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OSHA 300 Log

Fire Ratings Change for Some Plastic Pallet Users

Osha Issues Final Rule On Recording Hearing Loss

OSHA Announces New Ergo Plan

OSHA Revises Recordkeeping Regulations

 

 

OSHA 300

Do you know where your employer's OSHA 300 log summary is? You should soon, if your workplace has more than 10 employees and you are not in a low-hazard industry. You can expect to know where it is because your employer will be required to post the log on February 1, and leave it on the bulletin board until April 30. The log is a summary of all work-related injuries and illnesses that occurred in your workplace
during 2002.

This will be the first time you have seen the OSHA 300 log posted, because it has replaced the similar OSHA 200 log as a result of OSHA’s extensive revision of its recordkeeping egulations. The OSHA 300 log contains more information than the old OSHA 200 log.

By law, the information in the log is supposed to be available for inspection by employees all year long, but the employer is only required to display it in public for three months.

For more information about the OSHA 300 log and OSHA regulations concerning the recording of work-related injuries and illnesses, including a list of industries that exempt from the annual posting requirement, visit http://www.osha.gov/recordkeeping/index.html.



Warehouse News

Fire Ratings Change for Some Plastic Pallet Users

On July 19, the National Fire Protection Association (NFPA) plans to issue its final document updating changes to the NFPA 13 standards affecting the fire ratings of certain plastic pallets used in warehouses. These standards are the basis for most state fire code laws.

Until now, facilities that stored loads on plastic pallets require a one-class upgrade in fire protection above that needed for storage of loads on wooden pallets. The new rules require a two-class upgrade in fire protection for warehouses that store reinforced polypropylene and polyethylene plastic pallets. Reinforced pallets hold their structure and integrity longer which allows air gaps to remain longer within the pallet, which in turn fuels the flames and creates a more intense fire. Unreinforced plastic pallets continue to require a one-class upgrade over wooden pallets.
The change was made because unreinforced plastic pallets melt fairly easily in a fire and ofter smother flames, while reinforced plastic pallets are considered to be a higher risk.

Some exceptions to the new standard are:

  • Facilities that have sprinkler systems with an Early Suppression Fast Response (ESFR) 17 rating or higher
  • Pallets for which there is specific testing data, such as that collected by UL that proves the pallets qualify for a lower rating.

 

For more information, visit www.nfpa.org.

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Osha Issues Final Rule On Recording Hearing Loss
Agency Will Seek Comments on Delaying MSD Provisions

The Occupational Safety and Health Administration issued a final rule on July 1, 2002, that revises the criteria for recording work-related hearing loss. The agency will also seek comments on a proposal involving the recording of MSDs on OSHA's injury and illness logs.

Beginning Jan. 1, 2003, employers will be required to record work-related hearing loss cases when an employee's hearing test shows a marked decrease in overall hearing. Employers can make adjustments for hearing loss caused by aging, seek the advice of a physician or licensed health care professional to determine if the loss is work-related, and perform additional hearing tests to verify the persistence of the hearing loss.

Under the new rule, the criteria will record 10-decibel shifts from the employee's initial hearing test when they also result in an overall hearing level of 25 decibels. The old criteria recorded 25-decibel shifts.

The agency is also seeking public comments on a proposed one-year delay of the recordkeeping rule's definition of musculoskeletal disorders (MSDs), and whether to include MSDs and hearing loss columns on the OSHA Form 300 Log of Occupational Injuries and Illnesses.

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OSHA announces new ergo plan: Guidelines favored over rules


OSHA today unveiled its long-delayed plan for attacking ergonomics-related
problems in the workplace, describing a four-prong strategy:

1. Guidelines — OSHA will start work immediately on voluntary guidelines
targeted at specific industries and specific tasks. Officials will study
injury and illness rates for various industries, including construction,
agriculture, and maritime, to decide which ones could benefit from such
guidelines. You can expect to see these documents begin to come out of the
agency by the end of the year.

Guidelines will help employers spot ergo hazards and set up feasible means of
controlling them. Targeted ergo guidelines were written for the meatpacking
industry by OSHA in
1990.

