Tag: compliance

OSHA: What manufacturers need to know for 2018

Posted , updated on by

safety first card in gloved hand

 (Courtesy of Guest Bloggers Joseph N. Gross, partner, and Cheryl Donahue, associate, with Benesch, Friedlander, Coplan & Aronoff LLP)

Joseph Gross partner at BeneschCheryl Donahue associate with Benesch

Although many manufacturers are upbeat about the changes in leadership that will be coming at the Occupational Safety and Health Administration (OSHA) and having a full complement of commissioners at the OSHA Review Commission, new OSHA standards could mean a few non-compliance surprises.

Recordkeeping: Who, what, and when

OSHA revised its recordkeeping requirements for tracking work-based injuries and illnesses, now requiring many employers to submit their records electronically. This new electronic recordkeeping rule affects all employers with 250 or more employees that were previously required to keep OSHA injury and illness records and employers with 20-249 employees that are classified in any of 67 specific industries, including manufacturing, which, according to OSHA, historically have had high injury and illness rates. To be compliant, affected employers must submit their 300A Forms by December 1, 2017, per OSHA’s latest notice of proposed rulemaking. Forms are to be submitted to OSHA’s Injury Tracking Application. After the forms are collected, OSHA will post each employers’ specific illness and injury data on its website, to, as one of OSHA’s announcements explains, nudge employers to prevent workplace injuries and illnesses.

Recordkeeping in 2018

In 2018, the electronic recordkeeping requirements change again. Employers with 250 or more employees are required to electronically submit all of their required 2017 forms (Forms 300A, 300, and 301) by July 1, 2018. Employers in the specified high-risk industries, including manufacturing, with 20-249 employees are required to submit their 2017 Forms 300A by July 1, 2018. Beginning in 2019, the submission deadlines change from July 1 to March 2 each year.

Anti-retaliation protections

In addition to the electronic submission requirements, the new recordkeeping rule prohibits employers from retaliating against employees who report their work-related injuries and illnesses. The rule also requires employers to inform employees of their right to report their injuries and illnesses free from retaliation. Employers’ reporting procedures must be reasonable and cannot discourage or deter employees from reporting. Although OSHA did not go so far as making safety incentive programs unlawful, OSHA made clear that rewarding employees for having a good safety record is not permissible.

The dead Volks Rule

In April 2017, President Trump signed a resolution that killed the Volks rule. The Volks rule permitted OSHA to issue citations for certain recordkeeping up to five years after the noncompliant conduct. OSHA’s authority is back to six months. Changes to other rules and policies, including the electronic recordkeeping rule, are probably one to two years away, so stay tuned.

New compliance standards: beryllium & silica

On May 20, 2017, OSHA’s new beryllium standard became effective. Beryllium is a strong, lightweight metal used in industries such as aerospace, automotive, defense, and nuclear energy. The new standard reduces the permissible exposure limit for beryllium to 0.2 micrograms per cubic meter of air, averaged over an eight-hour day. The new standard also requires employers to use practices such as ventilation or enclosure to limit employee exposure to beryllium and to provide respirators when exposure cannot be limited.

On October 23, 2017, OSHA’s silica standard began limiting employee exposure of silica dust to 50 micrograms of respirable crystalline silica per cubic meter of air, averaged over an eight-hour day. Silica exposure occurs when employees cut, grind, or drill silica-containing materials such as concrete, rock, tile, or masonry. The standard now requires employers to limit employees’ access to high exposure areas, to provide medical care to employees who have been exposed, and to train employees about silica-related hazards.

Walking and working surfaces and ladders

OSHA’s new fall-protection standards became effective earlier this year, but manufacturers will not get the full impact until they have to buy new ladders. They are changing. In 20 years, employers will have to replace all cages and wells used as fall protection on ladders of more than 24 feet with more effective systems. But, starting November 2018, employers purchasing new fixed ladders over 24 feet will not be able to use cages and wells for fall protection.

What type of employer is HGR? Q&A with HGR’s Shipping Department

Posted , updated on by

HGR's Shripping Department on a ship

(Courtesy of Guest Blogger Doug Cannon, HGR’s transportation coordinator)

What does your department do?

