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Environmental Health and Safety Blog | EHSWire

OSHA Recordkeeping Changes for 2015

Posted by Emilcott Associates

Dec 9, 2015 12:17:29 PM

The Occupational Safety and Health Administration’s (OSHA) recordkeeping requirements have been in place since 1971 (29 Code of Federal Regulations CFR Part 1904). The requirements were updated in 2002 to make it easier for employers to comply. OSHA has again updated the recordkeeping rule for 2015 to include two key changes.

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Topics: OSHA, OSHA Recordkeeping regulation (29 CFR 1904), health and safety, OSHA Compliance, Occupational Health, health hazards, occupational health and safety, reporting, Medical Records, OSHA Injury and Illness Recordkeeping and Reportin, OSHA 300A Annual Recordkeeping Summary Form, incident investigation

Hot off the Presses: HazCom 2012

Posted by Shivi Kakar

Mar 20, 2012 9:19:17 AM

OSHA has published the final rule updating the Hazard Communications Standard as of today 3/20/12.  It will be published in the CFR officially on 3/26/12, but is available online now through the OSHA website. View Rule Here

Secretary of Labor Solis and Assistant Secretary Dr. Michaels provided a press release conference call this morning where they indicated that the new standard will reduce injuries to employees, reduce costs for employers and allow US manufacturers to be more competitive in a global market.

There were a few questions regarding combustible dust and unclassified hazards, which are now labeled as Hazards NOC (not otherwise classified).  Combustible dust will be classified as such and will not be placed in the Hazards NOC category.  A number of compliance dates were specified including employee training to be completed by December 1, 2013 and full compliance by June 2016.

OSHA launched its new website on HazCom 2012 today.  It provides guidance on compliance and frequently asked questions regarding the new standard.

Now that the final rule is released, look for an Emilcott Free Webinar, HazCom 2012 made Simple
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Topics: Emilcott, OSHA, health and safety, OSHA Compliance, HazCom, Occupational Health, Occupational Safety

2011: A Year In Recap

Posted by Shivi Kakar

Jan 4, 2012 3:29:54 AM

Bringing in the New Year is always an exciting time for everyone. People enjoy setting new goals, looking forward to the journey that the New Year brings and starting that resolution they promise they are going to keep. While the New Year brings many things to look forward to, it also is a time where we look back at the year that has passed and take a moment to reflect on what has happened.

At Emilcott, 2011 was a successful year where we were able to tackle new projects, serve our clients and continue to respond to current industry issues in the environmental, health and safety field. Though we have had many great memories from 2011, we would like to mention some of the things that stood out most in our business for 2011.

Hurricane Irene – the immense and powerful Atlantic hurricane that left a path of destruction and devastation was something that definitely stands out in 2011. We remember this event not only because of the wreckage caused by the storm, but also because of the after effects. The staff at Emilcott recognized the importance of addressing the legacy of water intrusion and the promise of mold after the storm and stressed to clients the importance of “timing” to address how to respond to this problem, as well as the importance of selecting the proper remediation technique along with an EHS mold expert and Emilcott’s mold remediation strategy. (Read more: Hurricane Irene Leaves a Legacy of Water Intrusion and the Promise of Mold)

Energy Sector – Emilcott has been thrilled to be able to participate in many different initiatives within the energy sector.  Regionally important to the growth of our economy, the ongoing infrastructure improvements have given us substantial health and safety support work. In EHSWire during 2011 we addressed many occupational hazards as Occupational Heat-related Illnesses where we went over the symptoms that workers may experience, as well as what should be done if someone does experience these symptoms. Besides dealing with working conditions such as heat, Emilcott also provided information on the truths about occupational slips, trips and falls which ended up costing American businesses $13.67 billion in workers compensation costs in 2008. Adhering to proper safety protocols and preventing injuries is something that benefits businesses and their workers. OSHA provides a Walking/Working Surfaces – Safety and Health Topic page which provides links to all the applicable standards.

With issues such as heat affecting the health of workers to preventing injuries on job sites, Emilcott has seen our fair share of mishaps. Being able to share our experiences and knowledge with others never gets old. From teaching someone the hazards about working near a crane, or things you should do when working in certain environments, Emilcott has always tried keeping people in the loop. We even have a 10-Hour Construction Industry Outreach Training Course based on the requirements established by OSHA which is a very hands-on and interactive class that we recommend to avoid a future work related issue. (Read more: Work Near a CRANE? Learn the Hazards!)

