Sunday, January 10, 2010

OSHA 300 Due February 1, 2010

That's Right,

It's again time to summarize your workplace injury and illness data on the OSHA Form 300-A, Summary of Work-Related Injuries and Illnesses and prepare to post February 1 thru April 30.

For a copy of OSHA's Form 300-A Summary of Work-Related Injury and Illnesses go to:

For the WAC 296-27 Recordkeeping and Reporting Standard and the OSHA 300-A Recordkeeping Summary requirements go to:

There are four (4) requirements for posting the summary:

  1. You must review the OSHA 300 Log for completeness and accuracy. NOTE: (this is a great time to make necessary corrections on the 2009 Log or any other Log of the past five (5) years as required by the Regulation.)
  2. Fill out the 300-A Summary Form
  3. You must certify 300-A Summary
  4. You must post conspicuously the 300-A Summary 2/1/2010 thru 4/30/2010

I recommend adding an incident rate to the summary if your Company has multiple facilities or job sites. It is great for general knowledge and for a topic at a safety meeting. Employees should know where they are on the corporate playing field regarding injury and illness statistics.

Also keep in mind that you are required to:
  • Provide an employee or former employee who worked at the facility (site) or their personal representative a copy of the OSHA 300 Log or 301 Incident Report by the end of the next business day. (Exceptions exist for "privacy concern cases")
  • Record cases involving hearing loss resulting in Recordable Threshold Shifts as specified in the Standard's Non-Mandatory Appendix A--Age adjustment calculations for comparing audiograms for recording hearing loss
Yes, you're right, I threw that last bullet in just to see if you were paying attention. However I do recommend using Appendix A as allowed by the Standard.

Lastly, remember that these OSHA Logs must be retained for a minimum of five (5) years.

Here is to a great New Year 2010,

Mark Close
Industrial Hygiene Consultant
P. 206-782-1254
Cell: 206-919-5314

Friday, January 8, 2010

All Confined Spaces Are Not Equal

Confined Space and Classifications

I'm often perplexed by comments regarding confined space when people say something along the lines of, "oh we just handle all of our confined space entries as permit-required confined space entries."

Why would anyone as a matter of routine, classify their confined space entries as the most dangerous type of confined space entry? Are these actually confined spaces where they are merely controlling the serious hazards not eliminating the serious hazards?

We should take all confined spaces seriously. However, it is my experience that less than one percent of all confined spaces are actually permit-required confined spaces.

Don't allow complacency to exist when your employees know that not all confined spaces are equally hazardous.

For the rest of this article go to

New Dept. of Ecology Stormwater Permit Requirements

News Update!
Effective as of January 1, 2010 Washington State Department of Ecology has new Stormwater Permit requirements. Go to the following link and left click on the NEW! PERMIT on the right side

I have been busy helping my clients, assuring that they are in compliance with the new DOE Stormwater Regulations.

The first order of business is to review the SIC classifications in Table I on page 6 and Table 3 on page 26 to determine whether the stormwater permit requirements apply to you.

If you fall under these requirements remember that until you make application for a permit your monitoring data is not reportable. This brings up the second order of business.

If you fall under the stormwater permit requirements, you may wish to conduct initial monitoring immediately and qualify and quantify any potential issues. Typically, the larger part of solving any stormwater issue is knowing what and how much is in your discharge.

It is important to remember that these requirements will be new for many businesses.

Don't ignore the inevitable. Allow the Close Group to assist you.

Best regards for the New Year

Mark Close
Industrial Hygiene Consultant
P. 206-782-1254
Cell: 206-919-5314