On April 26, 2010, many of us were in Pittsburgh attending the PMPA’s National Technical Conference…

Connecting to find 'Tools You Can Use'

 …while OSHA Administrator David Michaels announced the OSHA spring regulatory agenda.
This agenda only represents the items that OSHA is moving agressively forward on at this time.  these are items Michaels characterized as “long overdue.”
Ambitious agenda.

Items that will impact your precision machining shop include:

  1. Injury and Illness Prevention Program
  2. Changing the Occupational Injury and Illness Recording and Reporting Requirements
  3. Adding a Musculoskeletal Disorders column to the OSHA 300 log
  4. Increased enforcement of Ergonomics under the “General Duty” clause.
  5. Beryllium
  6. Walking Working Surfaces
  7.  

The Injury and Illness Prevention  ‘Plan-Prevent-Protect’ Program is a significant expansion of these kinds of requirements in the Labor Department. The proposed regulatory actions  require employers to develop programs to:
Plan –The Department will propose a requirement that employers and other regulated entities create a plan for identifying and remediating risks of legal violations and other risks to workers.
Prevent-The Department will propose a requirement that employers and other regulated entities thoroughly and completely implement the plan in a manner that prevents legal violations.
Protect- The Department will propose a requirement that the employer or other regulated entity ensures that the plan’s objectives are met on a regular basis. 
“Employerswho fail to take these steps… will be considered out of compliance with the lawsubject to remedial action.”-  excerpted from the Spring Agenda Narrative Page .
This sounds to me  remarkably like a means to get even more paperwork violations- a  pretext to fine employers even when no injury has occurred.
Copy of the Semiannual Regulatory Agenda
David Michaels photo credit Industry Week
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