9/11 Tenth Anniversary – focused the changes that have occurred since 9/11/2001 such as the new precautions that have taken place on the American Chemical Security issue.   The DHS (the Department of Homeland Security) has been increasing their focus on utilities and chemical facilities which may become targets for terrorist activities and the DHS Chemical Facility Anti-Terrorism Standard (CFATS) now requires completing and submitting a Top Screen analysis to the DHS.

The James Zadroga Act , which was authorized to broaden, renew funding and extend benefits to Ground Zero workers whose death was a result of exposure, is of great significance and has put new emphasis on the importance of proper real-time environmental site monitoring. New technologies are available to protect site workers and the public from exposure to hazardous substances such as those from the collapse of the WTC towers. (Read more: 9/11 Tenth Anniversary Focuses on American Chemical Security)

Toxic Substance Control Act (TSCA) – was of major importance not only to Emilcott, but also to facilities who are manufacturers or importers of chemicals in amounts of 25,000 pounds or greater. With so many questions regarding TSCA and the changes, Emilcott decided to put on a free webinar along with posting a number of blogs that answered many of the concerns our clients had. Emilcott was able to use its expertise and help many clients with TSCA compliance questions and concerns regarding the developments of IUR reporting and reporting obligations in 2011 for the calendar year 2010. (Read more: August 2011 Update on the TSCA IUR-now-CDR Rule)

Though Emilcott has had many remarkable memories of 2011, we felt these 4 really left an impression on our business. Emilcott is privileged to know that we were able to assist our clients in many different businesses not only in 2011, but throughout our history. Emilcott looks forward to a productive 2012 and we are excited to see what this year has in store for us.

Do you have any environmental, health or safety concerns for 2012? If so, please share them with us below!
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Topics: Emilcott, OSHA, health and safety, CFATS, Hazardous Materials, worker safety, Occupational Health, Occupational Safety, TSCA, Toxic Substance Control Act, Uncategorized, Mold

Setting up Health and Safety Communications in Remote, Mountainous Work Areas

Posted by Shivi Kakar

Apr 11, 2011 8:46:26 AM

By Don Hoeschele, MS, CHMM

In an age where we are reliant on modern technology as a part of our job, it is difficult to imagine not being able to use your cell phone or access the Internet because of topography.  As the Field Safety Manager for a 300-mile electric power transmission power line construction project, one of my first tasks was to address the question “How do you make communication possible across 275 miles of relatively unpopulated, harsh mountainous territory”?  Specifically, I had to meet OSHA’s requirements for communication:  29 CFR 1926.35 “Employee Emergency Action Plans” and 29 CFR 1926.50 “Medical Services and First Aid”.  

For a project health and safety administrator, it is vital to be able to communicate with your team members and with outside resources. How do you keep tabs on who is where and what is happening? How do you find if something has gone wrong or someone needs help?  In fact, these are the reasons that OSHA implemented the Standards listed above – life and death situations may depend upon it!

On this particular project, numerous construction crews were working at different, extremely remote locations with a distance of several miles between each work crew. While the power line tower construction and electric line-stringing companies included requirements for an eventual end-to-end 2-way radio system, the system was not available for at least the first year of the project. And, since cell phones and the average two-way radio systems were not able to be consistently or reliably available to meet the communication needs required for this project, I needed to find an alternative. 

After digging around and countless meetings, calls, and trips to all kinds of communications companies, we settled on a resourceful, cost-conscious and effective method of communicating between the crews, safety personnel, surveyors and managers. The end result was a creative mix of new technologies:

  • Cell phone signal boosters in each vehicle in the field

  • GPS SPOT locator units for each  crew

  • New technology satellite phones for work crews heading into the most remote locations.  


The vendor that built these systems also owned many of the frequencies needed for an end-to-end two-way radio system that would reach across the 275-mile project location.

Of course, the system’s effectiveness had to be proven – we were relying on it! So, I spent hours deep in the mountains field testing the equipment in some of the most remote project locations I have ever seen. Luckily, I was helped by some of the project team members who had spent a great deal of time in this area. Experience also helps communication!

