Have You Posted Your OSHA 300 Yet?

Have you posted your OSHA 300 yet? All gins should have the OSHA 300 forms posted in a conspicuous place by now. These forms are to be put up no later than February 1 each year and stay posted until April 30. If you haven’t gotten it up, now is a good time to get it done.

The OSHA 300 is the annual summary of injuries and illnesses at a business. All recordable injuries for calendar year 2012 are to be in the log and the summary posted. This is one of the most commonly cited OSHA violations each year and should be one of the easiest to avoid.

The 300 log can be downloaded from the OSHA site at www.osha.gov/recordkeeping. Before posting the form, make sure it has been reviewed for completeness and signed by a responsible individual. The instructions for the form are included when you download the 300 as well as on the cite itself. You only need to post the form, not send it in to OSHA normally. If you receive a written request to send OSHA a copy of your data, please let us know. Only a few gins get selected to report each year.

Don’t hesitate to call Barry or myself if you have questions about this posting and recordkeeping.

OSHA Activity On the Rise

We have mentioned on this blog before that OSHA is getting more active and more activist when it comes to fines. The cotton industry has not been immune to these increased fines. Our sister organization, the Southern Cotton Ginners, has recently mentioned,in their newsletter, that two gins in the Mid-South have been fined at levels we are not used to seeing…even for OSHA.

In their article, they listed six citations at these two gins with proposed penalties. First, a knock-out grommet missing from an electrical box carried a Continue reading

Annual Injury and Illness Summary Posting

It’s that time of year again. Time to post the summary of the injuries and illnesses your employees may have had this year. The OSHA 300A annual summary must be posted by February 1. It’s a good time to make sure you have a current 300 and that it is filled out correctly.

There are a number of companies that will help you with it but the summary is not that difficult. Your requirement to log all injuries and illnesses can be a bit complicated but the form OSHA 300 which can be found at http://www.osha.gov/recordkeeping/RKforms.html has all the instructions to fill the information out correctly.

Continue reading

OSHA Starts SBREFA Process on I2P2

It’s alphabet soup time again… or at least it feels that way. The Occupational Safety and Health Administration (OSHA) has just announced the formation of a Small Business Regulatory Enforcement Fairness Act (SBREFA) panel to review the Injury and Illness Prevention Plan (I2P2) rules that have been proposed by OSHA last year. This is an important development because, although the rule has been in development over the past few years, we knew it wasn’t going to move forward until this process has gone forward. Continue reading

>OSHA Getting Set for I2P2

>OSHA is in the beginning stages of drafting yet another new rule. The Injury and Illness Prevention Program or I2P2 would be a rule that requires businesses to provide a safety program that is specifically tailored to the hazards onsite and has certain criteria that each program must meet.

This idea has been around for a long time and was last brought up several years ago. We, honestly thought the issue was dead but has gained new life recently. The OSH Act (Law) already says employers must provide a safe workplace. That law is known as Sec. 5(a)1 or the “General Duty Clause”. “…employers must provide a workplace that is free from recognized hazards that are causing or likely to cause death or serious physical harm…” This clause is a catch all that many gins are already familiar with.
The General Duty Clause is used any time a specific OSHA standard doesn’t directly apply but someone still got hurt. It hasn’t been used as a catch-all for general inspections until recently. Nevertheless, OSHA is beginning to gather information to draft a new catch-all type rule to require a safety or I2P2 program for employers. This could likely end up being just more piling on for citations.
Do we think safety programs are important? SAFETY PROGRAMS ARE EXTREMELY IMPORTANT. The best way to prevent accidents is to develop a comprehensive program that inventories all hazards and eliminates the hazard or eliminates exposure to the hazard. That is already implied in current law and new law is not necessary in my opinion.
Southeastern Cotton Ginners, as do most of the other ginner associations, already has a very good safety program that is easily adapted to your operation. We’re happy to work with you in implementing it at your facility we just don’t want another way for OSHA to write our members up if they don’t cross every T and dot every “i”.
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>Combustible Dust in a Gin?

>Just over 2 yrs ago an area near Savannah, Georgia was rocked by a large explosion and fire at the Imperial Sugar facility. The ultimate cause of the explosion where several employees died was the apparently harmless dust that had accumulated in many places in the plant. That dust when, suspended in the air, became extremely explosive.

As a result of that one incident the focus was put on all industries that can generate dust. The first agency to make issue with combustible dust was the Georgia Fire Marshall’s office. Insurance Commissioner John Oxendine took the first swing at regulating dust in industrial facilities. That process hasn’t been completed but about the same time, Congress began to look into combustible dust and hearings started into a federal law that would govern combustible dust. In the mean time, OSHA has decided to look at combustible dust.

OSHA already has precedent in working with combustible dusts. All grain handling facilities have been subject to rules on dusts for nearly 30 years. Those rules speak a great deal to housekeeping and reducing accumulations of dust in the various parts of an elevator. These rules were developed in response to a rash of grain dust explosions in 70’s and early 80’s. It was developed with the joint work of industry and OSHA and has been hugely successful. Injuries and deaths from grain dust explosions in covered facilities has dropped to nearly zero thanks to those regulations.

The first outlines of a new OSHA rule dealing with combustible dusts is a very broad reaching rule that any facility that has any dust accumulations ,regardless of agriculture or general industry, would be subject to. OSHA officials have held a number of listening sessions across the country over the past several months and we are awaiting the next draft. After attending one of those sessions, I can say it appears they are going to rely heavily on the National Fire Protection Association (NFPA) for guidance. NFPA has had standards in place as part of the fire code and OSHA may bring those regulations in as OSHA regs or they my write their own. We’ll have to wait for a proposed rule to find out.

In the mean time, cotton gins certainly have dust but we’ve never had an explosion in a gin. Fires are much rarer than they used to be in fact. Nonetheless, it appears that OSHA could specifically include gins in this new regulation because of a mis-identified fire in California a number of years ago. An incident was called an explosion and it was just a lint fire. If OSHA uses similar reports to define the scope of the new rule, we could indeed be brought in under it.

So where does that leave us? At the Beltwide Cotton Conference this year, attendees heard that tests performed at Texas A&M showed that dusts found around a gin would not support combustion at any concentration. Southeastern Cotton Ginners Association joined with the National Cotton Ginners and others in writing comments asking that this information be considered and that gins be excluded from the scope of any new rule that is developed. We are attempting to get the report in CA changed and other measures to attempt to stay out from under this unnecessary and potentially burdensome regulation.

We’ll be monitoring OSHA for more information and expect movement sometime this summer.