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Regulatory Submissions Reminder

Most domestic manufacturers and importers are required to provide submissions to the Federal EPA or their State environmental departments.  For some, it is a broad range of different government agencies. With so many regulatory submissions, it can be hard to keep them all straight, so we have compiled a list of which regulations and submissions are due for the first quarter of 2016. This list even includes specific dates to keep you right on track and help you ensure that everything is submitted on time!


January 1st Kick-off List for CRTK and TRI Reporting

Another calendar year!  Where does the time go?  After the holiday bustle has ended, my next task is to start gathering up receipts and records for income tax filing.  Just like taxes, our businesses face regulatory submission deadlines, reporting data from the past year, including Submission of the EPA Community Right to Know (CRTK) Survey and the Hazardous Waste Biennial Report (or Annual for some states), which are due March 1st. Also on the horizon, is the EPA Toxics Release Inventory (TRI) and the New Jersey Release and Pollution Prevention Report (RPPR) both due July 1st.

Just like holiday gift shopping, the compilation and reporting process is less stressful and yields better results, if I begin early and develop a strategy with deadlines in mind.  As such, here is my personal January 1st kick-off list that should make the time-consuming process of CRTK and TRI reporting easier to handle.   

1.  Start requesting and gathering all the information needed for these submittals:


OSHA Forms

There are three OSHA recordkeeping forms that you should we aware of as an employer.  These include the OSHA 300 Log, the OSHA Form 301 and the OSHA 300A.  The OSHA 300 Log is used to record and track work-related injuries and illnesses as well as any associated lost, restricted or transfer days.  The OSHA Form 301 is used to describe details associated with work-related injuries and illnesses and to report Workers’ Compensation claims to insurance carriers.  It is not unusual for many insurance companies to have an “equivalent” to the 301 Form that they use internally.  OSHA allows for the use of an equivalent form, provided that it contains as least the same required information as the OSHA Form 301.  The OSHA 300A or annual summary, only includes a summary of work-related injury and illness information including the number of cases, all associated lost and/or restricted days and selected operational information such as the employers address and NAICS or SIC codes.  Key requirements of the OSHA 300A are that it must be reviewed by a senior member of the management team, signed to indicate their approval and posted for a specific period of time.  Additional information on each of the three forms is contained below.  All forms are available at www.OSHA.com.


Determining Recordability

Employers are responsible for recording all work-related injuries and illnesses. If you are unable to determine if an injury or illness is recordable after you have completed the investigation, and evaluated all available documents, it is recommended that you contact the OSHA area office nearest you.


OSHA Recordkeeping Changes for 2015

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.


Incident Investigations and Learnings

With the amount of time that our Emilcott associates spend on different sites, they have seen just about everything when it comes to incident investigations. We thought we would share some of our incident investigation lessons learned, so that you don’t experience similar situations. Here are a couple of example “learnings” from Emilcott’s staff:


Thankful for Safety Lessons Learned

“Safety lessons” are usually “learned” as part of the accident investigation after an injury. The health and safety professional community refers to these investigations as incident investigations – following the logic that almost all worksite fatalities and injuries, along with illnesses, are not accidents – but rather they are preventable incidents.


OSHA’s Hazard Communication Standard – The Next Completion Date

December 1, 2015 marks the next completion date for implementation of the revised OSHA Hazard Communication Standard (HazCom 2012).  As December arrives, containers of hazard chemicals shipped from a distributor must be labeled with HazCom 2012 hazard warning information. Manufacturers and importers shipments to their distributors included these revised labels on June 1, 2015.  Or at least “should have” included these revised labels.