OSHA has rewritten the Hazard Communication Standard, and all employers (including agricultural employers) were required to have their workers trained on this new standard by Dec. 1. This rulemaking is complete and being implemented.
A second rulemaking that would directly affect agriculture was proposed earlier in the month. Under current rules, all workplaces with 10 or more employees are required to collect their illness and injury data on OSHA 300a forms (or equivalent). This data must then be transferred to an OSHA 300 form. The 300 form is sort of a summary of everything that happened during the year. This form must be posted in the workplace from Feb. 1 until April 30 of each year. These forms must also be kept for a five-year period and made available to certain folks if required.
As you can see above, OSHA already requires most employers to collect and maintain injury records and to make them available to workers, former workers and OSHA under certain circumstances. The new wrinkle is that OSHA’s latest proposal would require covered employers to key their employee injury data into an online OSHA database. OSHA would then make this data public. Its argument is that this would help workers pick the safest companies for which to work and give the public better information about a given work site.
The government agency also argues that the information is already public since OSHA currently has the right to come to your work site and review these records.
Most folks will immediately spot a few problems with this proposed rule. First, the idea of entering medical information of any type into an online database makes a lot of people nervous, although the federal government is fairly certain it can manage this type of data successfully. Second, the idea of sharing your workers’ injury data with the world is something that will give a lot of folks concern. Even if you leave off names and identifying information, it is still concerning.
Finally, while we are keeping this information in paper form at our businesses, there is a lot of information you keep in a file for possible review by a government regulator that probably does not belong in a public database online.
This proposal is likely to get the privacy advocates really fired up. You may want to keep your ears tuned to this issue as 2014 rolls around. I suspect this rulemaking will be a lively one
Kelley Green, director of technical services for the Texas Cotton Ginners’ Association, contributed this article. Contact him at email@example.com or by telephone at (512) 476-8388.
BWCC To Host Ginning Conference
The 30th annual Cotton Ginning Conference will be conducted as part of the Technical Conferences at the Beltwide Cotton Conferences in New Orleans on Jan. 7. This event provides a forum for researchers and industry representatives to exchange information on new technology to improve gin operation efficiency and the preservation of fiber quality.
Industry issues are addressed by researchers and industry experts covering areas such as innovative management strategies, energy conservation, environmental regulations and compliance, labor law compliance and safety.
For more information, interested parties should go to www.cotton.org/beltwide.