OSHA is reminding employers that beginning today until April 30, 2008, they must post OSHA Form 300A, a summary of the total number of job-related injuries and illnesses that occurred during 2007.

“The OSHA 300 logs provide employers and employees a broad view of where injuries and illnesses are occurring at their worksites,” said Assistant Secretary of Labor for OSHA Edwin G. Foulke, Jr. “Identifying and posting injury and illness information provides employers and employees with useful information to help ensure a more safe and healthful workplace.”

The summary must include the total number of job-related injuries and illnesses that occurred in 2007 and were logged on the OSHA Form 300. To assist in calculating incidence rates, information about the annual average number of employees and total hours worked during the calendar year is also required. If a company recorded no injuries or illnesses in 2007, the employer must enter “zero” on the total line. The form must be signed and certified by a company executive and must be displayed in a common area where notices to employees are usually posted.

Employers with 10 or fewer employees and employers in certain industries are normally exempt from federal OSHA injury and illness recordkeeping and posting requirements. A complete list of exempt industries in the retail, services, finance, insurance, and real estate sectors is posted on the OSHA Web site, www.osha.gov.

Copies of OSHA Forms 300 and 300A are available in either Adobe PDF or Microsoft Excel Spreadsheet format on the OSHA Recordkeeping Web site at www.osha.gov/recordkeeping/index.html.

Happy New to all.  The Compliance Resource Center hopes you all had a wonderful and SAFE holiday season.   And now it is time to get back to work.
The beginning of a new year is a great time to do an annual assessment of your facility.  I always consider 4 parts to an assessment;

• Observation
• Conversation
• Compliance
• Evaluation 

OBSERVATION
I always to target 5 major areas that I am evaluating, during an assessment.  I start by looking and making notes with particular regards to these areas, but also notice if there are any other major concerns.  If time permits, I walk through the facility watching employee’s work and the equipment they are using.  I will often bring a camera and take pictures to support my findings.
CONVERSATION
Part of the assessment process should be talking with some of the employees.  This can give you a better understanding of employee’s opinion and understanding of the safety policies/procedures and their training.  Often the employees will tell a consultant some thing they would not tell their supervisor.
COMPLIANCE
My assessment is always based on compliance with OSHA regulations found in 49CFR.  If you are the safety person at your company, you should have a current 49CFR on your shelf.  This book is your bible for OSHA regulations and compliance.  Any assessment should follow these standards with regards to this manual.  Remember that OSHA standards are written for many industries.  You can also look at best practices to achieve a higher standard.  This is up to the individual company and location.
EVALUATION
After I stop, look and listen, I fill out an assessment tool that rates each area I observe.  This helps me keep my focus on facility and the good things they do and where they need improvement.  The final report is sent to my contact.  I follow-up in a few weeks to help the safety person develop a plan of action using the assessment made.  Finally, I check back every couple of months to see what progress is being made on the action plan.
So now you know some of the tricks of the trade; observe, converse, compliance and evaluate.  Have A SAFE NEW YEAR!

OSHA has announced a final rule on employer-paid personal protective equipment (PPE). Under the rule, all PPE, with a few exceptions, must be provided at no cost to the employee. OSHA anticipates that this rule will have substantial safety benefits that will result in more than 21,000 fewer occupational injuries per year. The rule was published in the Federal Register on November 15.

“Employees exposed to safety and health hazards may need to wear personal protective equipment to be protected from injury, illness, and death caused by exposure to those hazards,” said Assistant Secretary of Labor for OSHA Edwin G. Foulke Jr. “This final rule will clarify who is responsible for paying for PPE, which OSHA anticipates will lead to greater compliance and potential avoidance of thousands of workplace injuries each year.”

The final rule contains a few exceptions for ordinary safety-toed footwear, ordinary prescription safety eyewear, logging boots, and ordinary clothing and weather-related gear. The final rule also clarifies OSHA’s requirements regarding payment for employee-owned PPE and replacement PPE. While these clarifications have added several paragraphs to the regulatory text, the final rule provides employees no less protection than they would have received under the 1999 proposed standard.

 The rule also provides an enforcement deadline of six months from the date of publication to allow employers time to change their existing PPE payment policies to accommodate the final rule.

Proposed revisions that will change the requirements for facilities subject to the Spill Prevention, Control, and Countermeasure (SPCC) rule are expected within weeks. According to EPA, the revisions will tailor and streamline requirements to particular industry sectors and facilities subject to the rule.

EPA Administrator Stephen L. Johnson recently signed a proposed rule to amend the rule at 40 CFR part 112.

All SPCC-regulated facilities would be potentially affected by the proposed amendments, through which EPA intends to provide:

Clarity on the general secondary containment requirements,
Flexibility in the security requirements,
Flexibility in the use of industry standards to comply with integrity testing requirements,
Additional flexibility in meeting the facility diagram requirements, and
Clarification on the flexibility provided by the definition of “facility.”
Some of the other proposed changes include exemptions and a definition of loading/unloading rack.

Plan template allowed for small facilities
The changes would also streamline requirements and allow the use of an SPCC Plan template for a subset of qualified facilities known as “Tier 1” qualified facilities (i.e., with no individual oil storage container with a capacity greater than 5,000 U.S. gallons up to an aggregate of 10,000 gallons).

Until then, comply with old rule
Nothing in this proposed rule removes any regulatory requirement for owners or operators of facilities in operation before Aug. 16, 2002, to develop, implement, and maintain an SPCC plan in accordance with the SPCC regulations then in effect. These facilities are required to maintain their plans until the applicable date for revising and implementing plans under the new amendments.

Public comments on the proposed changes will be accepted for 60 days following publication in the Federal Register, which is expected within two weeks. Information about the SPCC rule proposed amendments is available at www.epa.gov/oilspill/spcc_oct07.htm

According to 29 CFR 1910.164(c), it is the employer’s responsibility to maintain all fire-detection systems in an operable condition, except during maintenance and repair work.  You must ensure that these systems are tested and adjusted as often as necessary to maintain reliability and operating condition.

The frequency of the tests and cleaning cycle must be determined in part by facility conditions, such as dust, as well as manufacturer recommendations.  Conditions such as the amount of dust, dirt, or other particulates may vary widely from one facility to another and therefore vary the maintenance cycle.
Factory-calibrated detectors do not need to be adjusted after installation, unless recommended by the manufacturer or service representative. However, trained personnel knowledgeable in the operation and function of the system must perform testing, cleaning, and maintenance of fire-detection systems.

You must also ensure that pneumatic and hydraulic-operated detection systems installed after Jan. 1, 1981, are equipped with supervised systems.