With fall officially underway and Halloween right around the corner, it can only mean one thing: sweets, sweets, and more sweets. However, I would ask that you put down whatever candy your kids have rejected so you can start reflecting on 2019 and planning for 2020.  And as all successful businesses know, it is important to not only include a sales or production evaluation but an evaluation of your safety program. To help, here is a 2020 Occupational Safety and Health Administration (OSHA) update to move you in the right direction.

Other Construction Equipment & Tasks that Could Generate Silica

OSHA is currently requesting information and comments on Table 1 of the agency’s engineering and work practice control methods. This table was developed as a means for construction employers to limit exposure to silica for listed equipment and tasks. Those in the construction industry are likely very familiar with this table. What OSHA is now looking for is information about other construction equipment and tasks that generate silica that they may want to consider adding to Table 1 along with ideas on the associated engineering and work practice control methods associated with the equipment and tasks.

If new equipment and tasks can be added or new engineering/work practice controls, employers will have more options when it comes to complying with the respirable silica standard without jeopardizing employee safety.

Comments are also being sought on whether to broaden the circumstances under which general industry and maritime employers would be allowed to utilize Table 1 as a means of compliance. The current requirements can be found in paragraph (a)(3) of the respirable crystalline silica standard for general industry.

For details on requirements, exposure assessment and developing an exposure control plan, watch this webinar: “OSHA’s New Silica Standard: What Contractors Need to Know.”

Comments Must be Submitted by October 14, 2019

Comments on both items must be submitted by October 14, 2019 and may be submitted electronically at the Federal e-Rulemaking Portal, or by fax or mail. See the Federal Register notice for submission details.

New OSHA Webpage for Tracking Workplace Conditions

OSHA has a new web page titled Using Leading Indicators to Improve Safety and Health Outcomes that shows how businesses can improve safety and health programs by tracking workplace conditions and events to prevent injuries or illnesses before they occur. This is better known as leading indicators.

Many employers are familiar with lagging indicators which measure the occurrence and frequency of past events. These may be helpful in identifying failures in an area of your safety program or to the existence of a hazard; however, they do not necessarily help determine if your safety activities are truly preventing incidents. Strong safety and health programs use leading indicators to promote change and lagging indicators to measure effectiveness.

This site can be used regardless of what stage you may be at in your safety and health program and can improve both safety and organizational performance through prevention of injuries/illnesses, reduced costs of incidents, improved productivity, higher level of safety performance, and increased employee participation in the safety program.

Whistleblower Protection Program Website Undergoes Redesign

Speaking of websites, OSHA recently redesigned the Whistleblower Protection Program’s website. The new design highlights important information for employers and employees on more than 20 statutes enforced by the agency. Video can be found on the homepage regarding covered industries, and improved navigational structure allows you to easily access information on protected activities, filing deadlines and resources.

Submit Your 2018 OSHA Form 300A

Finally, OSHA is reminding employers, if you have not done so already, to electronically submit your 2018 OSHA Form 300A (Summary of Work-Related Injuries and Illnesses.) These were due on March 2, 2019 but OSHA will still accept the late reports. Establishments with 250 or more employees that are required to keep OSHA injury and illness records and establishments with 20 to 249 employees in certain industries are required to submit these forms. View the list of designated industries here.

With that said, the deadline for electronically reporting the 300A for calendar year 2019 is March 2, 2020. You can start submitting the form on January 2, 2020.

Keep in mind that OSHA no longer requires those employers with 250 or more employees to electronically submit information for the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) or OSHA Form 301 (Injury and Illness Incident Report) as was required when the new electronic reporting requirements were first introduced in 2016. However, the requirement to keep and maintain OSHA Forms 300, 300A, and 301 for five years has not changed.

For those of you in state-government and local-government establishments in State Plans states, you are also required to electronically submit injury and illness information. You can contact your State Plan office for further information.

Minnesota OSHA (MNOSHA) Expands List of Industries

It should be noted that Minnesota OSHA (MNOSHA) expanded the list of industries federal OSHA requires to electronically submit their OSHA 300A form to include all NAICS codes. All employer establishments with more than 20 employees are required to submit their OSHA 300A Summary of Work-related Injuries and Illnesses data via federal OSHA’s Injury Tracking
Application (ITA).

For questions about submission requirements, you can complete the Help Request Form. Sign up for OSHA’s e-newsletter to stay current with OSHA updates and proposed changes.

Society Insurance is committed to promoting workplace safety and helping our policyholders prevent workplace accidents. Contact our risk management department and let a risk control representative assist you with the development of an effective safety program. All Society Insurance policyholders are eligible for free safety training sessions throughout the year. View our Risk Control resources here.