Injuries and illnesses should be recorded on only one employer’s injury and illness log. 29 CFR 1904.31(b)(4).
In most cases, the host employer is the one responsible for recording the injuries and illnesses of temporary workers. According to OSHA Release, injuries to Temporary workers go on the host employers’, not the Temp Agency’s OSHA 300.
OSHA has released a new educational bulletin for staffing agencies and host employers on current requirements for recording injuries and illnesses of temporary workers. The new Recordkeeping Bulletin (PDF*), which is part of OSHA’s Temporary Worker Initiative, addresses how to identify which employer is responsible for recording these work-related injuries and illnesses on the OSHA 300 log.
“The Recordkeeping Bulletin is the first of many materials we are releasing and helps clarify which employers are responsible for reporting injuries and illnesses,” said Dr. David Michaels, assistant secretary of labor for occupational safety and health. “These materials will provide valuable information for both host employers and staffing agencies on how they can work together to make sure their workers are properly trained and protected.”
The temporary worker Recordkeeping Bulletin helps businesses determine which employer is responsible for recording work-related injuries and illness on the OSHA 300 log. For more information, read the news release and visit OSHA’s temporary worker page.
Guest post by Jon Holbrook, PMPA member company North Easton Machine Company
The industry today is a buzz with the need for qualified workers. Low cost energy here in the United States combined with our ability to manufacture some of the highest quality products in the world are creating a bit of a “perfect storm”. This perfect storm of economic conditions is leading to a second industrial revolution in this country.
We are seeing a resurgence of many of the industries that only a few years ago were leaving the US in droves. This is not my father’s (or his father’s ) Industrial Revolution!
My father sharpened his own tools by hand on a bench grinder by eye.
He made fine adjustments on production equipment with a wrench and the tap of a ballpeen hammer.
He used “Speedi Dri” to soak up the oil that no matter how hard he tried could not seem to be contained to the machine.
Today we have a high tech industrial revolution! Digital and optical technologies are routine, as is the use of trig and geometry every day.
Today’s machinist uses disposable insert tooling, punches offsets into a computer and programs equipment using CAD models and 3D simulation programs.
All this in an environment that is closer to a climate controlled laboratory than the shops of the last century. @ Key questions:
How do we train the worker of tomorrow to be successful in manufacturing in the 21st century?
Equally important, how do we re-train today’s workers to meet the needs of manufacturing in America today?
While I am unable to offer a perfect solution to these issues, our company, North Easton Machine, is doing our part to hire the long term unemployed and re-train them for a rewarding career in the field of manufacturing. Our company was just awarded a “Hiring Incentive Training Grant.” We have confidence in the future of North American Manufacturing, just as my father did years ago. We are working diligently to make it happen. What can you do to help meet the challenges that we as North American Manufacturers face today?
We were pleased to be quoted in the weekend edition of the Wall Street Journal in an article by Tim Aeppel titled Feds Try Redefining Manufacturing.
Our initial post on Factoryless Goods Producers was cited in the article. It’s like manufacturing, except without us actually making anything.
The issue is that federal agencies are trying to redefine “Manufacturing” to recognize “Factoryless Goods Producers” as Manufacturers. If you don’t actually make something- how can you be considered a Manufacturer?
If you contract to have some company in a foreign country make your product, why should you be credited as manufacturer and why should US get balance of trade credit for being the manufacturer? We think that definitions ought to be honest.
Manufacturing is actually making things. not designing them, ordering them, or buying them from another company.
We think that manufacturing ought to be credited where the making things actually happens. Apple designs and sells some really cool electronics- but the manufacturing is not done in the US.
Why would we want to let US companies claim to be manufacturers when in fact they don’t make the products in the first place, and often have them made overseas where the operations are not governed by US legal protections for labor rules, safety, environment?
Deceiving consumers and the voters with fraudulent numbers is what this about. It’s not about reacting to globalization. It is about counting the hollowing out of US Manufacturing as actually manufacturing.
Yet no new employees are hired.
No new assembly lines or factories are built.
No new payroll taxes are being paid.
Manufacturing is about making things.
If you don’t actually make it, you aren’t a manufacturer.
Sorry if that offends you.
You may be a great designer. Broker. Outsourcer. Wholesaler, Distributor. Whatever.
But you aren’t a manufacturer unless you actually make things. Read Tim Aeppel’s WSJ Story What is manufacturing? He’s Lying Photo Credit
Consensus expectations were for 149,000 new positions to be added in February 2014. BLS announced that the economy added 175,000 jobs in February, up from 129,9000 in January.
Despite all the “Beat expectations” headlines we have seen on the news, we are not impressed. 175,000 new jobs added? We need 350,000 jobs EACH month. NOT impressed. Here’s why:
The U-3 Headline unemployment rate actually increased to 6.7 percent while the Labor Participation Rate remained steady.