Our department works in concert with the sales team and customers who require shipping services. We provide a shipping cost that we honor, and then proceed with the preparation and logistics of transportation when the opportunity is granted. We network with outside providers, such as a 3PL, specialized trucking brokers, LTL carriers, private long-haul carriers and local delivery services. They are, in turn, the marketing partners that complete the final leg of the sale. We select the appropriate mode of transportation as dictated by the nature of the products being shipped and the receiving capacity of the customer.

How many people work in your department, and what are their roles?

There are six employees in our group. Collectively, we all serve the goal of safely and economically transporting products to their ultimate destination in a timely manner. Doug Cannon and Dan Farris help to guide the sales staff on selling transportation and then executing the arrangements. Donovan Barton, Audley Wright and Dane Ferrell serve as custom carpentry designers for surplus. They build crates and pallets customized for the items being shipped by applying their creativity to condense the footprint and thus decrease the cost. Their skill sets are impressive. Jim Gubics is the LTL coordinator for shipments leaving on common carriers. He is the gatekeeper for ensuring these orders are accurate prior to leaving the building. Jim also works in several software programs where he updates in-house information, as well as emailing our customers their tracking numbers. He communicates with LTL dispatchers and drivers and loads them, as well.

What qualifications do you need to be successful in your department?

HGR buys and sells thousands of different items. They come in a great variety of weights and dimensions. So, success in our department requires individuals to possess many qualities. “Attention to detail” tops the list as no compromise. Then, to achieve success, we need to be highly organized, flexible, communicate well, and exercise imagination and creativity to provide the best solution to each purchase. No two shipments are the same; so, cookie-cutter solutions are far and few between.

What do you like most about your department?

The mutual understanding and respect the group has for each other and the tasks at hand. We genuinely like each other and the company we work to keep.

What challenges has your department faced, and how have you overcome them?

One of our biggest challenges occurred several years ago when HGR totally revamped the process by which it does international trade. This has had a large impact on shipping. We now devote extensive amounts of time on export compliance issues as we work under the guidelines of the Department of Commerce – Bureau of Industry and Security. The purpose is to protect The United States’ security and interests. The focal point at HGR is to identify machinery that could have “dual purpose” and to screen the international buyers to verify that they are not on our government’s “denied parties list.” Dan Farris has spearheaded this facet of shipping responsibilities and has served as both a mentor to Sales and a guardian to HGR and our community.

What changes in the way your department does business have occurred in the past few years?

Changes have been made in the way we service our sales staff, our customers and our community. Processes have been implemented to ensure our sales staff is provided with a transportation quote for every sales transaction that is not a customer pickup. We even provide quotes for items not sold, where customers are simply shopping and trying to determine their total “all-in” costs. These services are of tremendous convenience to the customer and help them to make a more informed decision. We take care to quote accurately and honor all quotes. Changes in international export help us to make sure we make our country a safer place to live.

What continuous improvement processes do you hope to implement in the future?

The future is today. Every employee in our group is dedicated to continuous improvement. It is one of HGR’s core values. We don’t rest on yesterday’s success, and know that we are only as good as we are today.

What is HGR’s overall environment like?

The Euclid, Ohio, facility is a beehive of activity! A collection of 70 employees perform specific roles while networking with other departments to achieve our end goal. It is a setting of perpetual communication among employees, both verbally and electronically. In the forefront is a revolving carousel of industrial surplus entering the building to be inventoried, displayed on our showroom floor, sold, and loaded on a myriad of outbound vehicles, trailers and containers.

What is your perspective on manufacturing, surplus, investment recovery/product life cycle/equipment recycling?

Primarily, I view HGR as the liaison for vendors that possess material assets and for those that seek them at an economical cost. HGR provides the service of immediate asset recovery to its vendors and spares them the distraction and expense of seeking an interested end user, as well as the logistics of the transfer. Buyers around the world can visit our showroom or browse our website and economically secure machinery, parts and unique items not found elsewhere. By virtue of its business model, HGR is a participant in the world’s interest of recycling.