Failure to implement these new guidelines will not be interpreted by OSHA as
a violation of an employer’s general duty to provide a workplace free from
serious hazards.

Employers with ergo hazards who effectively put these guidelines into
practice or use other effective measures will likely escape penalties issued
using the General Duty clause of the OSH Act.

OSHA says it will not focus its enforcement efforts on employers who have
implemented effective ergo programs or who are making good-faith efforts to
reduce ergo hazards.

2. Enforcement — Bad actors beware: OSHA plans to go after industries with
serious ergonomics problems with special ergo inspection teams that will work
closely with Labor Department attorneys and experts to prosecute violators
under the General Duty Clause.

The General Duty clause of the 1970 Occupational Safety and Health Act
broadly requires employers to provide workplaces safe from recognized serious
hazards, including ergo hazards. OSHA and Labor Department attorneys have
successfully used this general mandate to penalize employers for serious ergo
problems in cases involving a nursing home, Beverly Enterprises, and a food
processor, Pepperidge Farm.

If General Duty clause citations are not warranted following an inspection,
OSHA might issue hazard alert letters to employers with less serious ergo
problems. OSHA will conduct follow-up inspections or investigations within 12
months of certain employers who receive these ergonomic hazard alert letters.

OSHA will conduct specialized training for designated personnel on ergo
hazards and methods of controlling them, and plans to appoint ten regional
coordinators to be involved in enforcement and outreach.

A National Emphasis Program will focus on the nursing home industry to guide
inspections of nursing homes, and to specifically zero in on ergonomic
hazards related to patient lifting.

3. Assistance — OSHA will use a special Web site
(www.osha.gov/ergonomics/index.html) and training grants to give employers
tools to identify and control ergo hazards. A special effort will be aimed at
Hispanics and immigrant workers, since many work in industries with high
ergonomic-related hazard rates, and press investigations in the past year
have criticized OSHA for ignoring these workers.

Specific info (charts, illustrations, photos, hazards and solutions,
references) can be found on OSHA’s site for these jobs:

  • Baggage Handling
  • Beverage Delivery
  • Computer Workstations
  • Grocery Warehousing
  • Hospital
  • Nursing Home
  • Poultry Processing
  • Sewing [English]
  • Sewing [Spanish]

4. Research — OSHA is forming a national advisory committee to identify areas
where more ergonomics research is needed.

Why no standard?
OSHA’s new plan comes more than a year after Congress torpedoed an ergo rule
released in the waning days of the Clinton administration. Agency officials
contend there are numerous reasons why guidelines are preferable to doing a
rule at this time:

  • There are a variety of different hazards and combinations of different
    hazards to be addressed;

  • Exposure to the hazards is not readily measured in some cases;

  • The exposure-response relationship is not well understood;

  • Cost and feasibility of abatement measures may be uncertain and may be very
    high in some cases; and

  • It is very difficult, except in the most general terms, to prescribe
    remedies for abating such hazards in a single rule.

Will the agency ever again consider the idea of setting mandatory rules?
Never say never in Washington.

Officials say they will regularly review annual injury and illness rates for
musculoskeletal disorders and make decisions based on the best-available
information about what approach to take to protect workers from MSDs. OSHA
believes that guidelines currently offer the best method of continuing to
bring down injury and illness rates for MSDs.

On a national basis, rates for carpal tunnel injuries with days away from
work have gone down by 39 percent from 1992 to 1999. For the same time
period, rates for strains and sprains with days away from work have also gone
down by 39 percent, and rates for back injuries with days away from work have
gone down by 45 percent.

"Thousands of employers are already working to reduce ergonomic risks without
government mandates. We want to work with them to continuously improve
workplace safety and health. We will go after the bad actors who refuse to
take care of their workers," said OSHA chief John Henshaw.

"This plan is a major improvement over the rejected old rule because it will
prevent ergonomics injuries before they occur and reach a much larger number
of at-risk workers,"
--Labor Secretary Elaine Chao said in a prepared statement.

Not good enough
Union leaders and liberal Democrats wasted no time condemning what one labor
safety official called "largely a non-existent plan that raises more
questions than it answers." Other critics labeled it hollow and worthless.

