OSHA Postpones July 1 Deadline for Electronic Form 300A Submissions

May 22, 2017

OSHA has announced the agency is not accepting electronic submissions of injury and illness logs at this time, and that the agency intends to propose extending the July 1, 2017, deadline by which certain employers are required to submit the information from their completed 2016 Form 300A electronically.

OSHA said that information about the proposed extension date will be posted on OSHA’s Injury and Illness Recordkeeping and Reporting webpage when updates become available.

OSHA published the final rule to Improve Tracking of Workplace Injuries and Illnesses on May 12, 2016, and provides a description of how the electronic reporting will work at https://www.osha.gov/recordkeeping/finalrule/index.html.

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New Process Safety Rules for Refineries in California

California’s Department of Industrial Relations’ (DIR) Occupational Safety and Health Standards Board has approved a regulation to strengthen workplace safety and health at oil refineries across the state. The new regulation provides a framework for anticipating, preventing, and responding to hazards at refineries.

“This is the most protective regulation in the nation for the safety and health of refinery workers and surrounding communities,” said DIR Director Christine Baker. “This new regulation will ensure California’s oil refineries are operated with the highest levels of safety possible and with injury and illness prevention in mind.”

The approved regulation introduces a new refinery safety order enforced by Cal/OSHA’s Process Safety Management (PSM) Unit, adding section 5189.1 to Title 8 of the California Code of Regulations. The elements outlined in the regulation require refinery employers to:

  • Conduct Damage Mechanism Reviews for processes that result in equipment or material degradation. Physical degradation, such as corrosion and mechanical wear, are common technical causes of serious process failures.
  • Conduct a Hierarchy of Hazard Controls Analysis to encourage refinery management to implement the most effective safety measures when considering competing demands and costs when correcting hazards.
  • Implement a Human Factors Program, which requires analysis of human factors such as staffing levels, training and competency, fatigue and other effects of shift work, and the human-machine interface.
  • Develop, implement, and maintain written procedures for the Management of Organizational Change to ensure that plant safety remains consistent during personnel changes.
  • Utilize Root Cause Analysis when investigating any incident that results in, or could have reasonably resulted in, a major incident.
  • Perform and document a Process Hazard Analysis of the effectiveness of safeguards that apply to particular processes and identify, evaluate, and control hazards associated with each process.
  • Understand the attitudes, beliefs, perceptions, and values that employees share in relation to safety and evaluate responses to reports of hazards by implementing and maintaining an effective Process Safety Culture Assessment program.

Most refineries in California have adopted some of the practices outlined above over the past decade. Those refineries have seen significant improvement in safety performance. However, the industry still experiences major incidents that pose a risk to workers, nearby communities, and cause disruption to fuel services. The regulation represents a comprehensive safety performance standard for the state’s refinery sector. Now that the Standards Board has approved the regulation, the Office of Administrative Law has 30 working days to review and approve it.

The new rules are part of a package of complementary regulations intended to make California refineries safer for both workers and surrounding communities. The companion regulation strengthens the California Accidental Release Prevention (CalARP) program, designed to prevent the accidental release of hazardous substances that could harm public health and the environment. The revised CalARP regulation will also be submitted to the Office of Administrative Law for approval in the coming weeks.

Following a chemical release and fire at the Chevron refinery in Richmond in 2012, the Governor’s Interagency Working Group on Refinery Safety called for the establishment of an Interagency Refinery Task Force. The task force was mandated to improve workplace safety and health, emergency preparedness and response procedures at refineries. The California Environmental Protection Agency formed the task force in August 2013, which includes DIR, eight other state agencies, the U.S. EPA, as well as local and regional agencies from across the state that have refineries in their jurisdictions.

Cal/OSHA’s PSM Unit is responsible for inspecting refineries and chemical plants that handle large quantities of toxic and flammable materials. Health and safety standards enforced by the PSM Unit, including adequate worker training and participation, are intended to prevent catastrophic explosions, fires, and releases of dangerous chemicals, which could harm workers.

