It has been approximately two years since the Department of Labor announced its “Plan/Prevent/Protect” compliance strategy, with the basic goal to “ensure employers and other regulated entities are in full compliance with the law every day, not just when Department inspectors come calling.” We thought that it would be interesting to take a quick look
OSHA Rulemaking
OSHA Finalizes Major Changes to its Hazard Communication Standard
In one of the most significant rulemaking efforts in over a decade, OSHA has finalized a rule revising its hazard communication standard to align it with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The rule will affect over 5 million business establishments across the country. Over 40 million employees will need…
OSHA Publishes Update to Hazard Communication Standard
OSHA has published its long awaited update to its Hazard Communication standard to align the standard with the Globally Harmonized System of Classification and Labeling of Chemicals. Click here to go to OSHA’s webpage on the topic, which includes links to the final rule and other guidance material.
We will be providing additional information on…
OSHA Regulatory Update: IIPP Delayed but Hazard Communication Poised to be Published
Just weeks after announcing that it would be initiating the Small Business Regulatory Enforcement Fairness Act (SBREFA) process for its IIPP rule, the Agency recently announced that there would be an additional delay in starting the process. IIPP has the potential to be the most significant OSHA rulemaking in over a decade, potentially requiring all employers to implement…
IIPP – Ready or Not Here it Comes!
OSHA is poised to release to the public its initial regulatory approach to its Injury and Illness Prevention Program (IIPP) rule. OSHA has announced that it will begin the Small Business Regulatory Enforcement and Fairness Act (SBREFA) process for its IIPP rule, at which time the Agency will likely make public a draft regulatory text and…
IIPP – What Should Employers Expect and When Should Employers Expect It?
OSHA’s Spring 2011 Regulatory Agenda reiterates OSHA’s earlier commitment to initiate the Small Business Regulatory Enforcement Fairness Act process for its Injury and Illness Prevention Program (IIPP) rule in June of this year. Now midway through July, it is unclear when OSHA will release to the public its initial regulatory approach to the IIPP rule. The Agency’s oft-stated…
OSHA Proposes Requiring New Industries Keep OSHA 300 Logs, Adds More Stringent Reporting Obligations
OSHA has proposed changing the industries that would be generally exempt from maintaining regular workplace injury and illness records. Employers in exempt industries are not required to maintain OSHA 300 Logs, complete OSHA 301 incident report forms, or complete the OSHA 300A annual summary forms.
OSHA’s proposed rule also would require employers to report workplace amputations…
OSHA Surveys Employers’ Safety and Health Practices
OSHA has launched a survey of safety and health practices of private sector employers "as a tool toward better designing future rules, compliance assistance and outreach efforts." OSHA is surveying as many as 19,000 employers nationwide of all sizes and in all industries. Recipients of the survey can complete it either in hard copy form or electronically.
It…
OMB Extends Review of OSHA’s Proposed Silica Rule
The Office of Management and Budget (OMB) has announced that it is extending its review period for OSHA’s proposed crystalline silica rule. The proposal was received by OMB on February 14, 2011. This extension follows the recent pattern of OMB taking longer than the standard 90 days to review OSHA rules under Executive Order 12866. Notably, last…
New California Standard Requires Employers to Conduct PPE Hazard Assessments
California employers must now conduct an assessment of their workplaces for hazards that may require the use of certain personal protective equipment (PPE) and train employees in the use, care, and limitations of required PPE. The PPE included in the scope of the new rules are eye and face protection, foot protection, head protection, and hand…