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Risk Update and OSHA Reminders | March 2017

oswaldcompanies March 13, 2017

Please read below for important upcoming OSHA deadlines and notifications:    

New OSHA Electronic Recordkeeping

Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Form 300A by July 1, 2017.

Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Form 300A by July 1, 2017


Note: Oswald OnTrack will have the capability by the end of May to directly input the data to OSHA to be compliant with the new rule. For companies not on OnTrack, they will have to log into the website and manually input the data.

Completed EPA Tier II forms due by March 1, 2017

The EPA has Tier2 Submit to help facilities prepare an electronic chemical inventory report.



OSHA “Union Rep” Policy

In 2013, OSHA issued a standard interpretation letter allowing employees at nonunion workplaces to designate non employees such as union representatives to participate in so-called “walkaround” inspections.

A U.S. Occupational Safety and Health Administration policy that allowed union officials to participate in inspections at nonunionized workplaces may be doomed after a judge’s decision not to dismiss part of a lawsuit challenging the policy. Employers may still have to allow union representatives to participate in inspections of nonunion workplaces as the policy remains the official position of the administration. Employees, regardless if they are Union or Non-Union have the same rights to request representation during any questioning by an OSHA or governmental representative. No matter what the inspector says, all employees have this right.

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Questions? Contact Lara Ward, Loss Control Advisor | 216.777.6116

Note: This communication is for informational purposes only. Although every reasonable effort is made to present current and accurate information, Oswald makes no guarantees of any kind and cannot be held liable for any outdated or incorrect information. View our communications policy

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