Is Your Facility Compliant?

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Would you like to avoid a compliance request from the Department of Homeland Security (DHS)? Then you should be aware of the DHS program outlining Chemical Facility Anti-Terrorism Standards for facilities that possess “high-risk” chemicals of interest. If you meet or exceed the threshold screening values for the chemicals, you must go through the screening process which involves taking training, submitting a Top-Screen for DHS review, possibly conducting a Site Vulnerability Assessment, developing or revising a Site Security Plan, and hosting a DHS representative for an on-site inspection. To find out if this applies to your company, check out the list of the high-risk chemicals and the threshold screening quantities in Appendix A of the standards.

For more information regarding the CFATS process, click here.

If you require assistance complying with the regulatory guidelines, drop us a line. We’d be happy to assist.

2022 Worker Memorial Day

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Every year the nation recognizes Workers Memorial Day. Nationally, April 28th is the day we pay our respects to those who lost their lives on the job, and recognize the impact these tragedies have on the family members, co-workers, and communities. More than 4,700 workers suffered fatal injuries on the job in 2020 according to the Bureau of Labor Statistics. According to Washington State Department of Labor and Industries, 53 worker fatalities were recorded in Washington State in 2021.

This year there are live and virtual events taking place throughout the country to remember those that have lost their lives on the jobsite. Washington State is providing its Workers Memorial Day Ceremony virtually on Wednesday, April 27th at 11:30 a.m. PT. The event page can be accessed by clicking here.

The Department of Labor’s Workers Memorial Day Program national event is a virtual event being provided through YouTube on Thursday, April 28th from 1 p.m. to 2 p.m. ET.

OSHA Proposed Amendment to Occupational Injury and Illness Recordkeeping Regulation

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OSHA is proposing to amend 29 CFR 1904.41, Electronic submission of Employer Identification Number (EIN) and injury and illness records to OSHA. By revising reporting requirements, they are hoping to identify workplaces where employees are at higher risks. The proposed rule would also help OSHA leverage their resources to continue to promote increased transparency throughout the workforce. According to the news release from OSHA on 28 March 2022, the proposed rule would also:

  • “Require establishments with 100 or more employees in certain high-hazard industries to electronically submit information from their OSHA Forms 300, 301 and 300A to OSHA once a year.
  • Update the classification system used to determine the list of industries covered by the electronic submission requirement.
  • Remove the current requirement for establishments with 250 or more employees not in a designated industry to electronically submit information from their Form 300A to OSHA annually.
  • Require establishments to include their company name when making electronic submissions to OSHA.”

To review the summary of changes and submit formal comments click here. Comments must be submitted by May 31, 2022

2022 OSHA 300A Posting and Reporting

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Welcome to 2022! Did you know that it’s time again to prepare, certify and post your OSHA 300A Annual Summary of workplace injuries and illnesses in your workplace? It’s 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 that are exempt from OSHA’s injury and illness recordkeeping requirements. 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.

Your workplace Annual Summary must be posted from February 1st to April 30th. Electronic reporting is also due by March 2nd for employers with 20 or more employees.

For the PDF versions of the OSHA 300 forms series, click here or for more information on OSHA 300 reporting click here.