First, was the improved tracking of workplace injuries and illnesses – which emphasized the employee's right to report injuries and illnesses free from retaliation (29 CFR 1904.35). The new reporting requirements will be phased in over two years: OSHA proposed extending the compliance date for electronically submitting injury and illness reports from July 1 to December 1. Required employers can submit injury and illness data using an electronic reporting system. The anti-retaliation provisions become effective August 10, 2016, but OSHA delayed their enforcement Dec. 1, 2016. Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Form 300A by December 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.
Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Form 300A by December 1, 2017, and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2. They have also posted frequently asked questions on the rule.
The second major rule OSHA issued a final rule on Walking-Working Surfaces and Personal Fall Protection Systems that was effective Jan. 17, 2017. The final rule includes revised and new information that addresses everything from fixed ladders and fall protection systems to training and design requirements. The final rule updates and revises the outdated general industry Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) standards on slip, trip, and fall hazards, which are a leading cause of worker deaths and lost-workday injuries (29 CFR part 1910, subparts D and I). OSHA adopted the existing standards in 1971 and has not updated them since. The final rule also adds new requirements on personal fall protection systems (29 CFR part 1910, subpart I). OSHA estimates the final rule will prevent 29 worker deaths and 5,842 lost-workday injuries each year. Additionally, because the final rule harmonizes general industry requirements with OSHA's existing construction industry standard and many ANSI standards, the new rule will make compliance both easier and less costly. OSHA estimates the annual monetized benefits of the lives saved and injuries prevented will be $614.5 million (with net benefits of $309.5 million (benefits minus costs)).
Here are 10 specific items that changed in the standard.
1) Training required for exposed workers or equipment users by May 2017. This includes general for exposure, roof, equipment, and key individuals (authorized, competent, and qualified persons).
2) Equipment requirements included changes to the test weights of snap hooks and carabineers, and requirements for self-retractable lanyards, including deceleration distances.
3) Changed safe distance to roof edges as well as defining temporary and infrequent tasks on roofs.
4) Modified ladders and stairs requirements starting in 2018 and required safety systems on all ladders by 2036. This includes requirements for spiral stairs and ships ladders.
5) Guardrails are now aligned with construction industry and codified 19 inch opening requirements.
6) Requires written certification of the workplace assessment to determine if hazards are present.
7) Rope descent systems must comply with 1910.27(b)(1)(i).
8) Documentation requirements include assessments, training, anchors, and walking working surface load rating.
9) Updated definitions of competent and qualified person in subpart D and I.
10) Important compliance dates for employee training May 17, 2017, certification of anchorages on Nov. 20, 2017, existing fixed ladders need cage well, ladder safety system or PFAs Nov. 19, 2018, new ladders with ladder safety system by Nov. 19, 2018, and all fixed ladders must be equipped with a ladder safety system or PFAS by Nov. 18, 2016.
Employers should ensure compliance, safety, and risk management in all tasks. OSHA aligned fall protection requirements for general industry with those for construction, easing compliance for employers who perform both types of activities. For example, the final rule replaces the outdated general industry scaffold standards with a requirement that employers comply with OSHA's construction scaffold standards. OSHA has created a frequently asked questions guide for the standard.
On September 13, 2017, Don Elswick, CSP, CET, CHMM with ELSMART Associates will be discussing both of these changes during the Northeast Ohio Safety Council meeting. If you have any specific questions you want addressed at the meeting contact Don Elswick at email@example.com. Looking forward to seeing you on September 13, 2017 at this important information session.