The U-6 unemployment rate (un- and under- employment) was 12.6 percent
One in six men between ages 25 and 54 are jobless
“The economy needs to add about 350,000 jobs each month to push unemployment down to an acceptable level.”-Dr. Peter Morici, University of Maryland
Beat the consensus? That isn’t even critical thinking.
Good news- Our last PMPA Business Trends Report showed that “Ninety-eight percent (98%) of respondents expect employment prospects to increase or remain the same in our industry over the next three months.” Photo
Employee safety is a responsibility of all of us- employers, employees, and even the regulators. We are puzzled as to why OSHA fails to enforce its existing rules on fixed ladders to protect the safety of Communication Tower Workers and Wind Generator Workers.
1910.1053 (a)(19) could have saved these lives
Four communications tower related deaths have already occurred in 2014 according to OSHA, and more were killed in 2013 than in the prior two years combined. “Every one of them was preventable“- OSHA March 4 Quick Takes.
“We are very concerned about this sharp rise,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels in a Feb. 25 message delivered to the National Association of Tower Erectors. “The fatality rate in this industry is extraordinarily high—tower workers are perhaps 25 times more likely to die on the job than the average American worker.” OSHA Press Release In my problem solving practice, I ask three questions to get our remediation steps off in the right direction:
Is there a process?
Is it being followed?
Is it effective?
Lets see how this can be used to frame the 21 needless tower deaths in the U.S from 2011-2013.
Is there a process? (In the OSHA case at hand, this might better be framed as “Is there a regulation that addresses this?”) Is there a regulation?
YES! OSHA has a fixed ladder regulation on the books: 1926.1053(a)(19)
1926.1053(a)(19): Where the total length of a climb equals or exceeds 24 feet (7.3 m), fixed ladders shall be equipped with one of the following:
1926.1053(a)(19)(ii): Self-retracting lifelines, and rest platforms at intervals not to exceed 150 feet (45.7 m); or
1926.1053(a)(19)(iii): A cage or well, and multiple ladder sections, each ladder section not to exceed 50 feet (15.2 m) in length. Ladder sections shall be offset from adjacent sections, and landing platforms shall be provided at maximum intervals of 50 feet (15.2 m).
Is the regulation being followed? Great question. How many of the tower deaths involved workers working on ladders that were in compliance with 1926.1053(a)(19) (i) (ii)(iii)? Is this regulation effective? Not if it isn’t being enforced. Safety of the people and processes under our authority is our greatest responsibility.
Why aren’t the fixed ladders on Communications Towers and Wind Generators held to the same fixed ladder safety requirements as those in general industry?
Why doesn’t OSHA use the existing rules on the books to stop the death toll in this industry?
This doesn’t require new technology. Just enforcement of the existing proven effective regulation already on the books.
When I testified at OSHA last month I was asked, “Why does industry always come in against rules? Why doesn’t industry come in and say that they are for rules?”
I think all of us are for OSHA using its existing enforcement authority to assure that everyone abides by the demonstrated effective ladder safety requirements of 1926.1053 (a)(19)(i-iii). I am certain that there are 21 families out there who would ask why their loved one wasn’t entitled to the same fixed ladder protections as everyone else in general industry seems to be. Why doesn’t OSHA enforce 1926.1053(a) (19) (i-iii)?
Use of conversion charts and factors to convert hardness values in steels is widely done and typically based on ASTM methodology. SAE Ferrous Materials Manual Lists ASTM E140 Standard Hardness Conversion Tables for Metals
In non-austenitic steels and alloys, ASTM Method E140 Standard Hardness Conversion Tables for Metals is the authoritative standard.
Conversion of values is only an approximate process, due to the different combination of material properties measured by each test;
Converted values are suitable for use in establishing Specification Limits;
Converted values are subordinate to actual test values;
ASTM Method E140 paragraph 1.12 Caveat:
”Conversion of Hardness Values should be used only when it is impossible to test the material under the conditions specified, and when the conversion is made, it should be done with discretion and under controlled conditions. Each type of hardness test is subject top certain errors, but if precautions are carefully observed, the reliability of hardness readings made on instruments of different indentation type will be found comparable. Differences in sensitivity within the range of a given hardness scale (Rockwell B for example) may be greater than between two different scales or types of instruments. The conversion of values, whether from the tables, or calculated from the equations, are only approximate and may be inaccurate for specific application.”
If your work requires a more detailed analysis of material hardness and correlation to mechanical properties, I recommend “The Mechanical Properties of Work Materials” by Dr. Edmund Isakov, published by Hanser Gardner Publications.
