It’s time to prepare, certify and post your OSHA 300A Annual Summary of workplace injuries and illnesses in your workplace. This is required for all U.S. employers, except those with ten or fewer employees or those whose NAICS code is in the set of low-hazard industries exempt from OSHA’s injury and illness recordkeeping requirements.

In addition, by March 2, 2019, establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses. If employers in State Plan states (e.g. Washington) have questions about their obligation to submit injury and illness information, please contact your State Plan office.

Washington has seen a dramatic shift in oil transportation recently, both in the types of oil and in the locations where large quantities of oil are transported. These changes affect the risks associated with oil transportation. Many communities don’t have response resources for spills of oil or hazardous materials. To help solve this problem, the Washington State Department of Ecology provides equipment and training grants to emergency responders. These grants help local communities effectively prepare for and respond to spills.

Funding is available for the following entities:

• Washington counties, cities, and municipalities
• Other state recognized local governments
  • Ports
  • Public utility districts
  • Other special purpose districts (e.g., Clean Air Agencies, Fire Protection)
• Federally recognized tribal governments
• Washington state agencies

To be considered, the community the agency responds to must have a substantial threat of an oil spill or hazardous materials incident occurring in their jurisdiction. The grant is primarily intended to assist emergency responders in purchasing equipment they would not otherwise be able to purchase.

Grant applications will be accepted January 2, 2019 – March 6, 2019. See Ecology’s grant website for further information.

Decontamination is a vital part in any emergency response effort.  You never know what you may have come in contact with that can affect not only your health, but the health of those around you.  For decontamination to be effective, preparedness is the key.  It is important that you maintain open communications on the hazards that you face in your work or hazard environment.  You should also establish operational and emergency procedures to be prepared for an incident response.  Personnel protective equipment selection criteria should be put into place as well to ensure the safety and health of the responders.  Some elements to consider are the levels of protective equipment that may be required, whether it’s disposable or re-usable, how to layer to avoid cross-contamination during doffing procedures, whether physical, chemical or combination decontamination will be used, and how to collect and dispose of contaminated items.  Overall, communication, training, practice drills and periodic program reviews will provide feedback to ensure that your decontamination plan is effective, up-to-date, and ready for implementation should an event occur.

For more information on decontamination, review chapter 10 of DHHS (NIOSH) Publication Number 85-115 @ https://www.cdc.gov/niosh/docs/85-115/pdfs/85-115-d.pdf?id=10.26616/NIOSHPUB85115

Restrictions on outdoor burning and the use of uncertified wood burning stoves and fireplaces begins at 10 a.m., Sunday, November 18, 2018. The ban will remain in place until further notice.

Spokane Regional Clean Air Agency is issuing the “Stage 1 Burn Ban” because concentrations of air pollutants are expected to increase putting residents at risk. Under a Stage 1 “yellow” burn ban: 

• The use of uncertified wood stoves, fireplaces, inserts and other uncertified wood-burning devices is prohibited in the Smoke Control Zone, unless they are a home’s only adequate source of heat.*
• EPA-certified wood stoves, pellet stoves and other certified wood-burning devices are allowed.
• All outdoor burning is banned throughout Spokane County.

* If you don’t have an adequate source of heat, contact Spokane Clean Air for an exemption. Click here for details.

OSHA has scheduled a Notice of Proposed Rulemaking for March 2019 in regards to the agencies intention of updating the current Hazard Communication Standard.  The current standard, which is derived from the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), was issued in 2012.  The GHS is a living document and therefor has had many revisions made to it since its inception in 2008.  The current GHS-HazCom was based on the third edition of the GHS and now OSHA is looking to incorporate revisions 4 through 7 into the new standard.

With the inclusion of the 4 revisions, there are many areas for potential change within the GHS-HazCom.  Some possible changes are:

• Updates to multiple SDS sections to provide further clarity and instruction
• Updated labeling elements e.g. hazards, guidance, precautionary statements
• New physical hazard class, categories and categorization criteria

Additional details are available from OSHA and Lexology.

The U.S. Department of Labor Occupational Safety and Health Administration (OSHA) reports that it will begin using electronically submitted Form 300A injury data from CY 2016 to target manufacturing and non-manufacturing employers with high injury rates for comprehensive inspections. The agency will also perform inspections on a random sampling of employers who did not provide 300A data in order to deter establishments from failing to report.

The deadline for submitting the 300A data for CY 2017 was July 1, 2018; however, OSHA is still allowing employers to provide information. Going forward, establishments with 250 or more employees that are currently required to keep OSHA injury and illness records and establishments with 20-249 employees that are classified in specific industries with historically high rates of occupational injuries and illnesses will be required to provide information to OSHA by March 2 each year.

In September the U.S. Environmental Protection Agency (EPA) issued a final fees rule under the Toxic Substances Control Act (TSCA) that took effect on October 1, 2018.

TSCA provides the EPA with the authority to require payment from chemical manufacturers. Fees collected will go toward developing risk evaluations for existing chemicals as well as collecting and reviewing toxicity and exposure data and making determinations with respect to the safety of new chemicals before they enter the marketplace. Small businesses will be eligible to receive a substantial discount on their fees.

EPA will host a series of webinars focusing on making TSCA submissions and paying fees under the final rule. Upcoming webinars are October 24, and November 7, 2018. For a more detailed summary of the final rule and how it applies as well as other resources, see http://www.lawbc.com/regulatory-developments/entry/epa-issues-final-tsca-fees-rule.