With the start of the New Year, there are a few annual requirements that might be coming due, as well as many things to think about in planning the year.
The first thing companies should be thinking about is their OSHA 300 & 300A log forms. Throughout the year employers are required to keep Form 300 updated with recordable injuries and illnesses. At the beginning of each year the line items from the Form 300(s) are added up and transferred on Form 300A, along with a few other pieces of information about the company. The Form 300A is required to be posted starting February 1st, and cannot be taken down until after April 30th. This form is required to be posted in an area employees can easily find it and review it if desired, typically a break room or common area.
One thing people often forget is that all injuries and illnesses that get recorded on the Form 300 need to have an incident report. OSHA has the Form 301 available for documenting these incidents, though alternative incident reports can be used provided they are at least equivalent to the Form 301.
In addition to the Form 300 & 300A, employers should be thinking about when they need to conduct their annual hazard assessment. This is often referred to as the “PPE hazard assessment” because the requirement to perform the hazard assessment is found under OSHA’s PPE (personal protective equipment) standards. This is a common misconception, though, because the employer is required to assess more than just PPE requirements. Each year, employers are required to perform a documented assessment of the hazards in the workplaces employees might be exposed to. This assessment should look for all forms of uncontrolled hazards in these workplaces. Employers should then evaluate these hazards to determine what hazards can be controlled through elimination, substitution, engineering controls, signs/warnings, administrative controls, and lastly PPE (in this order).
Another consideration for employers at the start of the New Year is conducting their annual review of their policies. Many policies, such as control of hazardous energy (lockout/tagout), bloodborne pathogens, and respiratory protection, specifically require employers to review the p[policy annually. While many policies do not specifically require annual reviews per OSHA regulations, it is common practice to review all policies annually.
The start of the year is also a great time to start planning training throughout the year. OSHA requires several topics be trained on annually, such as access to employee exposure and medical records, HAZWOPER, noise exposure, or PPE. Some industries require annual training on topics, such as Hydrogen Sulfide training for oil & gas operations. Other topics require training every 2 -3 years, such as CPR or forklift operations. Often times covering all the training that is required in a year does not happen because employers fail to plan. The beginning of the year is a great time to get these trainings on the books throughout the year before the calendar books up.
A final reminder is to conduct reviews of required paperwork. Permit required confined space entry specifically requires permits to be reviewed at least annually. JSAs, incident reports, and work permits may not have a legal obligation to be reviewed, but it is common industry practice for employers to review these forms as well to ensure they are being utilized accurately, and to communicate issues with their staff.
For help with any of these issues or other safety issues call CS Consulting at 307-235-9112 or use the contact form on the right side of any page on this website. CS Consulting can help with making sure annual OSHA forms are completed, that incidents are investigated and recorded, that policies are developed and reviewed as necessary, provide training on most topics throughout the year, assist with reviews of forms and paperwork, and much more.
*Unless specific citations are shown, all answers are based on interpretations provided by authorized officials. As such, all information is deemed reliable, but not guaranteed.