click here to register for the webinar.  The 300A form summarizes the injury and illness information that was kept on the OSHA 300 log form.  Covered employers are required to prepare and maintain records of serious occupational injuries and illnesses that occur at a workplace on the OSHA 300 log form.  At the end of the year, covered employers are required to tally the totals on each column and enter the totals on the OSHA 300A form.  The information should be used by employers to evaluate safety in the workplace and determine ways to eliminate or reduce hazards in the workplace.  OSHA's 300A form is required to be posted until April 30, 2018 and must be retained for 5 years.  During the retention period you are required to update the log to add new information regarding the occupational injuries and illnesses recorded on it.  OSHA has brief tutorial to help you complete the forms.

OSHA 300 Form
A final rule was issued and went into effect on January 1, 2017, requiring certain employers to electronically submit injury and illness data to OSHA.  OSHA has provided an online secure website (click here for the website) for submitting this information. You must submit this information by July 1, 2018.  If you meet the following criteria you DO NOT have to electronically submit your 300A information to OSHA:
  • The establishment's peak employment during the previous calendar year was 19 or fewer, regardless of the establishment's industry.
  • The establishment's industry is on this list, regardless of the size of establishment.
  • The establishment had a peak employment between 20 and 249 employees during previous calendar year and the establishment's industry is not on this list.
  • Establishments under jurisdiction of these State Plan states do not currently have to electronically submit to OSHA: California, MarylandMinnesotaSouth CarolinaUtahWashington, and Wyoming.
300A Form Must Posted By February 1, 2018
A different rule which went into effect January 1, 2015, changed the list of employers partially exempt from the above recordkeeping requirements.  The revised list uses the new method of classification of industries, the North American Industry Classification System (NAICS).  The partially exempt industry list includes: architectural, engineering, & related services; legal services; & drinking places (really!!!), as examples.  For the full list of exempt industries visit OSHA's website on recordkeeping.  In addition, to new exempt industries there are industries that have to start keeping records.  These industries include:  automotive dealers, building material & supplies dealers, & activities related to real estate, for example.  Find the industries that have to start keeping records here.  
Logo for NAICS (North American Industry Classi...
Logo for NAICS (North American Industry Classification System), a system used by the U.S. Census Bureau and others. (Photo credit: Wikipedia)

However, this does not exempt these industries or covered industries from reporting to OSHA, within 8 hours, any work-related fatality and reporting work-related in-patient hospitalizations, amputations, or losses of an eye within 24 hours.  This new reporting requirement was also part of the changes that went into effect on January 1, 2015.  Employers can report these events by telephone to the nearest OSHA Area office during normal business hours, or the 24-hour OSHA hotline 1-800-321-OSHA (6742), or electronically through a new tool which is being developed, look for it here.   Should you need any assistance with these requirements contact Future Environment Designs.

Monday, December 11, 2017

LITE 2017 Is All About The Fundamentals, Future Environment Designs Develops An Online Course!

Future Environment Designs (FEDTC) would like to wish all of you a Merry Holiday and a Happy New Year!  We look forward to seeing all of you in the New Year.  In September, FEDTC attended the 2017 Leadership, Innovation, Technology, & Evolution (#LITE2017) annual conference in Edinburgh, Scotland.  We attended last year's #LITE2016 conference and wrote about our experience (see Future Environment Designs Attends the LITE 2016 Conference & Is Inspired!).  The conference is run by Administrate, which is the company now handling our training and customer administration.  As many of you know, we use Administrate to provide you digital access to our course manual.  Because of the information we learned this year, you now have access to the exam review slides we use in our classes.  We now offer a few Occupational Safety and Health Administration (OSHA) courses online (i.e., respirator users and asbestos awareness) and on adding more.  What attracted us to the LITE conference this year was our desire to delve deeper into the Administrate program and to learn best practices in managing our business.  This year the conference exceeded those goals.  This year there weren't as many inspiring speakers, but many of the speakers gave us fundamental knowledge of the Administrate program and its capabilities.

View from Administrate's Offices
Like last year, the conference followed two tracks Evolution and Innovation, which we mixed and matched the various presentations throughout both days.  All the presentations from the conference can be seen at Administrate's website.  It started with opening remarks from John Peebles the CEO of Administrate, filling us in on Administrate's growth in the United States (based out of Bozeman, Montana) and in the Middle East (based out of Beirut, Lebanon).  Followed by Mike McGrail (@Mike_McGrail, formerly of Administrate and now with Velocity Digital, no kilt this time), speaking on "Busting Modern Marketing Myths".  We then listened to Simon Greany, of Elucidat, discuss "Big Learning: 4 Strategies to Help You Unlock New Revenue Streams with Digital Learning."