Manufacturing Sector continues to grow and strengthen in February according to ISM PMI index, confirming PMPA’s own January Business Trends Outlook. “Optimism in terms of demand and growth in the near term” – Bradley Holcomb, Institute for Supply Management
“The February PMI® registered 53.2 percent, an increase of 1.9 percentage points from January’s reading of 51.3 percent indicating expansion in manufacturing for the ninth consecutive month. The New Orders Index registered 54.5 percent, an increase of 3.3 percentage points from January’s reading of 51.2 percent. The Production Index registered 48.2 percent, a decrease of 6.6 percentage points compared to January’s reading of 54.8 percent. Inventories of raw materials increased by 8.5 percentage points to 52.5 percent. As in January, several comments from the panel mention adverse weather conditions as a factor impacting their businesses in February. Other comments reflect optimism in terms of demand and growth in the near term.”
Link here Markets the precision machining industry serves did well in February: Machinery; Plastics & Rubber Products; Transportation Equipment; Electrical Equipment, Appliances & Components; Fabricated Metal Products; Furniture & Related Products; Primary Metals according to the ISM release.
The PMPA’s January Business Trends Report was similarly upbeat with strongly positive indicators for Sales, Lead Times, Profitability and Employment. Over 59% of our reporting precision machining shops were scheduling overtime in January. The ISM PMI Report for February 2013 shows continued growth and strength in the manufacturing sector.
The ISM report confirms this statement with its report on commodity prices “No commodities are reported down in price.”
That pretty much validates the index…
The precision machining industry is generating strong sales and positive prospects going into calendar year 2014. Very strong sales and busy shops characterize the precision machining industry in January 2014 PMPA’s January Business Trends Report’s Index of Sales bounced back up to 126 from December 2013’s high for any December of 100.
January 2014 ‘s 126 was just 2 points shy of January 2013’s 128.
Precision Machining Businesses had a great month in January.
Outlook for sales remains positive with 87% of respondents expecting the level of sales to remain the same or increase over the next three months.
Profitability is expected to remain the same or improve by 93% of respondents.
Fifty-eight percent (58%) of shops scheduled overtime- 36% scheduled 45 hours or more. Get the full report here. Note: This report was our inaugural issue of the Business Trends Reporting using our newly updated secure, online reporting system. Effective with this move to the new system, we have established the year 2010 as our index base.
“With aerospace function and safety criticality, we absolutely need to know the status and location of every piece that could be considered a part. We have definitely upped our performance in the accuracy, flow and knowledge of status of “what’s in the bin.””-Tammy Wilson. Permac Industries recently announced that they were just awarded their AS9100 certification, on their first try. AS9100 Certification is required by many OEM’s in the Aerospace industry. Lots of Teamwork.
I asked a group of employees at Permac what were the unexpected challenges and what made their efforts work.
If you are a manager, you might want to jot a few of these down. Challenges
Weren’t able to foresee many of the additional requirements.
Weren’t able to understand the impact of some of these requirements on our processes;
Weren’t really expecting additional paperwork- Our previous experience with Quality System implementations were that they helped us lean out our paperwork;
Really had to embrace the Authority of piece count and build processes based on count.
Enablers of Success
We really did have the right people in place;
Those people had both the responsibility and authority to make the system and process improvements demanded by the AS9100 standard;
They had management support when the changes were difficult to implement
They felt that management was confident in their ability to make the changes.
Members of the team told me that
Having strong existing systems made their job easier- they didn’t have to reinvent anything.
They did need to tighten up procedures;
They did need to add some additional procedures;
They have focused more on supplier and production control
Congratulations to the team at Permac for getting this done right first time.
Do you have a success story to share?
Guest post by Robin Rutschilling, Clippard Instrument Laboratory, Inc. I am sitting at my desk preparing my day and this thought came to me, who trained you?
My mentors go back to the 1970’s working with my father in his sawmill which helped develop my work ethic and safety awareness.
As I progress 35 years I think about the key contributors along the way Tom Nelson, Lee Fuller, Bill Clippard and Bob Clippard….. the question that I am having trouble answering today is- Who am I training and am I helping people as much as my mentors helped me?
This morning, I am going to our local high school for a trades competition. Our shops need talent. http://www.ohioskillsusa.org/home.html
These students have worked diligently with their instructors and volunteers (mentors) to prepare for this competition.
I am thinking about what many of our shops need, and what they think about this young talent waiting to be guided in our shops. And even more importantly, what are they doing to develop their talent?
The first two things that come to my mind are Training and Education.
The PMPA’s Technical Program Committee has put together a program for our National Technical Conference that is focused on Training and Education!
This year’s conference is in Indianapolis April 5-8 and is going to be full of opportunities to TRAIN and EDUCATE our staffs. It is important to get your rooms booked by March 5th to take advantage of the $149 room rate. The prices will go up on March 6.
I am challenging myself to meet everyone in attendance at this conference. I would love to hear how you have been mentored and how you are making an impact on the people around you. Networking is part of the conference that I have gained the most from. Who trained You? Who mentored You? Who are you training? Who are you mentoring? If you love Manufacturing as I do, you will have answers to these four questions. “Education, mentorship and experience will take mediocre and make them good; will make the good great; and make the great world class!”- David Thuro
