In the previous article posted concerning OSHA 300A Form Posting, there was discussion on calculating average number of workers. This value is to be entered under the establishment information on the OSHA 300A Form. This calculation can give employers some confusion and incorrect numbers can cause problems for your DART rate.

The DART rate for your company comes into play when you transfer your 300A data over to the OSHA electronic database. DART stands for days away, restricted or transferred, and the number of workers and total hours worked affect this rate. If your DART rate is high, it could trigger OSHA to take a closer look at your facility. We have had several gins receive letters from OSHA concerning their higher-than-average DART rate but have not seen any additional actions from OSHA at this point. It is very important that OSHA receives correct data representing your facility.

Average number of employees is essentially the total number of workers paid during the year divided by the number of pay periods. Be sure to count every paycheck, including all salaried, full time, part time, seasonal, and temporary employee. This would even include the employee that only worked a few days and never returned but did receive a paycheck.

Let’s look at an example for calculating the average number of employees for the purpose of OSHA 300A and electronic reporting. It can be viewed as the number of employees or the number of paychecks written. If you paid 15 employees for 8 pay periods, 30 employees for 16 pay periods, and 8 employees for 28 pay periods, then your total number of employees would be (15×8) + (30×16) + (8×28) = 824 total employees. That number would then be divided by the total number of pay periods (52 for weekly, 26 for biweekly, etc.). If we assume weekly pay periods, the average number of employees for this example would be (824/52) = 15.8 rounded up to 16 average employees over the year. If this calculation is not correct it will have an effect on how OSHA calculates your dart rate.

The other part of this calculation to consider is the total number of hours worked and is just as important as the average number of employees. For hourly employees the total hours worked can just be pulled from your payroll system, but salaried employees there will have to be some estimations made if the data is not available. For salaried employees, take the time to make as accurate estimations as possible as this total number of hours worked plays a crucial role in OSHA correctly calculating DART rates for your facility. Additional examples and explanations can be found here OSHA Forms and Instructions

It may take a little more time and work to get accurate numbers for the average number of employees and the total hours worked, but it is important to get these numbers correct. If you do not, there is a risk of being labeled as a high risk workplace based on faulty numbers.

If there are any question concerning this topic or other OSHA related issues. Please give Southeastern Cotton Ginners Association a call.

In the days since Joe Biden took office on January 20 there have been a large number of executive orders. One of those executive orders directed the Occupational Safety and Health Administration to do more on Covid-19 including a new temporary standard. While OSHA hasn’t gone quite as far as a standard, they have issued guidance on combating Covid in the workplace, since the Executive Order was signed. This is actually the second guidance. The first, in 2020, referenced CDC guidance and deferred a lot to them.

The guidance from OSHA can be found on their webpage entitled : Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace. That page has all of the current guidance including encouraging employers to have a Covid Plan. The implication is that if you don’t have a plan and you have an outbreak, you very well could face a General Duty Clause Citation.

While most gins have made it through the season with few or very few issues with Covid, we encourage everyone to go to the site above and review the 16 Elements of a covid plan that OSHA is recommending. Additionally many states are allowing agricultural workers to be in the current group eligible for vaccination. You and your employees may be eligible but distribution is VERY localized and you need to contact your local health department if you don’t know.

DSF

A few gins have called us recently regarding a letter or email from OSHA regarding their DART Rate. So what is a DART Rate and do you know what yours is? A DART Rate is a measure of injuries and illnesses and is designed to be able to compare industry to industry and individual companies to an industry average. It is SUPPOSED to eliminate the size factor so that you can compare apples to apples. DART stands for Days Away Restricted or Transferred.

Ideally, the DART rate is the number of injuries that would be lost time or restricted an employer with 100 employees would have in a year’s time. It is based on the 200,000 hour base for 100 employees at 2000 hours each. Employers record injuries with days away, restricted or transferred on their OSHA 300 form. For the past few years, nearly all employers have been required to send their OSHA 300A summary information (this includes the DART information) to OSHA. This has evolved in to some gins getting letters.