What’s Your DART Rate?

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.

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Gins And the Coronavirus Pandemic

Well this is an unprecedented situation we face. I can’t remember anything quite like this. We’ve received a few calls and emails asking some very good questions as we move into the second full week of the screeching halt that has become life in the US.

One of the most important things to remember is that given the current circumstances, it appears that the virus will work its way through society over time. Over how much time seems to be one of the most pressing questions. Without some significant changes, it’s not a matter of if but when someone you know will be affected by the virus. The outcomes in all but a few cases are good. The vast majority of people do get better. What I have read today is that most will get better in a few days just treating the symptoms. Some will require a hospital stay and that could be a significant time away from work even if the hospital stay is short. The idea is to keep the wave of patients to the hospitals below their capacity.

All of the things that we have seen implemented have been to reduce the impact to the medical community and ultimately to humanity. So what does that mean for you the cotton ginner? The first thing it means it to make sure anyone who is symptomatic to stay at home. It also means following the CDC guidelines and using common sense. Keeping distance, implementing increased hand washing and use of sanitizers and PPE where washing and distancing are not as practical. Keeping gatherings to a minimum or eliminate them altogether.

A really good place to start is the CDC. Follow their Guidelines for employers. Another source of information for employers is OSHA. OSHA put out Guidelines for employers last week at www.osha.gov. This has been updated and will continue to be as this evolves. We work closely with Fisher and Phillips who are a nationwide law firm. They have started a COVID-19 response team of lawyers on how employers can prepare and help themselves moving through this. Please go to their page on the COVID response. It is also continually updated as they see necessary. All these pages should be checked often.

As far as government response. Of course, you need to follow the guidelines in your local area. We’ve seen and will continue to see stronger response in some areas over others. Congress has passed one bill and will pass more to help alleviate the impact on employers and employees. Please refer to THIS SUMMARY of the first bill. It provides for up to 80 hours of paid sick leave and expands job protections for employees to all businesses. Please refer to the Summary for more details. President Trump just today said there will be relief for small businesses along with bailouts for airlines and cruise industries but no details were given.

This is a very VERY VERY fluid situation. In just over a week we went from a handful of cases to thousands and whole cities being put on lock down with highly restrictive travel. We’re monitoring the situation and please let us know if we can help.

PS: Keller and Heckman put out info on Insurance and the Coronovirus


Online Submission of OSHA Data Deadline Near

We wanted to remind everyone that the deadline for submission of your OSHA 300A data is near. All employers in certain industries (including ours) that had 20 or more employees at any point in 2019 must submit their OSHA 300A summary information online to OSHA by March 2, 2020.

This is the third year of the program and the earliest online submission date. Please don’t fall for any schemes or scams. I did a google search on this today and found a couple companies that will do this for you for a fee. THIS IS TOTALLY FREE DO NOT PAY SOMEONE TO DO THIS SUBMISSION.

The process is straight forward. Go to https://www.osha.gov/injuryreporting/index.html and go to the red block on the right side of the page that says “Launch the Injury Tracking Application”. This will get you started. The page linked above has a lot of information about the reporting process as well as who should report etc. If you don’t know, the NAICS code for cotton gins is 115111.

Please give us a call or email me if you have any questions


OSHA Clarifies Earlier Rules on Drug Testing and Incentives

Way back in 2016 (before the election) OSHA published a pretty comprehensive rule that affected many, if not all, businesses in the US. The rule was fairly controversial initially but not for the stated purpose of the rule. The rule was the electronic reporting rule that required all large and many small companies (including cotton gins) to report their OSHA 300 data to the agency each year. Included in that rule, almost as an afterthought, were two additional rules that dealt with incentive programs and drug testing as they play a roll in timely reporting of injuries by employees.

The additional rules known as the anti-retaliation rules, initially barred employers from post Continue reading

OSHA Revises Online Reporting of Injury Data

In a change that was largely expected, the Department of Labor published a proposed change to their Electronic Reporting Rule that requires large employers and smaller employers in certain high risk segments to report OSHA 300 data. The changes would rescind the previous requirement that the larger employers (over 250 employees) had to submit OSHA 300 form information as well as OSHA 300A (summary) data.

Assuming the changes become final in a few weeks, the larger employers and small employers would only have to submit the Summary 300A data. The concern is that the OSHA 300 data contains information Continue reading

Reminder: OSHA 300A Log Summary Due Soon

We are a little over a week until many businesses must submit their OSHA 300A logs electronically. Earlier this year, OSHA clarified that even employers in “state-plan states” that haven’t adopted the rule need to submit their data electronically this year.

Gins that have 20 or more employees at any point in the year will need to follow the links below to submit your data. Start with the OSHA record keeping page and make sure you Continue reading