Prior to 2012, Cal/OSHA’s PSM Unit conducted on average two to three planned refinery inspections per year, taking a single investigator approximately 80 hours to complete. Cal/OSHA has subsequently increased staffing of the PSM Unit from 10 to 24 staff members, including support personnel and investigators. The PSM Unit now has the resources to conduct more thorough inspections, deploying four to five inspectors at the four annual planned refinery inspections with an average of over 2000 hours at each planned inspection. In addition, the PSM unit invests 900 hours on average at each of the four turnaround inspections conducted at refineries each year. Turnarounds are scheduled operations where an entire process unit at a refinery is taken offline for an extended period for revamp or renewal.

Research Suggests Link Between Work-related Styrene Exposure and Lung Disease

With more plastic-based products on the market than ever before, concern about the work-related risks of the chemicals used to make them is increasing. One of these chemicals is styrene, a compound used extensively in plastic and rubber for cars, food packaging, boats, and many other products.

Scientific studies have linked work-related styrene exposure to asthma and an irreversible lung disease known as obliterative bronchiolitis. This rare lung disease causes scar tissue and inflammation in the small airways, which eventually makes it difficult to breathe. The National Institute for Occupational Safety and Health (NIOSH) recommends a styrene exposure limit of 50 ppm, or parts per million, over an 8-hour workday to prevent adverse health effects.

To understand whether work-related exposure to styrene increases the risk of asthma and obliterative bronchiolitis, NIOSH investigators analyzed 55 published studies and 2 additional unpublished case reports, according to their paper published in the American Journal of Industrial Medicine. They considered three types of studies, including those that reported individuals with lung disease, those that calculated death rates from lung diseases, and those that collected information from study participants at one point in time, known as cross-sectional studies.

Overall, they found 10 cases of obliterative bronchiolitis and 8 cases of asthma, with each case having had substantial styrene exposure. Among the cross-sectional studies, 87% had evidence that styrene exposure was associated with lung disease, and half of the death-rate studies had evidence that styrene exposure was associated with death from lung disease. In addition, 75% of the asthma cases reviewed had abnormal results following inhalational challenges to styrene. These findings suggest a relationship between styrene exposure at work and developing asthma and obliterative bronchiolitis. Although they do not prove cause and effect, the findings underscore the need for further research into the risk of styrene exposure at work

OSHA Finds Machine Safety Hazards, Lead Overexposure at Ohio Steel Plant

Republic Steel, an automotive steel manufacturer, faces $279,578 in proposed penalties from U.S. OSHA after agency investigators found workers at its Canton, Ohio, plant exposed to machine hazards and lead.

OSHA found one maintenance worker suffered severe injuries after being struck by an unguarded machine, and at least seven workers were exposed to excessive levels of lead, which can cause serious health issues.

“Companies must continuously monitor their facilities to ensure health and safety procedures are adequate and effective in protecting workers from injuries and illness on the job,” said Dorothy Dougherty, Deputy Assistant Secretary of Labor for Occupational Safety and Health.

On December 5, 2016, a 64-year-old maintenance worker suffered a fractured pelvis after being struck by a sail—a large clamp that holds the steel billet—because lock-out devices were not affixed to the machine’s operating parts to stop movement during maintenance.

A second inspection was opened on December 13, 2016, after a complaint alleged workers were being exposed to lead. Investigators documented seven incidents of lead overexposure in the caster facility.

In total, the agency found two repeated and five serious safety and health violations during the two inspections. OSHA found the company failed to:

  • Implement engineering controls to lower exposure to steel dust particulates;
  • Prohibit employees from eating in areas where lead exposure was possible;
  • Affix locking devices to machine operating parts during maintenance, and
  • Replace damaged guard and stair rails

In the past decade, Republic Steel has been cited for more than 250 safety and health violations at its facilities across the country. The company is a leading North American supplier of steel bars for automotive and industrial use.

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