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Post Your 300A

Don’t Forget to Post Your Summary of Work Related Injuries and Illnesses by February 1^st

Employers who are required to maintain OSHA’s Form 300, the Log of Work-Related Injuries and Illnesses, must complete and post Form 300A, which summarizes the injuries and illnesses for 2006.  The annual summary must be posted by February 1 and remain in place until April 30.   It should be displayed in a place where notices are usually posted or where employees may easily see it, such as a bulletin board in a break room.

The form must be signed by a company executive, who could be the company owner, a company officer, or the highest ranking company official at the location.  The signature is a certification that the form has been reviewed and the information is correct and complete.   Forms 300 and 300A must be retained for five years.

Complete directions for preparing the form are detailed in OSHA 29 CFR 1904.32 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=12776

The OSHA website also has all of the necessary forms for you to download for your use.  Go to  http://www.osha.gov/recordkeeping/RKforms.html  to access pdf or Microsoft Excel versions of the forms.

Manufacturer Fined $250K

Tool Manufacturer Fined Nearly $250,000 by Federal OSHA

For the third time in six years, federal OSHA has found widespread safety and health hazards at the West Hartford tool manufacturing plant of Danaher Tool Group, doing business as Holo-Krome Inc. OSHA's most recent inspection, conducted under two national emphasis programs aimed at preventing amputations and overexposure to lead, has resulted in citations for 26 alleged willful, repeat, and serious violations of standards. Proposed penalties total $247,600. While the list of citations was lengthy the primary citations included:

• Bypassing or removing interlocks
• Inadequately guarded power presses
• Not conducting annual inspections of lockout procedures
• Failure to lockout
• Exposed electrical parts
• Lack of asbestos training
• Lead exposure

The primary finding involved safety interlocks on machinery that were bypassed or removed, allowing employees to come in contact with moving parts. One worker sustained a hand injury on a machine with a bypassed interlock. OSHA proposed a fine of $70,000 for an alleged willful violation committed with intentional disregard of, or plain indifference to, the requirements of the OSH Act and regulations.

Eleven repeat citations, accounting for $138,100 in proposed fines, were issued for hazards similar to those cited at the plant in 2004. These included: unguarded or inadequately guarded mechanical power presses, grinders, and other machinery; no annual reviews of lockout procedures to prevent the accidental startup of machinery; exposed live electrical parts; lack of required hand protection; improper extension of fork trucks; and no warning signs and asbestos awareness training for workers. Repeat citations are issued when an employer has been cited for substantially similar hazards in the past and those citations have become final.

Fourteen serious citations, with $39,500 in proposed fines, were issued for lead accumulation on work surfaces; defective exit access; no controls to reduce excess noise levels; no hearing protection for exposed workers; confined space hazards; unguarded loft and work platforms; inappropriately used electrical cords; no fire extinguisher training; and failure to lock out machinery before performing maintenance. OSHA issues a serious citation when death or serious physical harm is likely to result from a hazard about which the employer knew or should have known.

"Left uncorrected, these conditions continually expose employees to the hazards of laceration, amputation, crushing injuries, hearing loss, fire, electrocution, confined spaces and exposure to toxic substances," said C. William Freeman III, OSHA's area director in Hartford. "The recurrence of hazards at this workplace is disturbing. Failure to supply and ensure these common, legally required safeguards unnecessarily puts employees' lives at risk."

What is GHS?

On September 12, 2006, OSHA published an Advanced Notice of Proposed Rulemaking in the Federal Register to seek comments on how to implement the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  The GHS has been adopted by the United Nations to facilitate international trade by developing consistency between laws in different countries.  The adoption of the GHS by OSHA will require OSHA to propose changes to the Hazard Communication Standard (20 CFR 1910.1200).  It is important to realize that the GHS is not a regulation or standard, but a system for standardizing and harmonizing the classification of chemicals internationally.  Its purpose is to create a logical and comprehensive approach to defining health, physical, and environmental hazards; develop a classification process that uses data on chemicals with comparison to defined hazards criteria; and standardize the communication of those hazards.

