OSHA Extends Comment Period of Proposed Recordkeeping Changes (TRN Update)

safety-blog-OHSA-temp-TRN-JAN-2014

From Cliff Gerbick, CSP (The Reserves Network Director of Safety)

The Occupational Safety and Health Administration (OSHA) has extended the open comment period for the proposed changes to the current Recordkeeping Standard, 29 CFR 1904.  The extension was in response to a request from the National Association of Home Builders.

Under current regulations, most employers are required to maintain the OSHA 300 Log.  While employers must maintain the log, they are not required to submit information from the log to OSHA or any other agency at years end unless specifically directed to by OSHA or another government agency, such as the Bureau of Labor Statistics.

The proposed rule will require employees to electronically submit OSHA 300 data to OSHA on an annual basis. The period to comment on this proposed rule change has been extended until March 8, 2014.

Interested parties can submit their comments via mail, FAX or electronically through the following link: (www.regulations.gov)

For more information, please visit: (www.OSHA.gov)

Cliff Gerbick TRN Staffing SafetyCliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@TRNstaffing.com. Visit the The Reserves Network’s website at www.TRNstaffing.com.

OSHA Releases Resources to Protect Workers from Chemical Hazards (TRN Update)

OSHA Alert Safety

From Cliff Gerbick, CSP (The Reserves Network Director of Safety)

The Occupational Safety and Health Administration (OSHA) has released two online resources to help workers understand and identify hazardous chemicals in the workplace.

While OSHA has identified many dangerous chemicals that are present in workplaces, it concedes that their “…exposure standards are out-of-date and inadequately protective for the small number of chemicals that are regulated in the workplace.”

In order to help eliminate the knowledge gap, OSHA’s first resource is designed to help employers replace harmful chemicals with less harmful substances.  The toolkit, as OSHA describes it, “…walks employers and workers step-by-step through information, methods, tools and guidance to either eliminate hazardous chemicals or make informed substitution decisions in the workplace by finding a safer chemical, material, product or process.”

The second resource allows employers and workers to compare current OSHA Permissible Exposure Limits (PEL’s) to other consensus exposure limits. This has been provided so employers and workers will voluntarily adopt the newer, more effective exposure limits.  Since many PEL’s were adopted over 30 years ago, it is imperative for employers to determine what levels are best practices to ensure they are protecting their employees.

For the full OSHA Press Release and links to the two online resources, please visit: (LINK: OSHA.gov)

Cliff Gerbick TRN Staffing SafetyCliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@TRNstaffing.com. Visit the The Reserves Network’s website at www.TRNstaffing.com.

OSHA Revises Hazard Communication Standard – One Year Later (TRN Update)

safety-blog-OHSA-HAZARDCOMM2013

From Cliff Gerbick, CSP (The Reserves Network Director of Safety)

It has been approximately one year since the  Occupational Safety and Health Administration (OSHA) revised the Hazard Communication Standard (29 CFR 1910.1200) to align it with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  Now that employers have had an opportunity to familiarize themselves with the changes they should be well prepared for the upcoming requirements that are going into effect in 2013.

By December 1, 2013, all employers must train all of their employees on the new requirements of 29 CFR 1910.1200.  The main items in which employees must be trained are the Safety Data Sheet (SDS) format and the pictograms that OSHA will be utilizing to identify hazards.  Additional items are required further down the line but December 1, 2013 is the first in a series of deadlines that both manufacturers and employers must meet to be in compliance with the new standard.

For further reading on 29 CFR 1910.1200 and GHS, please visit: (LINK: osha.gov)

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@TRNstaffing.com.

Visit the The Reserves Network’s website at www.TRNstaffing.com.

*Join us on the below Networks for a wide variety of HR Tips and Trends, Industry Articles, Best Practices, Safety Management, OSHA Alerts, Legal Topics, Blogs, News Releases, Videos and more…

OSHA Launches Initiative to Protect Temporary Workers (TRN Update)

OSHA Temporary Safety

From Cliff Gerbick, CSP (The Reserves Network Director of Safety)

Each year towards the end of April, the Occupational Safety and Health Administration (OSHA) holds a remembrance ceremony for Workers Memorial Day.  During this time, OSHA remembers those workers who lost their lives on the job and recommits to making worksites safer.

However, this year, in addition to the remembrance service, OSHA introduced an initiative to protect temporary workers in the workforce.  OSHA sent a memo to all regional administrators who assess field operations directing field inspectors “to assess whether employers who use temporary workers are complying with their responsibilities under the Occupational Safety and Health Act.”

This memo comes on the heels of a recently published Standard Interpretation that clarified who in the temporary agency/host employer is responsible for what aspects of required safety and health education.  That standard interpretation can be found at by (CLICKING HERE: osha.gov)

OSHA has long held that temporary agencies are required to provide general safety and health training while host employers are required to provide site specific training on potential hazards and risks.  Those responsibilities are not changing; OSHA is simply putting and emphasis on ensuring that both parties are fulfilling their obligations under the OSH Act.