This project had unusual difficulties – a big, remote, mountainous and unpopulated area – that could have thwarted OSHA’s communication requirements.  At any time, it would have been easy to throw in the towel, cross our fingers or perhaps put together a patched-together system and hope it worked.  However, with some tenacious ingenuity and a confidence that a reliable health and safety communication system could be found, we were able to overcome the almost overwhelming challenges and put an effective field communication system into place.

Have you been faced with challenges to provide adequate communication systems for your employees?  What has made a job site seem almost impossible to conquer? What did you do to overcome those challenges?
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Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, HazCom, Compliance, worker safety, Occupational Health, Occupational Safety, Hazard Communication Standard, communication

The Triangle Shirtwaist Fire (1911) - A Turning Point for Workplace Safety

Posted by Shivi Kakar

Mar 23, 2011 3:39:09 PM

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Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, H&S Training, worker safety, Occupational Health, Occupational Safety, regulation, Fire Safety, shirtwaist, fire, triangle

You Better be Qualified if You are a Respiratory Protection Program Administrator!

Posted by Shivi Kakar

Mar 21, 2011 2:31:48 AM

by Paula Kaufmann

What’s the job of a Respiratory Protection Program (RPP) Administrator? 


This individual is officially listed in the site’s written Respiratory Protection Program and is accountable and responsible for the day-to-day operation of the program. Some of those “day-to-day” tasks include

  • Maintaining the site Respiratory Protection Program

  • Assessing the workplace for potential respiratory hazards

  • Defining worker exposure for these hazards

  • Selecting appropriate respirators to provide protection from defined hazards

  • Ensuring

    • Medical evaluations are conducted of employees required to wear respirators PRIOR to fit testing

    • Respirators are fit tested for all required users

    • Proper use of respirators during routine and emergency operations

    • Respirators are appropriately cleaned, disinfected, stored, inspected, repaired, discarded, and maintained

    • Adequate air quality air is supplied if supplied air respirators are used.

    • Respirator users are trained in respiratory hazards, and the proper use and maintenance of respirators

    • Periodical evaluation of the Respiratory Protection Program implementation

    • Workers who voluntarily wear respirators (excluding filtering facepieces) comply with the medical evaluation, and cleaning, storing and maintenance requirements of the standard

    • All voluntary-use respirator users understand Appendix D of the standard




Yes, these incessant and critical health and safety tasks can be quite overwhelming!  What’s the big deal? For the company or job site or administrator who does not understand why a qualified and empowered RPP Administrator is a big deal, here is a triple-play of Top 5 facts that illustrate the importance of qualified training for Respiratory Protection Program Administrators!

Top 5 OSHA Violation!


Did you know that the Respiratory Protection Standard was in the Top 5 most frequently cited standards by OSHA compliance officers last year?  Why be a part of that statistic?  More about 2010’s Top 10 cited violations can be found in a recent EHSwire blog by Emilcott’s Sarah Damaskos.

Top 5 Reasons YOU need to be “Qualified”



  1. Workers at your site are required to wear respirators for protection from respiratory hazards – and you selected these respirators.

  2. You train respirator users on how to put on and take off their respirator – along with the limitations on their use, and their maintenance.

  3. Implementation of the site respiratory protection program (which you wrote) is just another one of your jobs!

  4. Airline (atmosphere-supplying) respirators are used at your site – and you make sure that an adequate air supply, quantity, and flow of breathing air is available.

  5. You coordinate the medical evaluation of employees who must use respirators.


Top 5 OSHA Compliance Indicators!


If you get a visit from an OSHA Compliance Safety and Health Officer, they review these essential factors to help determine if the Respiratory Protection Program Administrator is “Qualified”:

  1. The written Respiratory Protection Program and interviews with the program administrator reveal an understanding of the familiarity with the respirator standard, site respiratory hazards, and the use of the respirators in the workplace.

  2. Respiratory fit testing is conducting annually or at assignment and the program administrator maintains.

  3. Hazardous airborne contaminants that employees may inhale have been identified.  Reasonable estimates of employee exposures were used in determining the appropriate respirator for employees to use.

