What's New with OSHA in 2015?
Record keeping and Reporting
By now, hopefully you’ve heard the OSHA news that made a big splash toward the end of 2014: As of January 1, 2015, new reporting requirements are in place. Who has to report and how they have to report has not changed, but what needs to be reported has. Previously, there were two situations that companies were required to report to OSHA: all workplace fatalities and/or the hospitalization of 3 employees as a result of a single incident (hospitalization means admission to the hospital, not just an emergency room visit). Now the rules have grown stricter. In addition to still needing to report all workplace fatalities, employers now must report the hospitalization of one employee from a work-related incident, all amputations, and all losses of an eye.
Keep in mind that if you are under federal OSHA’s jurisdiction, you are bound by these requirements regardless of whether or not you are required to keep OSHA logs or other documentation. More information, including a definition of “amputation” and timelines for reporting can be found at OSHA’s website, here.
Global Harmonization System (GHS)
Image from Cornerstone
The first requirements for GHS (training, labelling, SDS, pictograms, etc.) have been in full swing for over a year now, but 2015 brings some new key dates. Come June, all employers are expected to be in full compliance with the new requirements and by December, distributors will not be allowed to ship any chemical from the manufacturer unless it has a GHS label. For all the talk about GHS over the past few years, this is it. It is now the law of the land. More information can be found here.
OSHA’s 2015 Regulatory Priorities
Along with its more detailed regulatory agenda, OSHA has announced some of its priorities for 2015. These include:
- Controlling crystalline silica exposure. From residential paver patio installation to commercial brick and block laying, if you haven’t seen serious crystalline silica overexposure occurring you haven’t been paying attention.
- On the heels of last year’s Ebola fears (luckily unfounded fears within the United States), OSHA is hot on enhancing its requirements regarding infectious disease protocols in the healthcare industry and other high-risk environments.
- Expect to see a final rule regarding the required electronic submission of injury and illness reporting documents. The controversial aspect? That these records would then be made public.
OSHA’s 2015 Regulatory Calendar
Here are the important key dates to watch for in the upcoming year:
- March – OSHA plans on issuing a proposed rule to help employers determine if crane operators are “completely qualified”.
- March – OSHA is expected to publish a final rule for its long-awaited Confined Space in Construction regulation.
- March – OSHA expects to issue a proposed rule that would incorporate new fit-test protocols into its existing respiratory protection standards.
- April – The comment period for input on ways to regulate occupational exposure to chemicals will come to a close.
- June – A small business review panel will begin discussing the process management standard in relation to preventing major chemical accidents.
- June – OSHA expects to complete analysis of all the public comments and stakeholder testimony it has received regarding Silica exposure since it requested the feedback in 2013.
- June – OSHA is expected to issue a final rule on slip, trips and falls, as well as establish requirements for personal fall protection systems.
- August – A final rule is expected that would require the electronic filing of record keeping documentation. OSHA also hopes to amend its regulation to say that record keeping requirements are an ongoing responsibility and, therefore, companies would be required to complete the documentation regardless of when they realized it had not been done. The impact? Those that have been able to have citations thrown out because the record keeping documentation OSHA had cited for was more than 6 months old would no longer be able to do so.
- On the backburner: Combustible Dust rule making has been pushed to 2016 as OSHA waits for the NFPA to update its consensus standard. Rule making regarding backup hazards has also been pushed back until 2016.