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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…)

(Update note: Supreme Court Says No to OSHA Employers Vaccine-or-Test Mandate 1/13/2022, but leaves mandate in place for healthcare workers.)

WOW! OSHA ruling is Issued on Thursday, then a Circuit Court of Appeals grants an emergency stay on the ruling Saturday….  And so the roller coaster ride begins.

You may recall that President Biden announced on September 9 that OSHA was being tasked to create new regulation requiring large employers to keep a roster of employee vaccination status and implement specific COVID protections,  and that gives employers the green-light to mandate COVID vaccination for their employees, if they choose to. OSHA shared a plan with the legislature on October 12, and on November 4, the legislation was enacted.

COVID Vaccination Card

This new regulation is called “Emergency Temporary Standard (ETS) on Protecting Employees from COVID-19”. The media has begun calling it the “Vax or Test Rule”. The rule has language that limits states and municipalities from trying to ban employers from requiring vaccinations, face coverings, or COVID testing. The COVID ETS is being enacted for a 6 month period, with plans to re-evaluate it at the end of that period (When there is no longer a grave danger from COVID for workers, the ruling will be discontinued).

Prior to the ETS being issued, 27 states had announced plans to challenge the COVID ETS, and on Saturday (November 6) the 5^th Circuit Court of Appeals granted an emergency stay of the newly enacted OSHA Emergency Temporary Standard. The government is expected to issue a response to this legal challenge on Monday (November 7). The Labor Department says they are confident in having legal authority to issue the ETS rule, and OSHA says they are fully prepared to defend the standard in court. Therefore, we should expect legal tussling over the new OSHA rule to be in our nightly news this week.

What does the Standard Require?

The regulation requires that employers with 100 or more employees (companywide) keep a roster on COVID vaccination status of their employees. They can either mandate that all employees be vaccinated, or they can allow any choosing to remain not-fully-vaccinated to go take a COVID test weekly (reporting any positive tests quickly, and staying out of work if diagnosed with COVID). In addition those choosing to remain unvaccinated will be required to wear a face-covering at all times when indoors at work or in a vehicle with another person for work. (more…)

Most all industrial sites and manufacturing companies are required to have a stormwater filing. Printing companies are included in this group. Stormwater filings must be updated every 5 years, and all companies have the same due date in Texas. The Texas Commission for Environmental Quality (TCEQ) has posted notice on their website that stormwater renewals are due by November 12, 2021. Your company likely received a notice from TCEQ as well.

Each company will need to have a company profile account with TCEQ. You can check your profile by going to www.tceq.texas.gov and scrolling down to "Central Registry" and putting in your company name.

One person at your company likely already has a STEERs account with TCEQ, but if that person has left the company, you will need to contact them to set up a new authorized person to make  filings with the on-line e-permitting system.

Since most don't have paper scraps or chemicals outside, most printing companies can file a Stormwater No Exposure Certification (NEC). There will be a fee of around $100 due. The filing is fairly simple with eleven basic questions. The hardest part of the form is (more…)

OSHA is really getting a boost from the Biden administration.  The OSHA budget was increased from $591 million in 2021 to $665 in 2022. A good portion of the funding will be used to significantly increase the number of safety & health compliance officers.

OSHA had a record low number of compliance officers in 2019, but they are slated to have way more in 2022. OSHA’s manning for site audits will be 32% higher in 2022 than it was in 2019.

OSHA conducted 33,000 inspections in 2019. Based on the increase in workforce, we are likely to have over 43,000 inspections in 2022. What does this mean for manufacturing companies?

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