Natasha Serafimovska Presentation on Financial Reporting
Many of the presentations afterwards were delving into the inner workings of  the Administrate programs.  These presentations helped us get the best out of the program or gave us ideas of how to improve the information we get from the program.  For example, the presentation by Siobhain Murdoch and our Account Rep Natasha Serafimovska, both from Administrate, discussed "Common Course Pricing Strategies for Training Companies."  From their presentation we learned about creating subscriptions, how training tokens work and how to offer them.   Siobhain Murdoch then joined together with Loki Lau, of Administrate, to discuss "A Deep Dive Into Course Templates," which taught us how to improve the course templates and in particular adding photos to the templates.  Gilles Bell's, of Administrate, presentation on "How to Communicate More Effectively With Students and Customers" provided some ideas we will be implementing with our communications moving forward (first changes will be with the Safety Suzy Newsletter coming out before the end of this month).  The second day started with a 1-2-1 session with our Account Rep Natasha Serafimovska to help us better understand the program and create several reports.  Mark Mullen & Jesse Vernon, both of Administrate, discussed "How to Improve Instructor Led Training (ILT) with eLearning" which made us realize we can significantly improve the materials we are providing you online. 

Ryan Cochrane's presentation on Creating Content That Converts to Leads
Based on the information we learned we have already made several improvements.  For all asbestos refresher courses the manual is online as many of you know already.  In addition, the review for all the asbestos refresher exams is now online, too.  We've created our first online course the respirator user course.  This course is required annually by anyone who uses a respirator.  This will allow you to take the respirator user course "At Your Convenience."  We plan on adding more courses and creating a separate landing page for the "Training At Your Convenience" service, that will include all the different ways we can train your employees, conveniently.  These improvements will help FEDTC continue to improve and offer more ways in meeting our goal of Keeping Your Employees Safe!

Thursday, May 04, 2017

PACNY's Environmental Conference - The NYSDOL Round Table - Day Three and So It Ends!

Day Three of the Professional Abatement Contractors of New York's (PACNY's) 21st Annual Environmental Conference started with Mr. Angelo Garcia, III's, of Future Environment Designs, Inc, presentation "Changes Are A Coming."  Our presentation can be found in our dropbox folder under conference presentations.  We discussed the many changes that will affect the abatement/restoration industry including the Environmental Protection Agency (EPA) (the new Director and Toxic Substance Control Act (TSCA)); Occupational Safety and Health Administration (OSHA) (the new Director, Silica, Beryllium, Safety & Health Programs, Recordkeeping & Reporting Requirements; & the increase in penalties); New York State Department of Labor (NYSDOL) proposed asbestos regulation changes to Industrial Code Rule 56; and changes coming from NYSDOL on the mold regulation (Article 32).  Our presentation, was videotaped and is attached below. 

The DiVal Safety Equipment Hospitality Suite caused a few late comers on Day Three
The next presenter was Mr. Jack Springston, of TRC Environmental, discussing "Mold Clearance Testing - The Good, The Bad and The Ugly."  Mr. Springston's presentation discussed all the different sampling methods for mold from spore traps (has a capture zone that collects air about the size of a golf ball), particle counters (not specific), Environmental Relative Moldiness Index (ERMI) (still under research) and culture plates (tried and true method).  In addition, he discussed the variability of data from certified laboratories and the interpretation of the that data.

Mr. Jack Springston, of TRC Environmental
After Mr. Springston's presentation, we took one last break in the Exhibit Hall to network with exhibitors Admar Construction Equipment & Supplies and Paradigm Environmental Services.  Our staff, Ms. Kimberly Granmoe, Ms. Sheryl Esposito, and I would like to thank all of you who visited our booth this year.
Our Booth, Sheryl Esposito, Kimberly Granmoe, Veronica & Angelo Garcia III
  The NYSDOL Round Table as usual is the highlight of the PACNY Environmental Conference.  Having NYSDOL regulators at the conference allows for questions and answers that can be timely and very useful.  The panel consisted of Dr. Eileen Franko, Director-Division of Safety and Health, Mr. Ed Smith, P.E., Engineering Services Unit, Mr. Kirk Fisher, Licensing & Certification Unit, and Mr. James Meachum, P.E., Asbestos Control Bureau.

Dr. Franko, Mr. Smith, Mr. Fisher, & Mr. Meachum on the Dais, Left to Right
This year's presentation they came armed with alot of information that was very useful.  They presented an update on the mold regulation from 2016 including the number of complaints (40), the number that was related to issues NYSDOL could address (16), while the remainder was outside of their jurisdiction (24).  The number of mold training courses held in 2016 were 31 assessor (1348 attendees), 26 remediation (1,668 attendees), & 32 worker courses (2,284 attendees).  There are 553 mold assessor companies (451 individuals); 526 mold remediation companies (526 individuals); 910 mold supervisors; and 1,941 mold workers.  Compare that with the 21,237 asbestos handling certificates, and 1,539 asbestos handler licenses (companies).  In 2016, NYSDOL conducted 2,457 asbestos inspections, and resolved 494 cases with 1,094 violations.  The top violations include:

Discussing Top Ten Violations
  • Asbestos Survey Required; 
  • Certification & Training Required; and 
  • Licensing Requirements and Procedures      
As many of you know, our biggest complaint about NYSDOL is that they don't do enough to go after companies that do asbestos without an asbestos survey, an asbestos license, and asbestos certified workers.  These three were the top three violations issued by NYSDOL, which means we say BRAVO!  NYSDOL keep up the good work!  It was interesting to us that one of the top ten violations was not having a manometer or working one (this piece of equipment literally can be purchased for about $30-50, the fine can be $5,000).  One of the biggest issues discussed was the need for a mold rule and at this point NYSDOL does not see the need for a rule.  After some questions and answers the conference ended with lunch.  This year's conference definitely seemed more technical than previous years.  As a trainer, this year's conference has provided significant information to bring back to our classes and provide to our attendees.  We look forward to seeing your next year, which Future Environment Designs will be celebrating 30 years in business.   

In the past week, NYSDOL announced the training requirements for mold refresher training.  All mold licensees will have to take a 4-hour refresher course to renew the licenses.  We are currently working on the submittal to become approved for these courses.  Below is the video from our presentation from the conference.


Friday, April 28, 2017

April 28th - Workers' Memorial Day!

Future Environment Designs (#FEDTC) joins with other safety organizations in marking today as Worker's Memorial Day!  Worker's Memorial Day is a day of remembrance for those who have died on the job.  This is also the day that the Occupational Safety and Health Administration (OSHA) was created in 1971.

Construction work on the ferry terminal on Lake Champlain

Before OSHA was created, an estimated 14,000 workers were killed on the job per year.  Though OSHA has been mostly successful in reducing the number job related deaths (job related deaths are down to 4,500 per year, however, there are over 50,000 who die from occupational diseases like asbestosis & silicosis) it is important to remember, there is still more we can do.  These deaths are preventable!  Now that Mr. R. Alexander Acosta has been confirmed as the new Labor Secretary, we will get a new OSHA director and find out the direction OSHA will take going forward.

Public events happen all over the country celebrating Worker's Memorial Day visit OSHA's website for more information.

Friday, February 03, 2017

Remember to POST Your OSHA 300A Form and File It Electronically!

On February 1, covered employers are required to post the Occupational Safety and Health Administration's (OSHA) 300A form.  The 300A form summarizes the information that is kept on the OSHA 300 log form.  Covered employers are required to prepare and maintain records of serious occupational injuries and illnesses that occur at a workplace on the OSHA 300 log form.  At the end of the year, covered employers are required to tally the totals on each column and enter the totals on the OSHA 300A form.  The information should be used by employers to evaluate safety in the workplace and determine ways to eliminate or reduce hazards in the workplace.  OSHA's 300A form is required to be posted until April 30, 2018 and must be retained for 5 years.  During the retention period you are required to update the log to add new information regarding the occupational injuries and illnesses recorded on it.  OSHA has brief tutorial to help you complete the forms.

300A Form Must Posted By February 1, 2

A final rule was issued and went into effect on January 1, 2017, requiring certain employers to electronically submit injury and illness data to OSHA.  OSHA has provided an online secure website (click here for the website) for submitting this information. You must submit this information by July 1, 2018.  If you meet the following criteria you DO NOT have to electronically submit your 300A information to OSHA:

  • The establishment's peak employment during the previous calendar year was 19 or fewer, regardless of the establishment's industry.
  • The establishment's industry is on this list, regardless of the size of establishment.
  • The establishment had a peak employment between 20 and 249 employees during previous calendar year and the establishment's industry is not on this list.
  • Establishments under jurisdiction of these State Plan states do not currently have to electronically submit to OSHA: California, Maryland, Minnesota, South Carolina, Utah, Washington, and Wyoming.

Logo for NAICS (North American Industry Classi...
Logo for NAICS (North American Industry Classification System), a system used by the U.S. Census Bureau and others. (Photo credit: Wikipedia)
A different rule which went into effect January 1, 2015, changed the list of employers partially exempt from the above recordkeeping requirements.  The revised list uses the new method of classification of industries, the North American Industry Classification System (NAICS).  The partially exempt industry list includes: architectural, engineering, & related services; legal services; & drinking places (really!!!), as examples.  For the full list of exempt industries visit OSHA's website on recordkeeping.  In addition, to new exempt industries there are industries that have to start keeping records.  These industries include:  automotive dealers, building material & supplies dealers, & activities related to real estate, for example.  Find the industries that have to start keeping records here.  

However, this does not exempt these industries or covered industries from reporting to OSHA, within 8 hours, any work-related fatality and reporting work-related in-patient hospitalizations, amputations, or losses of an eye within 24 hours.  This new reporting requirement was also part of the changes that went into effect on January 1, 2015.  Employers can report these events by telephone to the nearest OSHA Area office during normal business hours, or the 24-hour OSHA hotline 1-800-321-OSHA (6742), or electronically through a new tool which is being developed, look for it here.   Should you need any assistance with these requirements contact Future Environment Designs.

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