In this week's episode, Sheldon goes over tips and tricks for OSHA recordkeeping, reviews the OSHA upcoming regulatory agenda changing the recordkeeping rule, and reviews the OSHA resources for injury and illness tracking. You can also get more help with OSHA recordkeeping with the online course:
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[00:00:19] spk_1: Well, welcome to safety consultant podcast. I'm your host, Sheldon Primus. This is the podcast, right? I teach you the business of being a safety consultant. Talk about OSHA compliance and a whole bunch of other stuff to help you with your business and to get you going with this safety stuff. Well, welcome to another week of the safety consultant podcast. Want to thank everybody for being part of the show. You guys rock. I am going to, you're gonna hear some typing in the back, that's me and my nice loud, the world's loudest keyboard. So I am going to do what I've been doing the last couple of days on episodes, not days episodes. Let's go ahead and see who's with us. Alright, so I'm going to do the demographics. I did not do the demographics like per state because I figured it's going to be a lot if I were to like do like province and states and cities and everything else. So I have not been doing that, but I've been doing regions. 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It's an easy one. Safety consultant with Sheldon Prime Minister. Just tell anybody that you did here, just go ahead and look up and wherever they listen to podcasts and then they could go ahead and download the episode and subscribe even better. Alright, so thank you everybody, you guys are like, like the dream team of fans and the dream team of support. I just completely appreciate everything that you do. Thank you. Thank you very much. So, this episode, I'm actually gonna do my annual Ocean recordkeeping episode, as you can tell by the title. I try to do this each year because US in safety, especially in the US because this is only compliant in the US. Uh we have this timeframe in february, getting into um March where there's a bunch of things happening for recording of injuries and illnesses that is going to be required by the occupational safety and health administration. So right around february and March. And for those of you doing business with us in the uh in the US during this time period you may see your emails getting a little bit later and all of a sudden we're not responding to you right away like we should uh it's because this time period in the U. S. Um cycle for injury and illness recordkeeping. Not everybody has to keep injuries and illness records. So if you're doing this first and foremost and I'm gonna digress a little first and foremost, make sure that you actually need to keep records of injuries and illnesses because it is a establishment thing, not a firm thing, the firm is your full company. The establishment is a specific location. So let's say you have a location where there's an administration only, then that location, that establishment is exempt from record keeping. So you might help yourself out by lowering your reducing your paperwork by maybe moving uh your administration building to one particular establishment and maybe have support at your satellite offices. But you do have a main administration building and then you're gonna take yourself off of one establishment right there that you're not going to have to do paperwork for. So if you're not sure if your company is exempt or not, you want to go to the record keeping rules which is going to be 1904, That's the code of code of federal regulation number 1904, and you're gonna be looking for subpart B and you want appendix A. So when you get there, you're going to see a list of different types of organizations that are exempt from OSHA recordkeeping, those of you that are online. Yeah. You guys all know the rules. Everybody knows the rules. You cannot be looking up anything when you're driving. Okay? No, good. Cut it out. You're gonna do you're listening now and then when you get home, then you're going to go ahead and do all this stuff that you need to do regarding following websites that I give you. So, here's the website for record keeping on the OSHA site. OSHA dot gov forward slash recordkeeping. So OSHA dot gov forward slash recordkeeping. When you get there. This is kind of like a hub for record keeping. You can get a lot of information here. Uh I'm going to point your attention right down to scroll down to the page and on the bottom right, you're gonna start seeing near the the foot, I guess it's a footer, but above the footer where it's still in white, you're going to see uh little mini columns down there and one of the columns are gonna have heading cassettes. Training, there is a training power point that is there for record keeping. That is open source. It's right there for you guys to use and to to have available for your references. It's open to everyone. You know, if you use this guideline in your country, then go ahead and OSHA dot gov forward slash recordkeeping. Bottom right corner scroll all the way down. You're going to see training section and you could select training presentations and that's going to take you to a presentation of how to navigate, excuse me, how to navigate uh the 1904 rules. So go one column next to that and you're going to see where they say related documents and information. Um