  4. Recent changes in the workplace such as new processes have been evaluated for necessary respiratory program changes

  5. The program administrator keeps a written assessment of the program operations and implements changes that may be considered as efforts toward improvement.


How to Become a Qualified RPP Administrator


Focused, hands-on training with experienced health and safety instructors can make the difference for a Respiratory Protection Program Administrator – clarifying the waters by understanding the objectives of the law and how it applies to each work site!

As Health and Safety consultants to many types of companies, Emilcott staff are on job sites each day and see health and safety violations such respirators perched on foreheads or tissues jammed in the sides to ensure a bitter fit. Are these problems an employee violation or a company-wide result of not understanding the importance of a competent Administrator who can develop, maintain and enforce a respirator protection program that reduces occupation risk?

In these cases, we conduct urgent and immediate on-site RPP Administrator training that often includes high level managers to ensure that there is a top to bottom understanding of the importance of proper respirator usage. In addition to our private training, the Emilcott Training Institute offers public enrollment Respiratory Protection Program Administrator training courses in two formats:  an intense 3-hour course with a small class size and an in-depth two-day course.  In both classes, students learn the level of information required for their sites and are taught by an experienced H&S instructor that can answer questions. 

So if you are unfamiliar with your required duties as an RPP Administrator or you want a better understanding of how to encourage better respirator usage by your site personnel, look around for an effective RPP Administrator training class. Once complete and in practice, you should dicover aTop 5 list that looks more like this:

  1. OSHA respirator inspection passed without any problems, fines or additional action.

  2. Site personnel actively wear their respirators – the way that they are supposed to!

  3. Site workers reinforce the importance of respirator use to their colleagues (even when you’re not around)!

  4. Managers understand the need for respirator use and support related site activities such as testing of hazardous airborne contaminants.

  5. Written assessments of program changes are treated as a necessity for business to move forward rather than resented.


You ARE a Qualified Respiratory Protection Program Administrator!

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Topics: Emilcott, OSHA, Personal Protective Equipment, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Lab Safety & Electrical, emergency response training, Fire Safety, Exposure, Respiratory, Occupational Training, RPP, respirator protection program, administrator

Need a Paradigm Shift with Safety Attitudes at your Manufacturing Site? Try OSHA 10-Hour Outreach Training for General Industry

Posted by Shivi Kakar

Mar 7, 2011 1:13:18 AM

Martha Hernandez

When it comes to training, OSHA takes it seriously. With good reason:  training keeps workers safe and reduces incidents.  Many OSHA standards specifically require the employer to train employees in the safety and health aspects of their jobs. Other OSHA standards require the employer to make sure that only certified, competent, or qualified workers are assigned specific tasks--meaning that they have had special previous training.  OSHA compliance officers look to see that employers have provided appropriate training to their employees.  

In an effort to improve the consistency of the quality and content of health and safety training, OSHA has developed a series of “Outreach” training programs.  OSHA Outreach training focuses on segments of labor in the business sectors of General Industry and Construction and Maritime Industries. The courses are either 10 or 30 hours in duration with strict agenda guidelines containing focused and topical material, and must be taught by instructors that have extensive training and are approved to deliver the instruction.  The instructors or “Authorized Providers” must attend OSHA train-the-trainer courses, adhere to rigorous standards, and are subject to unannounced audits by OSHA at any time.  Over 3.2 million workers have participated in this type of training over the last 5 years!

In today’s blog we will look at the General Industry Outreach Training.

What is General Industry Outreach Training?


“General Industry” is defined by OSHA as any industry not directly involved with agriculture, construction, and maritime industries.  The standards applicable to General Industry are contained in Section 29 of the Code of Regulations, Part 1910.  As a result of the broad “General Industry” definition, one of the most popular OSHA Outreach courses is the 10-hr General Industry Training  which teaches safety and health hazard recognition and prevention.   OSHA Outreach training focuses on segments of labor in the business sectors of General Industry and Construction and Maritime Industries.

Who Should Attend a 10-hour General Industry Training Course?


