What OSHA’s Spring 2018 Regulatory Agenda Reveals

05/18/2018

Last week, OSHA released its semi-annual Regulatory Agenda, which indicates the various activities the agency plans to pursue that year and beyond.

The spring 2018 Regulatory Agenda Proposed Rule Stage entries, include:

• Hazard Communication Standard (HCS or HazCom) – OSHA indicated its plans to propose regulatory amendments in February 2019. These amendments would harmonize the HCS to the latest version of the GHS (GHS Revision 7) and codify a number of enforcement policies that have been issued since the agency first updated the standard in 2012.

• OSHA’s Recordkeeping Standard – OSHA is seeking to amend its recordkeeping regulation to remove the requirement for establishments with 250 or more employees – which are required to routinely keep injury and illness records – to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report). Expected by July 2018, the proposal would require these establishments to only electronically submit information from the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses).

• Occupational Exposure to Beryllium – OSHA expects to complete revisions to its general industry beryllium standards by late 2018 or very early 2019. The agency is also slated to release a final rule on beryllium in the construction industry and shipyards before the start of its fiscal year 2019 on October 1.

Other entries in the Agenda’s Prerule Stage that allude to changes OSHA could eventually make a priority, include:

• Emergency Response and Preparedness –Many of the standards OSHA currently uses to regulate aspects of emergency response and preparedness were promulgated decades ago and were not designed as comprehensive emergency response standards. Consequently, they do not address the full range of hazards or concerns emergency responders currently face, nor do they reflect all the major developments in safety and health practices that have already been accepted by the emergency response community and incorporated into industry consensus standards or changes in performance specifications for protective clothing and equipment. OSHA has acknowledged this, and the move of its standards governing emergency response and preparedness to the prerule stage indicates the agency’s plans to consider updating these standards with information gathered through an RFI and public meetings.

• Lockout/Tagout – Recent technological advancements that utilize computer-based controls of hazardous energy (e.g., mechanical, electrical, pneumatic, chemical, and radiation) conflict with OSHA’s existing lockout/tagout standard. The agency has recently seen an increase in requests for variances for these devices, and an RFI is planned to help understand the strengths and limitations of this new technology as well as any potential hazards to workers.

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