Osha top 10 issues for 2015 what everyone should know
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This document provides a summary of the top 10 things to know about OSHA regulations and guidelines in 2015. It covers requirements around injury reporting, inspections, employee interviews during inspections, common citations, the Global Harmonization System for chemical labeling, asbestos regulations, an employer's general duty to provide a safe workplace, multi-employer worksite liability, protections for self-audits, and information on OSHA whistleblower complaints. The summary was presented by Thomas Benjamin Huggett of Littler Mendelson law firm.
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Osha top 10 issues for 2015 what everyone should know
- 1. OSHA Issues and Update: Top 10 Things Everyone Should Know About OSHA in 2015 Presented by: Thomas Benjamin “Ben” Huggett January 2015
- 2. www.osha.gov Thomas Benjamin Huggett Littler Mendelson, P.C. 1601 Cherry Street Philadelphia, PA 19102 tbhuggett@littler.com (267) 402-3035 Presented by: Official Resources and Text
- 3. 1. Injury and Illness Reporting and Recordkeeping • Must directly report to OSHA – Within 8 hours • All work-related fatalities – Within 24 hours • All work-related inpatient hospitalizations of one or more employees • All work-related amputations • All work-related losses of an eye • Employers must record work related injuries and illnesses that meet a specified threshold criteria. – Basic First Aid cases are not recordable • Posting Form 300A – Signature • Safety Incentive Programs
- 4. 2. Inspections • OSHA does not have the right to conduct random inspections! • OSHA is being aggressive, but they must have Probable Cause to conduct an inspection. • Complaint • Referral • Fatality/Catastrophe • Neutral Program – National Emphasis Program – Local Emphasis Program
- 5. 3. Interviews & Walkarounds • Interviewees have rights – Hourly employees – Management employees – Audio or Video taping is not mandatory – Written statements are not required • Representation During Walkaround Inspection
- 6. 4. Top 10 OSHA Citations https://www.osha.gov/Top_Ten_Standards.html
- 7. 5. Global Harmonization System • It’s not that scary. Effective Completion Date Requirement(s) Who December 1, 2013 Train employees on the new label elements and SDS format. Employers June 1, 2015* December 1, 2015 Comply with all modified provisions of this final rule, except: Distributors may ship products labeled by manufacturers under the old system until December 1, 2015. Chemical manufacturers, importers, distributors and employers June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers Transition Period Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors and employers
- 8. 6. Asbestos • 1910.1001(j)(3)(i)Building and facility owners shall determine the presence, location, and quantity of ACM and/or PACM at the work site. Employers and building and facility owners shall exercise due diligence in complying with these requirements to inform employers and employees about the presence and location of ACM and PACM.
- 9. 7. Self Imposed Obligations and the General Duty Clause • Section 5(a)(1) of the OSH Act requires that “[e]ach employer...furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm...” • Company safety programs can establish additional liabilities if not carefully considered
- 10. 8. Multi-Employer Worksite Liability • Multi-Employer Worksites – Step One. The first step is to determine whether the employer is a creating, exposing, correcting, or controlling employer. – Step Two. If the employer falls into one of these categories, Step Two is to determine if the employer’s actions were sufficient to meet its obligations.
- 11. 9. Self-Audit Protections & Responses • OSHA will refrain from routinely requesting reports of voluntary self-audits at the initiation of an enforcement inspection • OSHA will refrain from issuing a citation for a violative condition that an employer has discovered through a voluntary self-audit if employer has corrected condition before the inspection and has taken steps to prevent recurrence • Privileges may protect audits
- 13. Questions?