The OSHA 10-hour General Industry course is designed for plant superintendents and engineers, floor foremen, safety professionals, project managers, and any other personnel responsible for workplace safety. Indeed, many organizations include all their plant personnel in this training because EVERYONE is responsible for safety. This course is an excellent introduction to health and safety programs for new employees or when it is time to create a paradigm shift in attitudes about safety at a facility.  The General Industry course can help line management get “safety religion”!  In fact, OSHA recognizes the completion card as an indication of the importance of safety and health at an organization.  Workers’ Compensation insurance providers often will reduce rates for companies that provide this training to their staff.

Emilcott’s OSHA 10-Hour General Industry Course


Based on the firm guidelines provided by OSHA, Emilcott’s 10-hour General Industry course provides important information about how OSHA is involved in the general industry community and how employees can recognize and control common workplace hazards. The training focuses on recognizing and controlling hazards found in the industrial workplace. It assumes no prior training nor requires prerequisite training. Much of our 10-hr General Industry course is interactive and hands-on.  More importantly, our courses are taught by instructors with real-world experience. Credentials and certifications provide a way to verify competency in particular fields but real-world experience should not be discounted. It’s one thing to talk about electrical hazards, it’s quite another to actually work around them. This experience allows our trainers to put the material in perspective and helps students make the connection between theory and practice.

Quality Training Makes a Difference


We have found that the OSHA Outreach Courses for both Construction and General Industry help site management really “get it” when it comes to site safety!  This training has given new life to existing safety programs and initiatives at our client sites.  Have you seen safety training make a difference is program compliance at your sites?
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Topics: Emilcott, OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, General Industry, Occupational Training

The Benefits of Instructor Led vs Online HazWOPER Training

Posted by Shivi Kakar

Feb 28, 2011 6:02:05 AM

by Paula Kaufmann

I have attended some incredibly mind-numbing courses over my lifetime.  The worst course ever was in high school American History when we were “taught” about the FDR Years (1933-45) from an endless series of film strips with audio from a synchronized record. Recently, I attended a full-day, on-demand technical class that immediately transported back to that American History lesson. Needless to say, this comparison does not reflect well for this recent course.

I find I don’t take away much from a course that does not engage me. This could be because the topic is inherently dull, the material is presented in a monotonous or non-engaging manner, or I simply can’t connect with the material or the instructor.  I’ve often joked that I am easily entertained (after all, I am a chemist by training!), but dull, monotonous and distant often leave me with zero recall of the main points, and the details, well, those never seem to penetrate my numb mind!

On-line or Classroom HazWOPER?


In a previous EHSWire blog, Vijay Chintamaneni noted, “ When evaluating the courses based on their published description, Online Training and Instructor Led Training (ILT) may look the same, so it is wise to understand the benefits and drawbacks of both before making a final decision. This is especially important for occupational health and safety training.”

So, when I am asked for my thoughts on whether to attend an on-line or instructor-led HazWOPER training class, my immediate response is clear!  It is CRITICAL to actually learn what is taught in these classes not just fulfill the OSHA requirement.  Why? These workers will be working on a HAZARDOUS WASTE SITE, and the knowledge learned in a HazWOPER class allows them to appropriately protect themselves. Students in a HazWOPER class must be engaged in this particular occupational learning as the material is inherently dry and dull.  The best way to imprint essential HazWOPER components such as risk assessment, hazard information, team emergency response and the practical learning, is from discussion, hands-on and group exercises.  

Training experts insist that hands-on training is the best way to learn!


Consider these situations the next time you consider online training to meet your HazWOPER requirements:

  • Would you SCUBA dive in the Florida Keys after completely an on-line SCUBA diving lesson (without ever handling the equipment on land or even in a pool)?

  • When you call 911 – would you trust an emergency responder that recently received CPR training on-line  without any practice or instructor guidance?

  • Would you lend your car to a friend who just learned to drive by completing an on-line driving class?

  • If folks need to be trained to work as a team with a command/response structure – how successful can team training be when individuals are trained in isolation?

  • How many other things do you do while you are “attending” an online course?

  • Do you really want the guy next to you at the hazardous site to be responsible for your health after taking critical health and safety training…online?


Why the Emilcott Training Institute? Because you will LEARN and be prepared!!


