Tom Barnes
Compliance Specialists, Inc.
McCalla, Alabama
While there have not been many changes to the U.S. Occupational Safety and Health Administration (OSHA) requirements over the past year, it is important to review some of the recent changes and remind you of some upcoming compliance obligations.
OSHA 300 Recordkeeping & Reporting
Any facility that has the equivalent of 10 or more full-time employees (shop, admin, sales, temps, contract labor, etc.) must have posted their 2019 300A summary sheet by February 1, 2020, and keep it posted until April 30, 2020. This is required even if the facility had no recordable injuries. Assure the highest-ranking official in the facility has signed this summary sheet. Additionally, facilities with the equivalent of 20 or more full-time employees must electronically report their data to OSHA by March 1, 2020, for the 2019 year.
OSHA Reportable Injuries
Remember that the regulations have recently changed regarding when and how quickly a facility must report an injury or death to OSHA (24 hours and 8 hours respectfully). Reportable injuries include any admission to a hospital, amputation (including the loss of a fingertip even if no bone loss occurs), or loss of an eye. Certain conditions apply, so seek guidance if your facility, unfortunately, has to deal with one of these situations.
Silica & Beryllium Standards
If your facility is still sandblasting, you must determine if the media you are using contains silica. If so, OSHA has instituted very low exposure limits. Some steel and electrical components may contain this beryllium. The facility must assure no overexposure is occurring.
Quick Environmental Reminder
All shops with more than 10,000 pounds of any OSHA-hazardous material must file a Tier II report by March 1, 2020, for the 2019 year. This could include VPI or dip tank varnishes if the facility has over approximately 1,200 gallons onsite at any one time during the year. This could also apply to any facility utilizing electric forklifts or pallet jacks due to the sulfuric acid in the batteries and its lower reporting threshold of only 500 pounds.
Review these and other safety considerations with your team. For additional resources, reference the EASA Safety Module at go.easa.com/safety.
For specific OHSA requirements and regulations, visit osha.gov.
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