Compliance Safety and Health Offices (CSHO’s), commonly referred to as OSHA Inspectors, are instructed to identify employers that utilize temporary workers and “assess whether temporary workers received required training in a language and vocabulary they could understand.”

Additionally, OSHA has begun working with the American Staffing Association (ASA), the largest trade association representing the U.S. staffing industry, in order to better promote best practices and provide education to both staffing agencies and host employees on OSHA requirements and employee training.

For more information on the OSHA Initiative, please visit (LINK: osha.gov)

For more information on the American Staffing Associating, please visit (LINK: americanstaffing.net)

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@TRNstaffing.com.

Visit the The Reserves Network’s website at www.TRNstaffing.com.

*Join us on the below Networks for a wide variety of HR Tips and Trends, Industry Articles, Best Practices, Safety Management, OSHA Alerts, Legal Topics, Blogs, News Releases, Videos and more…

OSHA and the Affordable Healthcare Act (TRN Update)

Affordable Healthcare Act, OSHA, Healthcare, Healthcare 2013, TRN Staffing, The Reserves Network

From Cliff Gerbick, CSP (The Reserves Network Director of Safety)

With the Affordable Healthcare Act (ACA) coming into focus as provisions of the act start to become law, the Occupational Safety and Health Administration has published an interim final rule in the Federal Register that governs whistleblower complaints filed under Section 1558 of the Affordable Care Act.

Title I includes a range of insurance company accountability policies, such as the prohibition of lifetime limits on coverage and exclusions due to pre-existing conditions.  If an employee registers a complaint against their employer for not providing the required provisions that employee cannot be retaliated against.  If an employee feels they have been retaliated against for voicing the complaint, they may file a complaint with OSHA.

The ACA tasks the Department of Labor with conducting investigations and making determinations based on the investigative findings.  Both of these tasks are driven by OSHA.  OSHA’s interim final rule establishes the procedures and time frames for the filing and handling of such complaints – including investigations by OSHA, appeals of OSHA determinations to an administrative law judge for a hearing, review of such decisions by the Administrative Review Board and judicial review of the secretary’s final decision.

The interim final rule can be viewed by (CLICKING HERE – PDF FILE)

Comments, which will be accepted for 60 days, may be submitted electronically via the federal e-rulemaking portal by (CLICKING HERE) or by mail or fax.

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@TRNstaffing.com.

Visit the The Reserves Network’s website at www.TRNstaffing.com.

*Join us on these Networks for a wide variety of HR Tips and Trends, Industry Articles, Best Practices, Safety Management, OSHA Alerts, Legal Topics, Blogs, News Releases, Videos and more…

OSHA’s Top 10 Violations of Fiscal Year 2012 (TRN Safety Alert)

From Cliff Gerbick, CSP (The Reserves Network Director of Safety)

OSHA has released it annual list of the top 10 workplace violations for fiscal year 2012 (October 1, 2011 – September 30, 2012). Annually the list contains mostly the same standards, only switching positions, and this year is no exception. As the political landscape remains static, OSHA will continue to focus on increased planned inspections and higher penalty amounts. OSHA has repeatedly stated that they are an enforcement agency so one can only assume the number of inspections and citations will continue to rise.

With that said, here are OSHA’s Top 10 Most Cited Standards for FY 2012:

1. Fall Protection – General Requirements
Standard 1926.501
Total Violations: 7,250

2. Hazard Communication
Standard 1910.1200
Total Violations:  4,696

3. Scaffolding – General Requirements
Standard 1926.451
Total Violations:  3,814

4. Respiratory Protection
Standard 1910.134
Total Violations:  2,371

5. Ladders
Standard 1926.1053
Total Violations:  2,310

6. Machine Guarding – General Requirements
Standard 1910.212
Total Violations:  2,097

7. Powered Industrial Trucks
Standard 1910.178
Total Violations:  1,993

8. Electrical – Wiring Methods
Standard 1910.305
Total Violations:  1,744

9. Lockout/Tagout
Standard 1910.147
Total Violations:  1,572

10. Electrical – General Requirements
Standard 1910.303
Total Violations:  1,332

For more information, visit the National Safety Council website by (Clicking Here!)

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@trnstaffing.com.

Visit the The Reserves Network’s website at www.TRNstaffing.com.

*Join us on these Networks for a wide variety of HR Tips and Trends, Industry Articles, Best Practices, Safety Management, OSHA Alerts, Legal Topics, Blogs, News Releases, Videos and more…

OSHA Issues FactSheet for Cranes and Derricks Final Rule (TRN Safety Alert)

From Cliff Gerbick, ASP (The Reserves Network Director of Safety)

The Occupational Safety and Health Administration (OSHA) has released a FactSheet to help employers understand the recently released final rule for the safe operation of Cranes and Derricks. The new standard was released in 2010 and it updated a severely outdated standard that had not been changed since its initial issuance in 1971. OSHA estimates that the new standard will prevent 22 fatalities and 175 non-fatal injuries in the workplace.

The FactSheet provides quick reference to the changes in the standard and outlines the requirements that employees need to take to ensure compliance with all aspects of the standard.

For more information regarding the Cranes and Derricks Standard: (Click Here!)

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@trnstaffing.com.

