We discussed the Occupational Safety and Health Administration’s rule to improve tracking of workplace injuries and illnesses as it progressed last year. The first reporting deadline for 2016 data was Dec. 1, 2017. It was moved back several times as industry pushed to get the rule repealed. But ultimately OSHA refused, and the rule did go into effect.
For 2017 data, the deadline is July 1, 2018, but you may want to get this done now. The first question is, “What data needs to be submitted?”For cotton gins, it is data contained on the OSHA 300A form. For many years, gins have been required to enter each work-related injury or illness on this form. At the end of the year, it must be totaled out, and the summary information added to the OSHA 300A form. For 2017, you should have already completed this process. For 2018, you should be keeping a new OSHA 300 form.
Enter Data And Post Forms
The 2017 OSHA 300A form should be completed at this point and must be posted in your workplace from Feb. 1 until April 30. If it is not, go to https://www.osha.gov/recordkeeping/RKforms.html to access the form and read the instructions for posting it.
The OSHA 300 and 300A system has been in place for many years. The new part of the rule requires data from the OSHA 300A form to be entered into the OSHA database. The good news is that for small businesses like cotton gins, it is only the 300A data. Larger businesses must enter all data from the OSHA 300 form, which is significantly more.
Since your OSHA 300A form is on the wall, now would be a good time to enter the data. The OSHA reporting website is https://www.osha.gov/injuryreporting/.
With the OSHA Injury Reporting Rule in place, we are seeing a higher rate of agency inspections. OSHA inspectors typically collect the OSHA 300 and 300A forms during each inspection. At this point, we don’t know if they are comparing the forms to the entries in the database, but it is probably safe to assume they will begin doing so at some point. If they see you have not entered your data in the system, then that would be a separate violation. This is a fairly simple system to navigate, so take a few minutes while you are thinking about it to enter your information into their system.
Kelley Green, director of technical services for the Texas Cotton Ginners’ Association, contributed this article.
Is Your Permit Up To Date? Do You Have Enough Bales?
After a big year like the 2017/2018 season, many gins processed a record crop. With the new emission factors, your permit has a limit on bales, and it is not dependent on the type of cotton you ginned. If you are not sure of your permit limits, give us a call or send us an email, and we will check it out for you. If you need to adjust your bales upward, now is the best time to do it.
If your permit has not already been converted to the new factors, you may have to go through public notice to it completely updated. This is generally a straightforward process, but it does take extra time.
After a big year, we typically see a lot of new equipment going into the gins. If you are making any sort of changes to your facility, be sure to let us know. Some things that seem major are actually very simple from a permitting standpoint. Other things that seem very minor are actually much more complicated from the permitting standpoint.
Let us know what you are doing, and we’ll figure out a plan to get your permit updated. We typically put the machinery upgrades and the increases in bales per year into the same package and get it all done at once. Permit times can be affected by a lot of issues. One of the main ones is how many other permits are submitted to the Texas Commission on Environmental
Quality. The TCEQ staff must process permits from many different industries. To be sure yours is reviewed in a timely manner, get it into the agency sooner rather than later.
Cotton Gin Renewals
Some ginners want to wait until their permit is renewed to get it updated. There are two problems with this plan. First of all, in most cases a permit update has to be handled separately from a renewal. You can do both at the same time, but they are two separate steps. In some ways, it may be simpler to do them separately. The second issue is timing. By waiting until the renewal comes around, you may get into problems with the TCEQ for not reporting changes in a timely manner.
Take a few minutes to check your permit to be sure it is up to date. If you need help locating your permit or any of your permit documents, we’ll be glad to email you a copy.
The Texas Cotton Ginners’ Association contributed this article.