Safety Consulting & Training
On-Site and/or On-Line

Who updates your site's OSHA 300 Log of work-related injuries and illnesses?

I you are not the person, please forward a copy of this reminder to them now.

Most companies have production and/or safety leaders completing incident reports and presenting the information to someone in HR, and HR updates and maintains the OSHA 300 log (since they have secure offices).  All non-governmental companies that have 10 or more employees are required to maintain a OSHA 300 log each year.

January is the time to check the OSHA log (of work-related injuries & illnesses) for the previous year, then finalize and print a summary of the incidents/illnesses for the year on the OSHA 300A (annual summary form). The OSHA 300A form must be signed by the local President or GM, then posted in the workplace for employees to view. The 300A summary must be posted for all of February through all of March, but most companies keep it posted year-round. Note that companies are not allowed to post the OSHA 300 log itself (privacy issue), so only post the annual 300A summary form.

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At the American Society for Safety Professionals annual PDC meeting in DFW this April, one presentation really stood out for me. It was presented by John Goodpaster, CSP, who is the Director of EHS at Briggs Industrial Solutions. The company primarily services material handling equipment. Their business is primarily conducted by solo field workers. They have 1,000 employees who utilize 650 vehicles across 5 states in the South & Southwest. Briggs is an employee-owned company.

Briggs failed in nurturing an effective safety program for years and from 2015-2018 their safety record hit rock bottom, with lots of injuries - and 4 deaths. The company was also losing a stream of clients over their lack of safety performance. John shared a story of how the company was able to turn this situation around and build effective safety processes and an on-going safety culture in the company.

These are some of the steps the company took that led to this major turnaround: (more…)

Now that companies have posted the OSHA 300A summary of recordable work-related injuries and illnesses in the workplace, many companies now have two weeks to upload the data from their 300A forms to an OSHA website. Industrial companies with 20 or more employees must put their 300A data (for the year 2022) on the OSHA (ITA) site by March 2, 2023.

A change in the Process: 
Before we can post the OSHA 300A summary data on the OSHA ITA site (Injury Tracking Application) this year, we must (more…)

Companies with good safety programs that are in the realm of being OSHA-compliant, it’s time to turn on a powerful burner for improvement -Kaizen. Kaizen is striving to have everyone make small continual improvements in their jobs every day or week.
To encourage Kaizen, some companies create a simple form (think simplified A3) for employees. The form asks for the following:
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Sizzling heat has begun early this summer in Texas. This is evident from the salt lines on my black tee-shirt at the end of the day after helping clients with forklift observations. Most manufacturing companies have warehousing and shipping employees working in areas that are not air-conditioned. Some companies also perform production operations areas with no AC. We are blessed to not have to deal with working in the sun much.

In addition to the deaths of children in hot cars, and some August football practices that are reported on the news, we are still having 30-60 work-related heat illness deaths  each year in the U.S. Of course, there are way more cases of heat illness on-the-job where no-one dies happening as well.

It’s critical that each manufacturer put preventive measures to prevent heat illnesses in place now. I’ve listed some common and effective best practices below to get you started: (more…)

Large companies - This is your crunch time for EHS regulatory reporting!

Annual Waste Report (AWS) is due to TCEQ by March 1, 2022

This report is a summary of all the Hazardous and Class 1 wastes generated or shipped from the facility during the year. Companies normally have their waste hauler help them classify industrial wastes into regulatory waste streams categories. Some classifications are non-hazardous (which do not go on this report), an others may be deemed to be Hazardous or Class 1 wastes.

Tier 2 Report is due to TCEQ by March 1, 2022

Tier II is required for companies that have over 10,000 lb of a hazardous chemical on-site or 500 lb (and sometimes less) of extremely hazardous substances (EHS). The data from these reports is required  by the Emergency Planning and Community Right-to-Know Act (EPCRA) - Fire departments may access this during emergencies.

Uploading OSHA 300A Data for 2021 is due by March 2, 2022

Uploading 300A summary data on work-related injuries and illnesses during 2021 is required if your company performs industrial activities (such as manufacturing or printing) and had 20 or more employees during 2021. Companies in less hazardous industries don't need to report unless they have 250 or more employees.

Emissions Inventory Report is due to TCEQ by March 31, 2022

Companies with facilities that have significant air pollutants must prepare an annual Emissions Inventory Report (EI) showing monthly emissions for 2021.  The report summarizes the monthly VOCs used/emitted and the monthly HAPs (Hazardous Air Pollutants).

For more information on whether your company needs to make any or all of these filings click here.

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It’s time to complete your OSHA 300A Summary form of work-related injuries and illnesses for 2021. To complete the form, you will need your OSHA 300 log from 2021, the average number of employees during 2021, the business SIC or NAICS code, and the cumulative number of manhours worked by employees during 2021. The form needs to be signed by the owner or highest ranking company official working at the site, and posted for employees.

"The OSHA 300A Summary form for 2021 must be posted in the workplace for all of February, March and April"

Who needs to do this? If your company had 10 or more employees some time during the past year (and is not part of the government), you need to do this. (more…)