The GHS was developed because the global chemical business generates more than $17 trillion per year.  Just in the US alone, chemicals are more than a $450 billion business including more that $80 billion per year in exports.  While laws are similar, they are different enough to require multiple labels for the same product.  It is estimated that there are over 100 different types of Hazard Communication Standards for global products.  For large global companies, labeling is costly and time consuming.  The various global regulations are complex and expensive and can prevent medium and small companies from entering into the global market.  Just here in the US alone, chemical manufacturers, importers, suppliers, and users must comply with regulations from the CSPC, OSHA, DOT, and EPA.

The proposed rule to the Hazard Communication Standard will address changes to the Material Safety Data Sheet (MSDS) and product labeling, see  http://www.osha.gov/dsg/hazcom/ghs.html In the US, workplace labels are “performance oriented” resulting in a label that has product identity, hazard statements, and supplier information, but tends to be confusing.   Some global US companies follow the voluntary ANSI Z129.1 Precautionary Labeling Standard that includes several of the core elements to GHS, which are: Symbols (hazard pictograms) that show health, physical, and environmental hazards; Signal Words such as Danger or Warning; and Hazard Statements that would include standard phrases assigned to a hazard class and category.  All symbols, signal words, and hazard statements have been standardized and assigned to a specific hazard category and class.

Under the GHS, the MSDS will become the SDS (Safety Data Sheet) with 16 required sections.  A few of the new subjects to be covered include Ecological, Transport Information, and Disposal Considerations. All three of these sections will have detailed information.  For example, under Disposal Considerations, the SDS will cover a description of waste residues and information on the safe handling and methods of disposal, including any contaminated packaging.  

The proposed changes to the Hazard Communication Standard will take time.  For companies that are interested in entering into the global market or companies that are currently in the global market, the intent is to help streamline the process of providing information and to decrease the redundancies of the various labels that are now required, with the overall result of saving time and money.

Serious Electrical Hazard

Square D Recalls Safety Switches Due to Shock or Electrocution Hazard

The U.S. Consumer Product Safety Commission, in cooperation with Square D announced a voluntary recall of over 27,000 electrical safety switches like the one pictured to the left.   Consumers should stop using recalled products immediately unless otherwise instructed.  It has been determined that the switch can continue to supply electricity even after being placed in the off position.  This poses a significant risk of electrical shock or even electrocution.

The recall includes General Duty 30 and 60 ampere, 240 volt, 1 phase and 3 phase NEMA 3R safety switches. The switches are typically used to control the flow of electricity to outdoor motorized units that are hardwired to a household or business’ electrical system such as outdoor air conditioning and heating (HVAC) equipment.  For more information go to http://www.cpsc.gov/cpscpub/prerel/prhtml07/07062.html

Contractor Fined $164K

A Residential Framing Contractor Faces $164,000 in Fines for Fall and Other Hazards

Federal OSHA has cited Shawnlee Construction LLC for allegedly exposing employees to fall hazards at residential construction projects in Newton and Danvers, Mass. The Massachusetts based wood framing contractor faces a total of $164,000 in fines. OSHA also issued $43,000 in proposed fines to Alexandria, Va.  based Avalon Bay Communities, the developer, project manager, and general contractor for both projects.

OSHA inspections in June and August found Shawnlee employees working at heights up to 33 feet without fall protection.  OSHA issued two repeat citations to Shawnlee for the fall hazards because the agency had cited the company in 2004 and 2005 for fall hazards at other jobsites. Shawnlee was issued an additional repeat citation for exposing employees to overhead hazards because it was cited in 2005 for similar hazards. Proposed fines for the repeat citations total $140,000.

Seven serious citations, carrying $24,000 in proposed fines, were issued to Shawnlee for uncovered floor holes and for electrical, fire extinguisher, guardrail, debris, stairway, and additional fall protection hazards.