in that column, again, this is going to be on the OSHA dot gov recordkeeping page. So forward slash recordkeeping. And as you go down towards the bottom of the page, you're gonna see four little columns. One will say form, one will say requirements, one will say related documents and information and the other one's training. So we're on related documents and information. You guys really need to look at that. Um that section real closely because you'll see news releases there. There's information with updates in the federal register. Uh there's wording in their documentation is a hyperlink is really what it is. A hyperlink leading you to OSHA's documentation regarding employer safety incentive programs and d incentive policies and practices. So that's important to OSHA. If you're doing any kind of safety incentive and it's gonna de incentivize the workers from being proactive towards safety and it was a lot of words. So what I really mean is uh you may have some safety incentive programs that will say, if we get to a certain amount of days without an accident, I'm going to reward you. That is not an incentive that dis incentivizes people from reporting system, uh, incidences or even situations where there's hazards because they want to get to that caveat. So OSHA has policies on that and then right underneath that you'll see compliance directive and there'll be a CPL number. CPL just means compliance letter 2-001 35. So what that compliance letter is, is a letter for the compliance officer's whenever they're doing a record keeping inspection, this is their guidance. So that compliance letter will show them how to conduct a recordkeeping inspection. So it's good for you to know that as well. And then the other thing that you're really gonna need to know for record keeping, which is, its not really obvious, but you're gonna need to know your organization's codes that they operate under in North America. We will have in Canada Us and Mexico the same coding system. It's a six digit code called the North american Industry Classification system code that's six digit code uh, was evolved from the standard industrial Classification code. That was a four digit code. So if you did construction, you would get a four digit code that says you did construction. If you do underground construction in the, you're doing piping for secondary elementary or something like that. You will get a special two digit attached to your construction code to prove your specialist in the field in your product. So that also will mean the data related to that code is going to be special to your organization. Not to your organization is to say to your industry. So now OSHA will start getting industry profiles by that any I. C. S. Code. But that code is also going to be important for you to see regulatory activity and all kinds of stuff. But the code is going to tell you if your establishment has to be on record keeping or not. And the code is also going to tell you if you're one of these unique cases with electronic record keeping that have 20 people to 249 people in a high hazard. N. A. I. C. S. Code. You're going to be required to do electronic recordkeeping along with the larger companies which are over 500. Um They're gonna end up needing to do Record company is recordkeeping as well. I say 500 I think I probably just that's a 500 I meant to 50 or more. No Y 500 stuck in my brain. Anyway. Uh right now it's compliance deadline for the U. S. With the um Well one thing is they're posting a form called a 300 a form. This is a form that's a summary of all the injuries and illnesses from last year. You got to post it in a place where people could see it and in the U. S. They're keeping it up from february 1st. And at the time of this recording is february 22nd. So this thing has been up for a couple of Weeks by now and then you take it down. I I always say day first just to make sure you're in compliance. But the last day it's required to be up is April 30. So, some people on, you know, the end of their work day, April 30 will pull down that, uh, that summary log of injuries. Hey, first, what's one more day gonna hurt? Right, come on stay in compliance. Just one more day anyway. Uh, that is going to be the requirement there. Um, there is a proposed rule coming up. The open comment period is closed for this one. So this year, I'm doing something a little different than I normally do with the recordkeeping. I'm gonna give you guys a reading of the proposed rule. So you don't even have to go to this one. But this isn't what we call the regulatory agenda. So that just means for OSHA. And there's many organizations in the federal government that has regulatory agendas, actually, all of them. But OSHA's regulatory agenda under the Department of Labor their planning a change in this change Came in the fall 2022 actually, before. But it was also in the fall 2022 regulatory agenda. Unified agenda is another name for it. It's just what ocean is planning. That's really what it means. So here's the announcement, if you will. And I find it really interesting. That's why I'll read this one to you guys. In 2016. OSHA finalized a rule which, among other things, required certain establishments to electronically submit certain case specific injury, injury and illness information to OSHA each year. And that was in 2016 in May, approximately three years later, the agency rescinded the requirement to