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 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


Wage and Hour Audits Coming to a Close

Due to an emphasis program in our region, many gins received investigations/audits from the Wage and Hour division of the Department of Labor. These audits have bee fairly extensive and have been a lot more drawn out than some in the past. Most of the audits occurred back in the early Fall but few have gotten the results yet. A few have just now begun to find out if they owe any back wages and if so how much.

We have only seen a couple of the forms that gins have received and the ones we have reviewed so far have some issues. Some alleged violations of MSPA or other laws were mis-applied and back wages were mis-calculated. We’re working through these and these are not typical for the agency to miss these issues.

If you were lucky enough to get audited by the Wage and Hour division, we encourage you to have a second set of eyes look at the proposed back wages and/or penalties. We can look at it, your attorney can look at it or others but make sure you discuss this with someone that knows the laws surrounding the alleged violations. It could save you a lot of money.

Give us a call if you have any questions.


Have You Posted Your OSHA 300A?

Remember, your OSHA 300 forms should be filled out and the 300A posted by Feb. 1 each year and the Summary should remain in place until April 30th. The OSHA 300 is the form where you record all your work-related injuries and illnesses. Even if there are no injuries or illnesses, you still need to fill the form out. Make sure there are totals (zeros count as totals) in the appropriate columns and sign the form. Make sure there are no blanks.

Then you should fill out the OSHA 300A summary form. This is the form that gets posted. It should be posted for Feb, March and April of each year. All 300 and 300A’s should be filed once the time for posting is up and you should have five years in your files. This is typically one of the first things that an OSHA inspector will want to see if you ever get inspected.

While you’re at it, go ahead and enter the information on the 300A into the reporting Portal. OSHA collects the 300A information for many employers each year. Cotton gins with less than 20 employees for the entire year are exempt but most gins will have to report. Go to then click the red button on the right column to launch the injury tracking application (ITA). You will enter the data that is on your OSHA 300A summary form that you have posted. This filing must be done by March 2 this year and following years. There is a lot of information on this page if you have trouble with your reporting.

As always, give us a call if you have any questions.


New I-9 Published Today

On Jan. 31, 2020, USCIS published the Form I-9 Federal Register notice announcing a new version of Form I-9, Employment Eligibility Verification, that the Office of Management and Budget approved on Oct. 21, 2019. This new version contains minor changes to the form and its instructions. Employers should begin using this updated form as of Jan. 31, 2020.

The notice provides employers additional time to make necessary updates and adjust their business processes. Employers may continue using the prior version of the form (Rev. 07/17/2017 N) until April 30, 2020. After that date, they can only use the new form with the 10/21/2019 version date. The version date is located in the lower left corner of the form.

USCIS made the following changes to the form and its instructions:


Revised the Country of Issuance field in Section 1 and the Issuing Authority field (when selecting a foreign passport) in Section 2 to add Eswatini and Macedonia, North per those countries’ recent name changes. (Note: This change is only visible when completing the fillable Form I-9 on a computer.)


  • Clarified who can act as an authorized representative on behalf of an employer
  • Updated USCIS website addresses
  • Provided clarifications on acceptable documents for Form I-9
  • Updated the process for requesting paper Forms I-9
  • Updated the DHS Privacy Notice

A revised Spanish version of Form I-9 with a version date of 10/21/2019 is available for use in Puerto Rico only.

For more information, visit I-9 Central or join a free Form I-9 webinar

Certified Ginners Honored at Southern Southeastern Annual Meeting

Many years ago, the National Cotton Ginners Association and the USDA developed the plan for a Certified Ginner Program. The certification attests that the ginner has fulfilled the requirements set out by the organizers with the expectation that they will stay in the ginning industry. The gins that sponsor these employees are making a commitment to the industry as a whole and to their employees to raise the level of leadership in their facility and ginning.

To become a Certified Ginner, an individual must attend three levels of Gin School, Complete a written exam, be current on CPR and First Aid Training and receive a letter of recommendation from an established ginner as to the individual’s skill, experience, knowledge, and character. This year there were nine ginners from the Southeast that fulfilled those qualifications.

Certified Ginners Receive Award
Certified Ginners Receive Award

Four of the ginners that completed all the requirements were able to travel to the Southern Southeastern Annual Meeting to receive their plaques. Martin Coronado from Miller County Gin, Maximo Hernandez, Oseas Lopez, and Marcus Cauley from Southeastern Gin in Surrency Ga were present. Adrian Lozano from Henry County Gin, Gustavo Mendoza from Cherokee Gin, Sam Perkins from Early County Gin and Pablo Felipe and Evan Williams from Edwards Cotton Company were not able to attend this years meeting but all deserve congratulations. For more information on Gin School and the Certified Ginner Program, please visit the National Cotton GInners site at

Gin Cost Survey Participation Urged

The Southeastern Cotton Ginners Association and the National Cotton Ginners Association urge ginners to complete USDA Agricultural Research Service’s 2019 Cost of Ginning Survey.

The confidential, triennial survey helps to identify historical trends of gin operation and helps to document the incorporation of new technologies to maintain or reduce ginning costs. The cost of ginning cotton is an important concern for producers and ginners, and survey data provides information about key variable costs as a component of the overall cost of ginning cotton.

The survey now is being conducted electronically – a step aimed at making it easier for ginners to complete the questionnaire at

Questions should be addressed to NCGA’s Harrison Ashley at 901-274-9030 or