As the last two months of 2016 are upon us, we wonder how we got here so quickly. Is there a way to avoid being so busy and enable us to make some of that time available for other things? One way is to take the anxiety out of missing deadlines by using a compliance calendar to plan for, schedule, budget and execute routine tasks required by the OSHA regulations.
This “Health and Safety Success Calendar” can be used to assure compliance with the OSHA requirements that apply to your facility (and sleep better at night not worrying if you missed any deadlines). Take what applies to your facility and give it a try!
|Month||OSHA Standard||Annual Requirement / Annual Refresher Training|
|1. January||Injury & Illness Recordkeeping Requirement & Reporting
|The Annual summary of work-related injuries and illnesses for the previous year, using OSHA Form 300A, must be completed and posted in a common area at the workplace by Feb. 1 until April 30.(A.)|
|2. February||Access to Employee Exposure and Medical Records
|Upon an employee’s first entering into employment, and at least annually thereafter, each employer shall inform current employees covered by this section of the following:
(i) The existence, location, and availability of any records covered by this section;
(ii) The person responsible for maintaining and providing access to records; and
(iii) Each employee’s rights of access to these records.
|3. March||Occupational Noise Exposure
|The training program shall be repeated annually for each employee included in the hearing conservation program. Information provided in the training program shall be updated to be consistent with changes in protective equipment and work processes.|
|4. April||Hazardous Waste Operations and Emergency Response
|Those employees who are trained in accordance with paragraph (q)(6) of this section shall receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly.<– This is the section of the OSHA HAZWOPER regulation which the author perceives applies to virtually ALL companies that have “hazardous substances” on site as defined in 1910.120(a)(3). See 1910.120(a)(1)(v) as well.|
|5. May||Respiratory Protection
|Retraining shall be administered annually, and when the following situations occur:
(i) Changes in the workplace or the type of respirator render previous training obsolete;
(ii) Inadequacies in the employee’s knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill; or
(iii) Any other situation arises in which retraining appears necessary to ensure safe respirator use.
|6. June||Fire Brigades
|The employer shall assure that training and education is conducted frequently enough to assure that each member of the fire brigade is able to perform the member’s assigned duties and functions satisfactorily and in a safe manner so as not to endanger fire brigade members or other employees. All fire brigade members shall be provided with training at least annually. In addition, fire brigade members who are expected to perform interior structural fire-fighting shall be provided with an education session or training at least quarterly.|
|7. July||Portable Fire Extinguishers
|The employer shall provide the education required in paragraph (g)(1) of this section upon initial employment and at least annually thereafter.
The employer shall provide the training required in paragraph (g)(3) of this section upon initial assignment to the designated group of employees and at least annually thereafter.
|8. August||Fixed Extinguishing Systems, general
|The employer shall train employees designated to inspect, maintain, operate, or repair fixed extinguishing systems and annually review their training to keep them up-to-date in the functions they are to perform.|
|9. September||Control of Hazardous Energy (Lockout/Tagout) – 1910.147(c)(6)(i)||The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.|
|10. October||Bloodborne Pathogens
|Training shall be provided as follows:
(A) – At the time of initial assignment to tasks where occupational exposure may take place;
(B) – At least annually thereafter.
|11. November||Permit Required Confined
|1910.146(k)(2) An employer whose employees have been designated to provide permit space rescue and emergency services shall take the following measures:
Ensure that affected employees practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.
|12. December||Mechanical Power Presses
|The operator training required by paragraph (f)(2) of this section shall be provided to the employee before the employee initially operates the press and as needed to maintain competence, but not less than annually thereafter. It shall include instruction relative to the following items for presses used in the PSDI mode.|
|OTHER RECOMMENDED ANNUAL TRAINING TOPICS.|
|Emergency Action Plan 1910.38||Employees should review and practice emergency procedures, including evacuations and severe weather drills. Training especially important for those with responsibilities during an emergency.|
|Chemical Safety||Recommended – Initial and Annual training for all affected employees. Details: Proper handling and storage, bonding and
grounding of flammables, ventilation, personal protection and hygiene, waste management procedures.
29 CFR 1910.1200
|For Any employees who may work with or around hazardous chemicals. Required training – Initial and as needed to maintain understanding; update if new types hazards are introduced. Training must cover all elements of the written program, including representative chemical hazards. Due to Global Harmonization Standard updates to the OSHA Hazard Communication Standard (HCS), CTI recommends that this training be conducted annually.|
Important caveats to keep in mind:
- New electronic reporting requirements begin in January of 2017 for OSHA Standard 29 CFR 1904 – Injury & Illness Recordkeeping Requirement & Reporting. Contact CTI with your questions on compliance reporting or see ttps://www.osha.gov/recordkeeping/finalrule/finalrule_faq.html
- This calendar addresses only those Federal OSHA standards that specify training or information review at least once a year, and does not include those standards that may require refresher training in special cases (such as when procedures or equipment are changed).
- This calendar does not indicate any of the OSHA chemical compound-specific initial & annual training requirements (such as the 13 carcinogens, ethylene oxide, methylene chloride, lead, formaldehyde, 1,3-Butadiene, etc.). These standards are found in the 1910.1000 series of 29 CFR.
- Standards that require refresher training at longer time intervals are not listed (such as the Process Safety Management (PSM) standard (1910.119) requires refresher training every three years and the Industrial Truck standard (1910.178) requires operator reevaluation every three years).
- This calendar does not include standards incorporating specific training by reference by a specific organization (such as Red Cross First Aid or CPR classes).
Compliance Technologies, Inc. has a team of experts ready to develop a customized OSHA & EPA compliance calendar for you now. Call or email us now to start your 2017 Compliance Calendar.