"The administration handed a win to big business at the expense of millions
of average workers who risk workplace injuries every single day," said Sen.
Edward M. Kennedy, D-Mass., chairman of the Senate Health, Education, Labor
and Pensions Committee.

Watch for supporters of a federal ergo standard to take their case to
Congress, and also try to pass state ergo laws to stir up demand for a
consensus national standard.

Labor Secretary Chao is scheduled to explain OSHA’s new ergo plan to Sen.
Kennedy’s senate committee on April 18th.

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OSHA Revises Recordkeeping Regulations

7/13/2001—Secretary of Labor Elaine L. Chao announced June 29, 2001, that an
Occupational Safety and Health Administration (OSHA) rule on recordkeeping
would largely go into effect as scheduled on January 1, 2002. According to
Chao, the rule increases employee involvement, creates simpler forms in plain
language, and allows employers to use computers to meet OSHA regulatory
requirements.

The Department of Labor (DOL) is proposing a delay of a year before
implementing the criteria for recording work-related hearing loss and
musculoskeletal disorders (MSDs). The DOL is investigating the level of
hearing loss that should be recorded as a "significant" health condition, and
is holding forums to develop a comprehensive plan to address ergonomic
hazards, where appropriate definitions of "ergonomic injury" and MSD will be
decided.

OSHA revises recordkeeping regulations. New rules for how employers keep track of work-related injuries and illnesses go into effect January 1, 2002. OSHA issued the long-awaited update of recordkeeping practices on January 19, 2001.

About 1.3 million workplaces will be required to follow the new recordkeeping procedures. Employers with 10 or fewer employees will continue to be exempt from most requirements, as will a number of industries classified as low-hazard sectors. (All employers covered by OSHA must continue to report any workplace incident resulting in a fatality or the hospitalization of three or more employees.)

During the current year of 2001 employers must follow the requirements of OSHA’s original recordkeeping rule. The new rules update three recordkeeping forms: OSHA Form 300 (Log of Work-Related Injuries and Illnesses); OSHA Form 301 (Injury and Illness Incident Report); and OSHA Form 300A (Summary of Work-Related Injuries and Illnesses).

 

  Here’s what you need to know. The new recordkeeping rule:
  • Eliminates different criteria for recording work-related injuries and illnesses — one set of criteria will be used for both.
  • Requires your records to include any work-related injury or illness resulting in one of the following: death; days away from work; restricted work or transfer to another job; medical treatment beyond first aid; loss of consciousness; or diagnosis of a significant injury/illness by a physician or other licensed health care professional
  • Includes new definitions of medical treatment, first aid, and restricted work to simplify your recording decisions.
  • Requires a significant degree of aggravation before a pre-existing injury or illness becomes recordable.
  • Adds additional exemptions to the definition of work-relatedness to limiting recording cases involving eating and drinking of food and beverages, common colds and flu, blood donations, exercise programs, and mental illness.
  • Clarifies how to record "light duty" or restricted work cases. You’ll now record cases when the injured or ill employee is restricted from their "normal duties", which are defined as work activities the employee regularly performs at least once weekly.
  • Eliminates the term "lost workdays" and focuses on days away or days restricted or transferred. Also, new rules for counting these days rely on calendar days rather than workdays.
  • You’ll be required to record standard threshold shifts in employee hearing. The new OSHA 300 Form has a separate column to capture statistics on hearing loss.
  • Forms also include columns dedicated to musculoskeletal disorder cases. You’ll use the same recording criteria for MSD cases as for all other injuries or illnesses.
  • All needlestick and sharps injuries involving contamination by another person’s blood or other bodily fluids must be recorded.
  • You must set up a procedure for your employees to report injuries and illnesses, and you must tell your employees how to report. You are prohibited from discriminating in any way against employees who do report. (This could have ramifications regarding how safety incentive programs based on zero injuries are used.)
  • For the first time, employee representatives have access to parts of the OSHA 301 Form that are relevant to the employees they represent.
  • Your annual summary of injuries and illnesses will have to be posted for three months instead of one.
  • Your summary must be certified by a company executive.


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