Emilcott offers quality HazWOPER health and safety training that prepares workers for the real world by keeping them engaged and interested in the materials! Our HazWOPER instruction combines classroom knowledge with interactive, hands-on activities, respirator fit-testing, individual and group activities, and a simulated, outdoor hazardous waste operation complete with “what if” scenarios and instructor guidance.

  • The Emilcott 40-hour HazWOPER mock drill is chock full of “what if” scenarios such as unidentified hazards, nosy neighbors, health and safety incidents, decontamination exercises, use of instruments, and more.

  • We film our mock drill and then evaluate the results in class.

  • We have taught thousands of HazWOPER training classes – many of them for the US Armed Forces in the states and Europe.

  • Our 8-hour Site Supervisor course concentrates on group exercises and managerial experience to reinforce essential skills needed to ensure the health and safety of the crew while getting project work completed without incident.

  • We interview our students to ensure that the materials presented are as applicable to their job function as possible.

  • Our annual 8-hour Refresher is revised each year to ensure well-rounded exposure for our repeat students.

  • We train students, but we do not pass students who don’t qualify!


What is the importance of a good instructor?


Emilcott HazWOPER instructors are field-experienced health and safety professionals who have seen it all!  In fact many of our instructors have been working on hazardous waste sites and training for over 25 years. Emilcott instructors consist of

As HazWOPER instructors, their job is to review the OSHA-required materials in such a way that students can remember the materials and apply them to their job.  Through a variety of media, discussions and exercises Emilcott ensures that our 24-hour, 40-hour or 8-hour HazWOPER class is as practical and hands-on as possible!

Understand Yourself and the Impact of Effective Training


As a CIH consultant with a family and other obligations, it is always a challenge for me to squeeze in occupational training. After all, time spent learning does compete with project work, and there are only so many hours in the week!  With such a tight schedule, sitting in on a webinar or other type of on-demand learning is easier to squeeze into my schedule. Conversely, I also know that attending a course in a classroom with a qualified instructor is a far better option for learning and applying critical health and safety information that I will need on the job. As a result, whenever I have the option between online or instructor-led, especially for a dreaded or boring topic, the best option is to block out the time for classroom learning; my distractions are reduced, my attendance and alertness is required and, now that I’ve set aside the time, my focus is on learning the most and maximize the opportunity. 

Have you ever taken an online, technical course? What were some of the distracting activities you did while “learning”? My personal favorites are cleaning up my email or wallet! Have you ever taken a technical course for multiple days and walked out of it remembering almost next to nothing and thinking, “Oh, that was a waste!” Has that experience affected your training selection process?
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Topics: Emilcott, OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, H&S Training, Hazardous Waste Management, Compliance, Occupational Health, Occupational Safety, class, Occupational Training, HazWOPER, training

Regulatory Submissions & Postings Reminder (January thru April 2011)

Posted by Shivi Kakar

Feb 6, 2011 9:20:28 PM

Paula Kaufmann, CIH

Here is a handy table we recently created for our clients -- a gentle reminder to get organized! Even if you miss a deadline, it's better to start playing catchup as soon as you find out that you are not in compliance.

Want to stay informed? Emilcott publishes a timely email reminder, "EHS Regulatory Submissions", 3x/year to keep our clients informed about upcoming deadlines. If you'd like to subscribe to that newsletter, just go to http://www.emilcott.com/subscribe.asp. If you need help with your Regulatory Submissions, contact Emilcott and ask for either an EHS or Hazardous Materials/Waste consultant.

Quick Reference Guide to Regulations and Submissions (Jan-Apr 2011)





















































RegulationSubmissionFrequencySUBMISSION DATE
EPA TSCA New ChemicalsTSCA Polymer Exemption ReportAnnualJanuary 31
EPA Greenhouse Gas ReportingCertificates of RepresentationRegistrationJanuary 31
EPA Greenhouse Gas ReportingGHG ReportsAnnualMarch 31
OSHA Recordkeeping & Reporting Occupational Injuries & IllnessesOSHA Injury and Illness Log Summary – Form 300AAnnualPost Feb 1 thru April 30
NJ Emissions Statement RuleEmission StatementNon-applicability ReportAs WarrantedFeb 1
Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312Community Right-to-Know (CRTK) Survey and Tier I or Tier II Inventory FormAnnualMarch 1
NPDES Stormwater ProgramAnnual CertificationAnnualVaries by State

EPA TSCA New Chemicals

Anyone who imports or manufactures a new polymer in 2010 that met the TSCA Exemption Criteria must submit a TSCA Polymer Exemption Report of manufacture or import by (postmarked) January 31 of the year subsequent to initial manufacture. The notice must include:

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Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, EPA, Hazardous Waste Management, Compliance, worker safety, Occupational Health, Occupational Safety, TSCA & R.E.A.C.H., TSCA, reporting, Form 300, Greenhouse Gas Reporting

OSHA Recordkeeping 300A…It’s For You and the Rest of the Country!

