First Quarter HSE Bulletin
Department of Health, Safety & Environment Compliance Reminder – Quarter One – 2019
OSHA’S TOP TEN VIOLATIONS
OSHA announced its list of the Top 10 most frequently cited workplace safety violations for fiscal year 2018. Fall Protection remains the No. 1 violation with Hazard Communication as No. 2. New to the list is Personal Protective and Lifesaving Equipment – Eye and Face Protection. Composites manufacturers can use this list as a blueprint in the workplace to ensure compliance and keep workers safe.
- Fall Protection (1926.501) – 7,270
- Hazard Communication (1910.1200) – 4,552
- Scaffolding (1926.451) – 3,336
- Respiratory Protection (1910.134) – 3,118
- Lockout/Tagout (1910.147) – 2,944
- Ladders (1926.1053) – 2,812
- Powered Industrial Trucks (1910.178) – 2,294
- Fall Protection – Training Requirements (1926.503) – 1,982
- Machine Guarding (1926.212) – 1,972
- Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102) – 1,536
UPCOMING REGULATORY DUE DATES
February 1st – OSHA Injury and Illness Record keeping Rule
The annual summary of work-related injuries and illnesses for calendar year 2018 must be recorded on the OSHA 300A Form and posted in a visible prominent area of the workplace from February 1 – April 30, even if there were zero injuries for the year. This rule applies to covered employers with more than 10 employees. The Injury and Illness Log (Form 300), annual summary (Form 300A) and related injury and illness documents (Form 301 or equivalent) must be kept for a period of 5 years. Forms are available at https://www.osha.gov/recordkeeping/RKforms.html.
In addition to posting a hard copy of the 300A Summary annually, certain facilities must submit electronic reports by March 2nd every year to OSHA’s portal using the “ITA Launch Page” https://www.osha.gov/injuryreporting/index.html
- Facilities with 20-249 employees in certain industries, which includes composites manufacturers and manufacturing codes 31-33. Submit the OSHA 300A (Summary). For a list of applicable NAICS industry classifications, see https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.pdf.
- Facilities with 250+ employees. Submit the OSHA 300A (Summary), 300 (Log) and 301 (injury/illness detail).
NOTE: OSHA recently published a Notice of Proposed Rulemaking to remove the requirement for these facilities to submit 300 and 301 data. It is uncertain if the proposed rule change will be approved, so be sure to check OSHA’s https://www.osha.gov/injuryreporting/ before March 2nd for the latest update!
For additional information go to OSHA’s Record keeping page at https://www.osha.gov/recordkeeping/.
March 1st – EPA Section 312 Tier II Reporting
Annual submission of EPA’s Chemical Inventory Report (Tier II) for Reporting Year 2018 is due March 1, 2019. Facilities that store 10,000 pounds or more of any hazardous chemical on-site at any one time must file. For Extremely Hazardous Substances (EHSs), the reporting threshold is 500 pounds or the threshold planning quantity (TPQ), whichever is lower (see http://www.epa.gov/epcra/epcra-sections-311-312). Reports are required to be sent to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), and local Fire Department.
For each chemical reported, include applicable physical and health hazard information. See EPA’s Fact Sheet on for more information https://www.epa.gov/sites/production/files/2018-12/documents/fact_sheet_and_qsas_for_reporting_new_hazard_categories_on_tier_ii_form_12-03-18.pdf.
June 30th – DOT Hazmat Registration
Annual DOT Hazmat Registrations and fee payments are due June 30, 2019 for those who offer or transport certain hazardous materials (or wastes) in commerce that require placarding. More information is found at http://phmsa.dot.gov/hazmat/outreach-training/registration-program.
July 1st – EPA Section 313 Toxic Release Inventory (Form R) Reporting
The Annual Toxic Release Inventory (TRI) Report is due to EPA by July 1, 2019 for the 2018 Reporting Year. The rule applies to specific industry sectors, with 10 or more full-time employees, and who manufacture, process or otherwise use a TRI-listed chemical above threshold levels. Additional information on the TRI Program addressing applicability, reporting instructions and guidance can be found at https://www.epa.gov/toxics-release-inventory-tri-program.
Compliance Program Review, Safety Meetings and Annual Training Requirements
Now is a good time to plan your calendar to review written programs, set-up monthly/periodic safety committee meetings and schedule annual required OSHA and EPA training, such as:
Hearing Conservation (and annual audiograms).
- Respiratory Protection (and FIT testing).
- HAZWOPER Emergency Responder.
- Lockout-Tagout and Electrical Safety.
- Portable Fire Extinguisher and Fixed Extinguishing Systems.
- Access to Employee Exposure and Medical Records.
- Bloodborne Pathogens.
- Hazardous Waste Training for LQGs.
Other training may be required every 3 years (e.g., First Aid, Powered Industrial Truck (Forklift), and DOT Hazardous Materials Training).
Ask the Compliance Expert
For questions related to the content in this bulletin, as well as any other regulatory issues, please email us at firstname.lastname@example.org. Or visit us at https://www.compositesone.com/people/health-safety-environment/regulatory-assistance/ for more information or to submit an inquiry. We will make every effort to answer your request within 24 – 48 hours.
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