1. UPDATE
2017

2. Who Is This Guy?
“To Protect and Promote the Value of Life Through Safety”

3. OSHA 2017 Enforcement Dates
New Recordkeeping Rule – Anti-retaliation laws, drug screening mandates, whistleblower rules, revived emphasis on safety incentive programs, and new electronic record keeping rules (OSHA 300A hard copy logs)
Walking-Working Surfaces – General Industry Only
Final Rule on Beryllium – PEL’s lower by 10x’s
Final Rule on Crystalline Silica – PEL’s lower by 5x’s (Construction Only)
Crane Standard – Qualified vs Certified (Construction Only)
OSHA Political Outlook 2017

4. 1. New Recordkeeping Rules
January 1, 2017 – enforcement began
Anti-retaliation laws, drug screening mandates, whistleblower rules, revived emphasis on safety incentive programs, and new electronic record keeping rules (OSHA 300A Logs)
February 1st – April 30th – OSHA 300A Hard Copy to be placed in a conspicuous location within your establishment (separate from the electronic requirements)

5. 1a. “Mandatory Post-Accident Drug Screening Ruled Out”
1a. “Mandatory Post-Accident Drug Screening Ruled Out” - New Recordkeeping Rules
QUESTION: How many of you have policies and procedures that mandate drug and alcohol testing in the wake of a workplace accident, regardless of reasonable suspicion?
Effective December 1, 2016 OSHA’s final rules on electronic reporting of workplace injuries require employers to implement “a reasonable procedure” that cannot deter or discourage employees from reporting a workplace injury. 
QUESTION: When might an employee under-report an injury out of fear for being drug screened?
Bee stings (serious citation) $$
Back strain (serious citation) $$
Repetitive Motion Injuries (serious citation) $$
QUESTION: What about an employee who is injured as a result of another team member?

6. 1a. “Mandatory Post-Accident Drug Screening Ruled Out”
1a. “Mandatory Post-Accident Drug Screening Ruled Out” - New Recordkeeping Rules
What is OSHA’s View of “Unreasonable Procedures?”
Unreasonable if, for example, an injured or ill employee were required to report the injury or condition within only one hour of its occurrence or were required to report the injury or condition to so many different managers that it would be a deterrent to reporting
Mandated/Blanket Post-injury Drug Testing is “Unreasonable Procedure”
OSHA will be focusing on an employer’s motivation in implementing its post-accident drug testing policy
No effect on random drug testing, but if OSHA determines that the intent of an employer’s post-accident policy is to deter or discourage the reporting of work-related injuries or illnesses, then OSHA is likely to issue a citation seeking to eliminate an employer’s continued use of such a policy
A “blanket” or “automatic” post-accident or post-injury drug testing policy will, in effect, be presumed to be retaliatory and intended to deter or discourage reporting

7. 1a. “Mandatory Post-Accident Drug Screening Ruled Out”
1a. “Mandatory Post-Accident Drug Screening Ruled Out” - New Recordkeeping Rules
Some Questions to Consider as We Await More Information
How do DOT mandates effect this rule?
Is it possible injured workers become a protected class?
What are your post accident motivations for drug screening?
How will employee complaints trigger OSHA enforcement?
Separate division already investigating employee complaints
What is your post-accident investigation procedure?
How will this effect Worker’s Comp payout and co-exist with State Work Comp Laws

8. 1b. “Your 300 Logs Are Going Public” – New Recordkeeping Rules
Effective January 1, 2017, but the first roll-out where OSHA will require establishments with 20+ employees to electronically submit the OSHA 300A
This information will be PUBLIC, meaning the general public, customers, potential customers, prospective employees, general contractors, etc. will all have access to your injury data
WHO and WHEN?
Employers within high hazard industries that have more than employees (300A). (July 1, 2017, 2018 and March 2, 2019 and March 2nd every year thereafter)
Employers with 250+ employees (OSHA Forms 300, 300A and 301 (July 1, A ONLY, July 1, 2018, March 2, 2019 and March 2nd every year thereafter for ALL forms)

9. 2. Walking Working Surfaces – General Industry Only
January 17, 2017 – Law went into effect
June 17, 2017 – Deadline to have your employees trained on the new fall and equipment hazards
The rule benefits employers by providing much greater flexibility in choosing a fall protection system. For example, it eliminates the existing mandate to use guardrails as a primary fall protection method and allows employers to choose from accepted fall protection systems they believe will work best in a particular situation
This means you can use guardrail systems, safety net systems, personal fall arrest systems, positioning systems, travel restraint systems, ladder safety systems, rope descent systems, and again, any approved device that will eliminate the hazard. 

10. 3. Final Rule -Beryllium
March 10, 2017 – 10-fold decrease in allowable exposure limits
You MUST know your baseline
OSHA's new PELs are 0.2 micrograms of beryllium per cubic meter of air, over an 8- hour time-weighted average, and 2.0 micrograms per cubic meter over only a 15 minute exposure period.
These PELs are the same for all employers covered by the standards in general industry, construction, and shipyards. The new PEL represents a ten-fold DECREASE from the previous PEL. In other words, it was originally 2.0 over an 8-hr period and now it's .2. HUGE difference

11. 3. Final Rule -Beryllium Where do we find Beryllium?
Beryllium Oxide Ceramics and Composites
Beryllium Production
Nonferrous Foundries
Secondary Smelting, Refining, and Alloying
Precision Turned Products
Copper Rolling, Drawing, and Extruding
Fabrication of Beryllium Alloy Products
Welding
Dental Laboratories
Abrasive blasting with slags and 
Coal-fired Power Utilities

12. 4. Final Rule – Crystalline Silica
What is it?
"Crystalline silica is a common mineral that is found in materials that we see every day in roads, buildings, and sidewalks. It is a common component of sand, stone, rock, concrete, brick, block, and mortar.
Exposures to crystalline silica dust occur in common workplace operations involving cutting, sawing, drilling, and crushing of concrete, brick, block, rock, and stone products (such as construction tasks), and operations using sand products (such as in glass manufacturing, foundries."
For decades, Silica has accounted for numerous fatalities and chronic illness.  
The original rule on Silica was established in 1971 and despite the science and years of data pointing to flaws in the original PEL's (personal exposure limits), the rule has not budged.  
NIOSH has been stating the original rule has been out of sync with the science since the 1974 studies proved as much.

13. 4. Final Rule – Crystalline Silica
The final rule took effect on June 23, 2016., after which industries have one to five years to comply with most requirements, based on the following schedules
Construction - June 23, 2017, one year after the effective date.
General Industry and Maritime - June 23, 2018, two years after the effective date.
Get a baseline sample to KNOW what is required

14. 5. Crane Standard – Construction ONLY
November 10, 2017 – Decision must be made
Qualified vs Certified
Political pieces

15. OSHA Political Outlook 2017
Employee Complaints
OSHA Reportable Injury Laws
OSHA “Consulting” Visits
OSHA’s New Fine Structure
New Region 7 Director

16. 2017 Effective Date Timeline

17. Questions and Answers

18. Contact Summit Safety Group
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