It's That Time! Remember to Post Your 300A Form and Electronically Report Your 2023 OSHA 300A Data to OSHA Using a New Login Procedure.

Every year at this time the Occupational Safety and Health Administration (OSHA) requires employers with 10 or more employees to post the OSHA 300A form from February 1 to April 30th, 2024.  Each year certain employers must electronically submit the OSHA 300A information directly to OSHA by March 2, 2024.  If you remember, the 300A form summarizes the injury and illness information that was kept on the OSHA 300 log form.  In addition, remember COVID-19 is a recordable and reportable illness if confirmed, work-related, and led to a loss of workdays (see below for a further discussion).  It would be recorded as a respiratory illness on the OSHA 300 form.  Because this is an illness, if an employee voluntarily requests that his name not be entered on the log, the employer must comply as specified under 29 CFR 1904.29(b)(7)(vi) and list it as a privacy case. 

OSHA 300A Form - Posting/Reporting Form

If you need assistance in completing the OSHA 300A form we did a webinar together with Keevily Spero & Whitelaw on completing the OSHA 300 & 300A form.  You can find the webinar here or watch it below.   Remember 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, 2024, 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 a brief tutorial to help you complete the forms.  

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.  Remember there is a new login procedure that became effective in October 2022.  The OSHA Injury Tracking Application (ITA) transitioned its login procedure to the public's one account access to government applications, Login.gov.  All current and new account holders must connect their ITA account to a Login.gov account with the same email address to access the application for the 2024 collection of Calendar Year 2023 Form 300A data.  You can watch the video on creating this account here.  You must submit this information by March 2, 2024, OSHA started collecting the information on January 2, 2024.  If you meet the following criteria you DO NOT have to electronically submit your 300A information to OSHA:

OSHA 300 Log Form

 

• 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 the establishment.
• The establishment had peak employment between 20 and 249 employees during the previous calendar year and the establishment's industry is not on this list.   Construction and remediation and other waste management services are both on this list, so if you are in those industries and meet the size requirements you must electronically report your OSHA 300A information.

SARS-CoV2

In addition, COVID-19 can be a reportable and a recordable illness if a worker is infected as a result of performing their work-related duties.  If your work-related confirmed COVID-19 case results in a hospitalization you must report it within 24 hours of exposure to COVID-19 at work or if it results in a fatality you must report it if it occurred within 30 days of exposure to COVID-19 at work (see OSHA coronavirus reporting for more information).  However, employers are only responsible for reporting or recording cases of COVID-19 if all of the following are true:

• The case is a confirmed case of COVID-19 (see Centers for Disease Control (CDC) information on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19);
• The case is work-related (as defined by 29 CFR 1904.5); and 
• The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7 (e.g., medical treatment beyond first aid, days away from work).

Employers should follow the OSHA guidance found in the Updated Interim Enforcement Response Plan for Coronavirus Disease 2019 (COVID-19).

Related Articles:

• OSHA Recordkeeping Webinar To Discuss Posting Requirements For 300A Form & Filing It Electronically! (futureenv.blogspot.com)
• It's That Time Again! Did You Remember to POST Your OSHA 300A Form! (futureenv.blogspot.com)
• Have You Remembered To Post The OSHA 300A Form? (futureenv.blogspot.com)

Happy New Year!!!! Here's to Hoping Your Holidays Were Merry and The New Year Will Be Fabtastic!

Happy New Year!  Future Environment Designs, Inc. wishes that all of you had a Merry Holidays and will have a Happy New Year!  This year was a little of a roller coaster ride for us starting with some ups at the beginning of the year, some downs at the middle of the year, and then back to some ups at the end!  We like that we ended on a high note and it looks to continue into the new year.  With us entering our 36th year in business we continue to adjust our offerings to meet your training requirements.

Christmas Tree at Rockefeller Center

Starting in September 2024, individuals who have Site Safety Training (SST) cards that will expire in September of 2025 must take a refresher course to renew the SST cards (which expire after five years),  That refresher course consists of a 4-hour fall prevention course and 4-hour supported scaffold user course that we are bundling together and will be part of our regular schedule.  To read more about these training requirements for New York City construction workers read our blog post "Final Phase of New York City Training Requirements for Construction Workers Arrives on March 1, 2021".  We have teamed with All New York City Training to offer the SST refresher course and the SST initial course at our facility in Syosset or their facility in Ridgewood.  We are also working with them to start offering the Environmental Protection Agency's Lead Renovator, Remodeler, and Painting (RRP) Course at both facilities, too. 

Bergdorf Goodman Window Display

We continue to offer training throughout Long Island (we have a mold worker and remediation/supervisor initial course coming up in East Hampton), Plattsburgh, Rochester (we are planning a mold worker/remediation/supervisor/assessor in the future), Queens, and Manhattan.  In other words, we will provide training and our other services at your convenience anywhere your workers are located.  We look forward to meeting your training requirements!  May your new year be happy and we look forward to seeing you in 2024!

Saks Window Display

Save the Date for PACNY's 2024 Environmental Conference February 15-16, 2024!

The Professional Abatement Contractors of New York (PACNY) have announced the dates for next year's Annual Environmental Conference.  The Environmental Conference will be held on February 15th & 16th, 2024 at the Turning Stone Resort and Casino in Verona, New York.  We are looking forward to attending the premier conference for the New York asbestos abatement industry.

Dale Chihuly's sculpture "Tree of Peace"

This year we have been part of the Conference Committee and it has been working hard (as in past years) to make this conference better than last year!  The Keynote Speaker of the conference this year is:

Michael Rubin

OSHA Attorney at Ogletree

He is a shareholder and OSHA lawyer at Ogletree Deakins, a premier labor and employment defense firm with offices worldwide. He has over 20 years of experience and focuses his practice exclusively on handling OSHA matters nationwide in federal and state-plan jurisdictions. He has handled OSHA matters in over 30 states, including construction and environmental contractors. He is also a Certified Safety Professional (CSP), demonstrating his knowledge and commitment to occupational safety and health.

"My mission is to help employers protect their workers, their businesses, and their reputations from OSHA inspections, citations, and enforcement actions. I guide employers through the OSHA inspection process, from the opening conference to the closing conference, and assert their rights and interests at every stage. I also contest and litigate OSHA citations, including through trial, and develop and audit safety programs and policies. I counsel employers on risk-management strategies and best practices to ensure compliance and prevent accidents. I am passionate about delivering effective and efficient OSHA defense solutions to my clients and staying updated on the latest OSHA developments and trends."

The conference will start at 8:00 AM on Thursday, February 15, 2024, with multiple sessions by Industry Leaders.  The Vendor Happy Hour will run from 4:00 PM - 7:00 PM that same day.  Friday will be the Keynote Speaker, and the New York State Department of Labor Roundtable with a question and answer session with the regulators.  Ending the conference with a networking lunch.  Aramsco, Dival Safety, Lovell Safety Management Co., LLC, Lozier Environmental Consulting, Inc., and Paradigm Environmental Services are some of the sponsors of this year's conference, to join these sponsors click here.  As usual, Future Environment Designs will be one of the sponsors of the conference and will have a table in the Exhibit Hall.  Reserve your spot at the conference here.  We hope to see you there!

Visit us at our Booth in the Exhibit Hall