Posted by Shivi Kakar

Jan 31, 2011 1:59:49 AM

Paula Kaufmann, CIH

Did you know that the OSHA Illness and Injury Summary Log, 300A, is used for more than just recordkeeping at your site?  By documenting your company’s illness and injuries properly, you shape OSHA’s future initiatives!  Specifically, OSHA Summary 300A Forms are gathered by the OSHA Data Initiative (ODI) to help direct OSHA programs and measure its own performance.  

How does OSHA get this information?

OSHA gets these data from two sources:

  • As part of an annual survey, the Bureau of Labor Statistics (BLS) sends injury and illness survey forms to randomly selected employers and uses the information to create the Nation's occupational injury and illness statistics.

  • The OSHA Data Initiative mails its annual survey (in June) that collects data on injuries and acute illnesses attributable to work-related activities in private-sector industries from approximately 80,000 establishments in selected high hazard industries. In 2010, OSHA also collected this information from approximately 20,000 establishments in the construction industry in addition to the non-construction establishments. The Agency uses these data to calculate establishment-specific injury/illness rates, and in combination with other data sources, to target enforcement and compliance assistance activities. Traditionally, OSHA collects data from the establishments that meet the following categories, but as we saw in 2010, OSHA can expand these criteria.

    • Non-construction industries with 40 or more employees are chosen randomly

    • Non-respondents in the previous collection year

    • Site with an inspection or consultation visit for performance measurement

    • DART rate (days away from work, restriction or transfer) of 7.0 or higher in previous data collection




Does the data really help OSHA?

Now that OSHA has the data from BLS and the ODI, the Agency uses the information to

  • Calculate and establish specific injury and illness incidence rates

  • Develop targeted intervention programs (i.e., inspections and enforcement action)

  • Assist inspectors so that they can direct their efforts to the higher incidents hazards that are hurting workers.

  • Measure the success of agency efforts to reduce the number of workplace injuries and illnesses in select high-hazard industries

  • Provide the base data for the BLS Annual Survey of Occupational Injuries and Illnesses, the Nation's primary source of occupational injury and illness data.


What is your role?

Be a savvy and educated reporter of your company’s illness and injury information. Understanding the OSHA 300 log reporting requirements will ensure an accurate portrayal of worker health and safety as well as maintaining OSHA compliance. Can you answer the following questions?

  • How do I complete the OSHA 300 Log and Form 301?

  • Am I required to post an OSHA Form 300A ? How do I know if I am exempt? 

  • What is classified as a work-related illness or injury? 

  • How do I fill the forms in correctly without over-reporting?

  • Do I have to fill in the form if I have no recordable injuries or illnesses in the previous year? What are the rules for posting?

  • Once the form is filled in and submitted, if requested by BLS or OSHA, are there other legal requirements I should know?


Not convinced that recordkeeping is important?

Besides providing a visible record of worker safety benchmarks and improvements (or worse, tragedies and reversals), establishments that are requested to but fail to submit a completed data collection form may be subject to OSHA enforcement actions, including the issuance of a citation and assessment of penalties!  So, take the time understand OSHA’s reporting requirements and implement them correctly – it affects your company and the nation’s workers.

If you need assistance with OSHA recordkeeping, Emilcott offers a variety of ways to help your business stay in compliance from a webinar-based course that outlines the rules and regulations to the development of complete health and safety plans. Or, if you have an OSHA recordkeeping question, just ask us!
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Topics: Emilcott, OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Compliance, worker safety, Occupational Health, Occupational Safety, Webinar, reporting, regulation, Medical Records, BLS, Bureau of Labor Statistics

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