What to Expect from OSHA in 2024

Another year is on its way. With that, there are updates and changes being made in the Safety World, particularly within the Occupational Safety and Health Administration (OSHA) and other regulatory agencies. The safety of employees is not a choice; it is a responsibility we all take on. With that duty, achieving safety for employees and maintaining OSHA compliance requires a proactive approach. This article will help you see what’s coming down the pipeline in the safety world.

OSHA Citations Get More Expensive

Each year the maximum penalty fines increase with inflation. Effective January 16th OSHA’s maximum penalty for Serious, Other-Than-Serious, and posting violations increased from $15,625 to $16,131 per violation. This fine increase has also been applied to the fines for failing to abate the violations with the difference of that fine being able to be applied PER DAY the violations are not abated. In addition to those fines, the maximum penalty for Willful and Repeat violations has increased from $156,259 to $161,323 per violation.

These increases come to approximately a 3.24% percent increase from 2023 to 2024. This type of increase is common year over year with OSHA.

Along with the increase in monetary fees associated with citations, OSHA has recently issued a memorandum for regional administrators that reinforces OSHA’s ability to split violations individually rather than grouping them together at their discretion. Times when the directors may split violations into individual citations rather than group them together include, but are not limited to, cases which have different abatement methods, each condition can result in serious physical harm or death, or the situation exposes workers to related but different hazards. It is rumored that this could lead to significantly more citations from violations due to lockout/tagout, machine guarding, permit-required confined space, respiratory protection, falls, as well as for cases with other-than-serious violations pertaining to recordkeeping. OSHA states that this should be used as needed to “enhance deterrence” and “more accurately capture an employer’s lack of compliance”. This can be looked at as a method for OSHA to put more monetary pressure on companies and employers who have been cited before as a way to compel them into compliance. Whether this approach is fully legal for all types of violations or not is up for debate. In the meantime, it would be beneficial to continue to take a proactive approach in ensuring your facility is fully in compliance with all of OSHA’s applicable rules and regulations through safety inspections, program reviews, and training.

OSHA’s Digital Shift

As of January 1st, OSHA’s regulation on occupational injury and illness reporting is in effect. This regulation requires certain employers to submit their OSHA 300 logs electronically to the OSHA website by March 2nd of each year. This regulation applies to employers with 100 or more employees in specified “high hazard” industries. Additionally, employers are required to maintain records of the logs on-site for at least five years as well as post the previous year’s data from February through April in a conspicuous location where notices to employees are typically placed (which has been a requirement for some time). With the electronic submission of these records, more information will be required to be submitted, thereby more information on employer sites will be available to the public. The list of “high hazard” industries can be found here (https://www.osha.gov/recordkeeping/naics-codes-electronic-submission).

 National Emphasis Program on Warehouse Safety

OSHA has launched a three-year National Emphasis Program (NEP) to focus guidance and enforcement on Warehouse Safety. This will include warehouses, processing facilities, distribution centers, and high-risk retail locations. The primary focus of this NEP includes hazards related to powered industrial trucks, material handling and storage, walking and working surfaces, egress, fire protection, heat illness, etc. This NEP directs regional offices to conduct more inspections of facilities that fall within the sectors listed above, as well as facilities that can be categorized as large retail establishments with warehousing and distribution centers that have high rates of injury and illness. The reason OSHA is implementing this NEP stems from the statistics pointing to warehousing and distribution centers posing serious safety and health hazards.

Other Standards Updates

  • The American Welding Society (AWS) is partnering up with the Standards Committee for R15.06 Safety Requirement for Industrial Robot Systems. This partnership’s goal is to harmonize the safety standards for robotic welding systems in order for users to better understand the safety requirements of the whole system (robot system and welding equipment) to provide a safe workplace and comply with regulatory requirements.
  • The user requirements sections for R15.06 – Safety Standard for Industrial Robot Systems and R15.08 – Safety Standard for Industrial Mobile Robot Systems are being drafted. The user requirements (Part 3) will be the bridge between the safety requirements of the machines and systems and the OSHA requirements for safe operation.
  • OSHA is being further trained on the inspection of robot systems. This training is educating inspectors on the real-world operations and limitations of robot systems. A highlight of this training includes an OSHA Inspector’s first question when looking at a robot system being “Can I see your Risk assessment.” This is because the R15.06 and R15.08 standards require the user be provided a comprehensive risk assessment from the Integrator of the system as well as conduct an as-installed risk assessment of the system once it is in place at the facility.
  • NFPA Standards on Combustible Dust are being edited and updated to be compiled into one master standard that will be known as NFPA 660. This updated standard will include the requirements and informative references identified in NFPA 61, 91, 484, 652, 654, and 664.

It is important for all of you and the facility personnel you work with to be up to date on the changes happening in the safety regulation and standards world. With these changes comes opportunities to further improve the safety in your workplaces. Safety is not a choice; it is a responsibility.

If you need assistance with ensuring you are in compliance with all OSHA requirements, please contact CTI at (770) 263-6330.

Leave a Reply

Your email address will not be published. Required fields are marked *