OSHA Issues Memorandum on Employer Incentive Programs (TRN Safety Alert)

From Cliff Gerbick, ASP (The Reserves Network Director of Safety)

The Occupational Safety and Health Administration has issued a public memorandum outlining potential violations based on employer safety incentive and disincentive policies and practices.

Meant for internal staff, the memo outlines example safety incentive and disincentive programs and how they can potentially violated Section 11(c) of the OSH Act. Section 11(c) prohibits employers from discriminating against an employee because the employee reports an injury or illness.

The memo is intended to give compliance officers (AKA OSHA Inspectors) and whistleblower investigative staff guidance regarding the different types of incentive programs used in the workplace, and how they can potentially discourage employees from reporting injuries.

The full memo, including four different scenarios can be found by (Clicking Here!)

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@trnstaffing.com.

“OSHA Target List” Released (TRN Safety Alert)

From Cliff Gerbick, ASP (The Reserves Network Director of Safety)

The Occupational Safety and Health Administration (OSHA) has released its annual list of employers with the highest occupational injury and illness rates, commonly know as the “OSHA Target List”. This year, OSHA has identified approximately 14,900 workplaces with higher than average incident rates. The employers are those whose establishments are covered by Federal OSHA and reported the highest “Days Away from work, Restricted work or job Transfer injury and illness” (DART) rate to OSHA in a survey of 2010 injury and illness data. For every 100 full-time workers, the 14,900 employers had 2.0 or more injuries or illnesses which resulted in days away from work, restricted work or job transfer. The national average is 1.8.

All employers identified were sent a letter that encourages employers to consider hiring an outside safety and health consultant, talking with their insurance carrier, or contacting the workers’ compensation agency in their state for advice.

A template of the letter sent to notify employers and the entire list of 14,900 employers can be found at the following link: (Click Here for OSHA Letter)

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@trnstaffing.com.

OSHA Revises Hazard Communication Standard (TRN Safety Alert)

From Cliff Gerbick, ASP (The Reserves Network Director of Safety)

The Occupational Safety and Health Administration (OSHA) has revised its Hazard Communication Standard (29 CFR 1910.1200) to align it with the United Nations global chemical labeling system. In a process that began decades ago, OSHA has at last published the final rule that will update the current standard to mirror the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

The updates to the standard will provide chemical manufacturers a proscribed format for identifying the hazards associated with chemicals. Currently, OSHA requires all employers to maintain Material Safety Data Sheets (MSDS) for all hazardous chemicals in the workplace.

While this requirement will not change, the format in which MSDS are organized will be standardized and must contain the information in the following order:

Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-Aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical properties
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information
Section 13. Disposal considerations
Section 14. Transport information
Section 15. Regulatory information
Section 16. Other information, including date of preparation or last revision

In addition, OSHA is phasing out the use of MSDS and will now use the term Safety Data Sheet (SDS).

The other big change to the current standard is the standardized use of pictograms to identify the hazards associated with chemicals. There are nine pictograms used in the GHS and OSHA will adopt eight of them.  The ninth pictogram is in regards to environmental effects and since OSHA does not have jurisdiction overall environmental issues, it will not be used. The pictograms are:

HCS Pictograms and Hazards

Health Hazard

Flame

Exclamation Mark

• Carcinogen
• Mutagenicity
• Reproductive Toxicity
• Respiratory Sensitizer
• Target Organ Toxicity
• Aspiration Toxicity
• Flammables
• Pyrophorics
• Self-Heating
• Emits Flammable Gas
• Self-Reactives
• Organic Peroxides
• Irritant (skin and eye)
• Skin Sensitizer
• Acute Toxicity (harmful)
• Narcotic Effects
• Respiratory Tract Irritant
• Hazardous to Ozone Layer
(Non Mandatory)

Gas Cylinder

Corrosion

Exploding Bomb

• Gases under Pressure • Skin Corrosion/ burns
• Eye Damage
• Corrosive to Metals
• Explosives
• Self-Reactives
• Organic Peroxides

Flame over Circle

Environment
(Non Mandatory)

Skull and Crossbones

• Oxidizers • Aquatic Toxicity • Acute Toxicity (fatal or toxic)

OSHA has developed a timeline for all employers to be in compliance with the standard, culminating in 2016. The first deadline in the timeline, December 1, 2013, requires employers to train all employees on the new label elements (pictograms) and SDS format.

Other deadlines are as follows:

Effective Completion Date

Requirement(s)

Who

December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format. Employers
June 1, 2015

December 1, 2015

Compliance with all modified provisions of this final rule, except:
The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label.
Chemical manufacturers, importers, distributors and employers
June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers
Transition period to the Effective Completion Dates noted above. May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both. Chemical manufacturers, importers, distributors and employers

OSHA estimates the revised standard will prevent an estimated 585 injuries and illnesses annually. It will reduce trade barriers and result in estimated annualized benefits in productivity improvements for American businesses that regularly handle, store and use hazardous chemicals, as well as cost savings of $32.2 million for American businesses that periodically update safety data sheets and labels for chemicals covered under the standard.

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@trnstaffing.com.

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