OSHA Finally Clarifies Online Injury and Illness Reporting Rule

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“The U.S. Department of Labor’s Occupational Safety and Health Administration today proposed a delay in the electronic reporting compliance date of the rule, Improve Tracking of Workplace Injuries and Illnesses, from July 1, 2017, to Dec. 1, 2017. The proposed delay will allow OSHA an opportunity to further review and consider the rule.
The agency published the final rule on May 12, 2016, and has determined that a further delay of the compliance date is appropriate for the purpose of additional review into questions of law and policy. The delay will also allow OSHA to provide employers the same four-month window for submitting data that the original rule would have provided.“- OSHA NEWS RELEASE
PMPA noticed an unannounced posting on the OSHA website which we captured and shared with our members May 31:

On June 27, OSHA issued a news release quoted above.
While it took OSHA 27 days to issue a news release AFTER we noticed their website posting, they are offering the public only until July 13, 2017 to provide comments.
Here are some bullet points from our testimony back on January 9, 2014:

OSHA has not provided any reasons to show how making this previously confidential information public will advance worker safety;
OSHA has shown no public purpose to justify the increase in the reporting frequency to quarterly;
The creation of quarterly reporting merely provides OSHA with another means to find employers to be not in compliance with yet another paperwork requirement;
The proposal removes the presumption of privacy rights from the employer and employees whose data and information would be reported;
We disagree with the presumption of this proposal that data shared for statistical and regulatory purposes should be broadly disseminated and made publiclly available to third parties who have no regulatory need for that data;
Employers are mandated by the federal government to protect the privacy of health related information of employees in our records, yet OSHA will use this rule to publicize to the world the injury or illness status of our employees;
But most seriously, the way that this proposal has been explained places the credibility of OSHA on the line: telling employers that“The proposal does not add any new requirement to keep records, it only modifies an employer’s obligation to transmit these records to OSHA” is disingenuous at best when the proposal in fact removes the privacy of the employers’ data and changes its status from confidential to publically accessible. Telling us that ‘nothing has changed,’ when in fact the agency’s intent is to remove privacy status of employer reported information and publish those details online is not telling the whole truth.

We’ll be reiterating these and some additional points in our comments, but by all means, feel free to weigh in on your own.
Try this link Injury and Illness Comments
Is public shaming of employers is the REAL agenda, or is it just about using the power of regulatory agencies to bully? What is the regulatory need for public online posting? No one will be any safer because these records are posted on the internet.
Department of Employer Shaming

Good News From OSHA Spring Regulatory Agenda.

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The U.S. Department of Labor ~~finally~~ recently published its 2013 Spring Regulatory Agenda. Despite the extra time, a number of dates are still shown as “00” or undetermined / to be determined.

But hey, at least they’re not handling our healthcare…

It's not like they should be held accountable to deadlines like they do us, right? — It’s not like they should be held accountable to deadlines like they do us, right?

But tucked in the 67 pages of Spring Regulatory Agenda we found good news regarding two items affecting our precision machining industry.

Item 1, Cooperative Agreements

According to the Regulatory Agenda, OSHA has “withdrawn” RIN # 1218-AC32, effective 07/00/2013, (whatever “00” means) which would have-

eliminated exemptions from inspections for companies regardless of participation in Safety and Health Achievement Recognition Program (SHARP) exemption status;
allow Compliance Safety and Health Officers to proceed with enforcement visits resulting from referrals at sites undergoing Consultation visits and at sites that have been awarded SHARP status;
limit the deletion period from OSHA’s programmed inspection schedule for those employers participating in the SHARP program.

I guess someone figured out that there would be no incentive at all for companies to participate in these programs if their was no employer benefit at all.

Item 2, Revising Record Requirements in the Mechanical Power Press Standard

The other good news item in the Spring Agenda was the notice that OSHA is Revising Record Requirements in the Mechanical Power Press Standard, RIN: 1218-AC80. Notice of proposed Rulemaking (NPRM) and Direct Final Rule dated 07/00/2013:

“As part of the Department of Labor’s burden hour and cost reduction initiatives, OSHA will examine revoking requirements for employers to prepare and maintain periodic records certifying that the employer performed the required tests and inspections on machinery. The purpose of revoking these records is to minimize paperwork burdens imposed on employers. Recently, OSHA revoked requirements that employers develop and retain training records for a number of standards when the revocation did not adversely affect worker safety and health.”

The other 8 OSHA items have potential major impact on our shops. We’re analyzing them for reporting to our members.

We call our attention to regulatory issues “PMPA Regulatory Assurance.”

Who is working on this for you? Where do you go for OSHA regulatory guidance? Are your HR people proactively working these issues?

Thanks to EndUserSharePoint for the photo

Dodd Frank Section 1502 Conflict Minerals Guidance for Machine Shops

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PMPA staff has prepared a Conflict Minerals compliance guide for our members based on our analysis and understanding of the SEC’s final rule.

That’s 356 pages worth of time we won’t be getting back- but that we can save you!

Saving you the pain... — Saving you the pain…

Our two page summary provides

a link to the final rule;
an overview of the potential impact of the rule;
explains the SEC’s determination of what constitutes “Conflict Minerals” as applies to our precision machining shops;
clarifies the “necessary to production question” that concerns many people. (If the conflict minerals are in my shop’s tools, machinery, or computers, do they need to be reported?)

In addition to identifying the 4 focus minerals that are encountered in our industry, our report provides 5 questions to help you make sense of and formulate your reply to each job and request for documentation from your customers for Conflict Mineral Status.

Finally, our document provides both the means to determine and suggested language to warrant that your product is “DRC Conflict Free” to your customer.

Effective associating through PMPA means that our members get a clear plain English tool they can use document to make sense of their obligations under Dodd Frank. And guidance on how to respond and educate your customer.

Where do you go to get sensemaking on newly emerging regulatory requirements?

PMPA members know that we provide them with REGULATORY ASSURANCE.

PMPA provides assurance to you in the high stakes world of regulatory compliance.

Our diligence on identifying regulatory issues and sensemaking on regulations help PMPA members assure compliance and avoid draconian penalties. And we provide tools they can use to respond effectively and confidently minimizing the impact and burden their shop.

That is Effective Associating!

Where do you go to get sensemaking on newly emerging regulatory requirements?

Not a PMPA member? Call Jeff Remaley 440 526 0300

Highwire