Last week we reported that OSHA’s ITA portal, the place you put your OSHA 300A summary information, was having some issues. Not that they are all resolved but the page is still up and is accepting data. We have heard from a couple of gins that had not made the deadline due to the problem, that they were able to make reports either late last week or in the last day or so.
If you had not submitted your data and still need to do so, we wanted to remind you that you can still get the data in.
It was announced earlier this year that there wouldn’t be a gin school for the second year in a row… at least not in person. The National Cotton Ginners Association, USDA and various state and regional Associations feel that continued training is a very important part of what we do. Therefore, in lieu of an in-person gin school, the NCGA and USDA are hosting an online Gin Training Seminar.
There will be three seminars in total scheduled one day a week for three weeks. Each session will cover different topics and you can register for one, two or all three. All sessions are from 1PM-5 PM CENTRAL TIME and 4 hrs of Continuing Education Credits will be given for all of these sessions for certified ginners. Please refer to the links in the flyer below. We certainly encourage all of our members to participate. This is a great opportunity for your gin employees to learn from the best in the business.
Please contact Harrison Ashely with the National Cotton Ginners Association for questions.
The deadline for reporting your OSHA 300A information was two days ago but we understand many people still cannot get into the site or get part way in and receive errors. OSHA has indicated that they are continuing to have problems.
At this point we recommend you keep trying and capturing your screen to prove you’ve been attempting to enter the data. Also, if possible, open a help ticket (that link has been having trouble as well) to get some help in the process. The errors that have been reported range from no establishments associated with a user account, to not being able to reset a password or not being able to establish an account and everything in between.
If we get more information or tips on how to best deal with this, we will let you know.
From the NCC: FSA announced today that the Quality Loss Adjustment (QLA) application deadline has been extended until Friday, April 9 due to the recent winter storms and updates on program rules. This extension is welcomed in order to give cotton growers additional time to gather production information to complete signup.
Please contact NCC staff if you have any questions.
The deadline to apply for the Quality Loss Adjustment is Tomorrow, March 5, 2021. The program assists producers who suffered quality losses in the 2018 or 2019 crop years. This program requires that producers show a 5% loss on ‘affected production’. This would be bales that had a loss of quality in one or both of those seasons. Bales that do not have a quality reduction are not ‘affected production’ and are not counted in the calculation.
The USDA has a website at www.farmers.gov/quality-loss for more details. We have also attached a Frequently Asked Questions (FAQ) from the National Cotton Council. We have been told that if you don’t have all the documentation together but think you will have a loss, it is best to apply by the deadline and fill in the documentation later.
Please refer to the FAQ below for more information from the NCC:
All employers in many categories (including agriculture) must submit their OSHA 300A summary information to OSHA via their web portal. This year’s deadline is March 2 (tomorrow). Please take a few minutes to make sure you have done this. The website is https://www.osha.gov/injuryreporting/ . When you go to that page, look for the Injury Tracking Application to begin the process.
For the past several years, OSHA has been requiring that all employers in most industries, to submit their OSHA 300A summary information to the agency via the web. Most cotton gins are captured in this group of employers that are required to report their data. The only ones that may not have to are the gins that, at no point during the previous calendar year, in this case 2020, had 20 or more employees (peak employment). If you had 19 or fewer employees for the entire year, you will not have to submit your data.
One of the critical things you may want to double check is your DART rate. Please refer to this article that Andy wrote on how to calculate your DART rate. The reason this is critical is that in the past year a few of our members have received some letters from OSHA regarding their DART rate compared to “Industry Average”. Since the Industry Average has been derived on a very small number of sampled employers in the past it may be inaccurate. When the Obama Administration first proposed this electronic submission, the rule’s preamble specifically discussed that the data (DART Rate) may become public, allowing for current or potential employees to see the data in a way similar to how people can look up or view a restaurant’s Health Department Inspection information. The Trump administration stopped that but we are in a new era and there’s no telling what may happen going forward.
The page linked above has a lot of Frequently Asked questions on this process. . You can find most answers on this page or contact Andy Knowlton with Questions regarding the OSHA 300 or 300A summary. We can help with the forms but not the site unfortunately.
As previously reported, the 2021 Adverse Effect Wage Rate (Minimum wage for H-2A employers) was delayed due to legal activity over a proposed rule in the waning days of the Trump administration. The USDA wage survey results were released on Feb 11. Tomorrow the DoL will publish the AEWR for 2021 with the wages effective immediately upon publication.
What does this mean? If you don’t hire H-2A workers, then it doesn’t mean anything. If you are currently working H-2A employees then they and your corresponding domestic employees will need to be paid the new wage. If you don’t have any H-2A or won’t until the harvest season, the new wages will need to be paid for 2021.
Wages for 2021 are below.
Your agent or contractor that you work with will be sending this information to you soon if they haven’t already but we wanted to make sure you had it for planning purposes.