submit the specific case specific information. And that's 2019. So you can see that there's been some, some political issues for us in the US between that time frame. So you can see that, uh, there there was influence as I could tell in this. So here we are, seeing some more written down says on March 30th 2022 OSHA published a notice of proposed rulemaking which would amend the occupational injury and illness recordkeeping regulation to again, requires certain employers to annually electronically submit injury and illness information. So therefore, OSHA's going back to their original intent for the electronic recordkeeping rule, which was watered down. The intent of the original rule is what they're about to do right here. They actually changed it up a little in the intent and what I'm reading again is the regulatory agenda. This is what OSHA is trying to do in the future. And this is specifically on record keeping. So they go on in here and again, this is why I find it interesting. This is what they're going to. The new rule is going to be specifically, OSHA proposed to amend its regulation to require establishments with 100 or more employees in certain designated industries. And that's probably going to be the same designated industries that they have right now, with that list that OSHA has on the record keeping page that are hazard high hazard industries. So, I'm imagining it's going to be that same list, but now, instead of 20 workers is going to go up to 100 100 or more workers. So that might be what I'm thinking here. But let's read on. So, uh Under proposal, establishment or 20 or more employees and certain industries will continue to require to electronically submit information from their 300 a form. So, okay, so I guess it is going to be the 20 more, but then there's gonna be another uh grouping of 100 or more employees. Uh let's see, OSHA also proposed to update the classification system used to determine the list of injuries covered by the electronic submission requirement. Okay, so there we go, we just figured that out that they are going to update the list of industries. So that's that's what that 100 looks like in there. And let's see. Finally, OSHA proposes to remove the current requirement for establishments of 250 or more employees in a designated industry to electronically submit the 300 a form to OSHA on an annual basis. So that's good. So that means there'll be less regulation for some companies. And then they're just gonna look for specific high hazard companies in the new rule. So that's not bad at all. That's like the, um, that's a good way of putting it. Unfortunately, OSHA is political. So, um, right now it may work, but if there's a change in administration from democrat to Republican, things will change and vice versa because that's just the way OSHA operates in the US. So right now, I'll tell you guys keep an eye out on the record keeping role. Keep an eye out for the regulatory agenda and he should be okay. Just kind of check back with OSHA and the recordkeeping page, OSHA dot gov for slash record keeping. And that's going to help you out. If you need some more help with record keeping, I have a course that I did a while back and I keep updating it. So you will always have any of the courses that you get for me, anytime I update the courses you get your update because it's going to be a lifetime. So if you need help with record keeping, go to OSHA dot coach, OSHA dot coach, that's me. So OSHA dot coach, you can see the record keeping class if you have trouble with that domain, that's okay, You can go to primus dot training. So OSHA dot coach. Primus dot training and you can get the record keeping class and uh just go ahead, sign up for that class, Register for it now, you'll have it for life and any time I update, update the class, especially when we get this new update from OSHA, I'm kind of waiting for that and then I'm going to update everything up to match the newest and latest. So there you go, OSHA dot coach Primus dot training. I want to thank everyone for being part of everything. You guys have been awesome to me. I truly appreciate all of you listening to the podcast and sharing it with friends and liking and subscribing to the podcast for those of you who have not been on safety consultant dot tv. That's the TV product that I have. A video on demand subscription service, use code SC- 101 at checkout and you'll get 30 days free and you can actually see some of the podcast interviews as well as you're going to get information, how to run your business. 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[00:21:19] spk_0: This episode has been powered by safety FM. The views and opinions expressed on this podcast or broadcast are those of the host of its guests and do not necessarily reflect the official policy or position of the company. Examples of analysis discussed within the past hour are only examples. They should not be utilized in the real world as the only solution available as they are based on very limited and dated open source information, assumptions made within this analysis are not reflective of the position of the company. No part of this podcast or broadcast may be reproduced stored within a retrieval system or transmitted in any form or by any means mechanical, electronic recording or otherwise. Without prior written permission of the creator of the podcast or broadcast. Sheldon Primus.