6/26/2018 11:47 AM | 0 Comments

Guest Blogger: Tim Lodge




Every year, there are changes to compliance regulations and it can be difficult to understand them as well as meet the compliance deadlines, especially when you are focused on running and maintaining business operations. There are a few OSHA compliance updates that require your attention this year, including the OSHA electronic reports, the final rule on beryllium exposure, and the final rule on respirable crystalline silica. Learn more about these rules and how you can meet compliance before the deadlines.


Covered Establishments in All States Must Submit OSHA Electronic Reports

On April 30, 2018, the Occupational Safety and Health Administration (OSHA) announced it will require all establishments affected by the electronic reporting rule to submit their 2017 data to OSHA by July 1, 2018.


This announcement clarifies the requirement for establishments in states with an OSHA-approved plan. These establishments must submit electronic reports, regardless of whether the state has ratified or incorporated the electronic reporting rule into its OSHA state plan. The rule requires establishments to report data from their injury and illness records to OSHA electronically if they:

  •  Are already required to create and maintain OSHA injury and illness records and have 250 or more employees;
  • Have between 20 and 249 employees and belong to a high-risk industry (which includes manufacturing); or
  • Receive a specific request from OSHA to create, maintain and submit electronic records, even if they would otherwise be exempt from OSHA recordkeeping requirements.

These are the steps your establishment should take to ensure compliance:

  • Establishments in all states, including those with an OSHA-approved state plan, should prepare to submit electronic reports by July 1, 2018.

  • Becoming familiar with the requirements in the electronic reporting rule.

  • Transitioning their OSHA records to an electronic format approved by the Injury Tracking Application (ITA).


Final Rule to Protect Workers from Beryllium Exposure 

According to OSHA, about 62,000 workers are exposed to beryllium in their workplaces, including approximately 11,500 construction and shipyard workers. To prevent these risks of chronic beryllium disease and lung cancer, OSHA issued a final rule in January 2017 that amends its beryllium standards for the general, construction and shipyard industries. The rule became effective on May 20, 2017.

The final rule sets a new permissible exposure level (PEL) and requires new provisions to protect workers, including exposure control measures, exposure assessments, respiratory protection, personal protective clothing and equipment, and new conventions for housekeeping, medical surveillance, hazard communication and recordkeeping.


The final rule establishes two new PELs that apply to beryllium in all of its forms, compounds and mixtures:

  • The rule reduces the TWA PEL to 0.2 μg/m3 and creates a STEL PEL of 2.0 μg/m3.

  • It also creates a new action level of 0.1 μg/m3 calculated as an eight-hour time-weighted average.

These are the steps your company should take to ensure compliance:

  • Employers should become familiar with the new standards and evaluate their current workplace practices and training programs to ensure compliance with the final rule by the applicable deadlines.  

  • Employers must comply with most elements of the rule starting March 12, 2018 — one year from the original effective date.

  • Employers have an additional year — until March 11, 2019 — to provide required change rooms and showers, and an additional two years — until March 10, 2020 — to implement engineering controls.


Final Rule on Respirable Crystalline Silica 

About 2.3 million people in the U.S. are exposed to silica at work and those who inhale these very small crystalline silica particles are at increased risk of developing serious silica-related diseases, including Silicosis, an incurable lung disease that can lead to disability and death, lung cancer, Chronic obstructive pulmonary disease (COPD), and kidney disease. The rule reduces the permissible exposure limit (PEL) for silica to 50 micrograms per cubic meter of air (50 µg/m3) as an eight-hour time-weighted average and requires employers to implement specific measures to protect workers.


The final rule affects employers in the maritime, construction and general industries. The rule is effective June 23, 2016, but employers in the construction industry have until Sept. 23, 2017, to comply and employers in the maritime and general industries have until June 23, 2018, to comply.


These are the steps your company should take to ensure compliance:

  • Employers must develop a customized silica exposure control plan. This plan must be tailored to each employer’s needs and must address specific aspects of each work establishment.

  • The Commercial Lines team at Eastern Insurance can provide a Compliance Program Template that can be used as a starting point for employers in their compliance efforts. Employers must edit, add and alter all sections of this document to ensure their customized plan is in compliance with the new final rule. Contact our team here to get started.



At Eastern Insurance, we understand that navigating compliance regulations and rules can be confusing. We can work with you and your team to analyze and ensure that your manufacturing company is fully compliant with these OSHA standards.  To contact a member of our team, or to request an insurance consultation online, please visit our website or call us at (800) 333-7234 (Option 3).

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