We’ll look at an even dozen: you can slot them into your calendar and update one of these programs each month. We’ve assigned a specific month to each, but with the exception of the February annual posting requirements, you can do them whenever it is convenient for you. It may also be that not all of these standards apply to your site. Feel free to rearrange or delete these reviews as it best suits your workplace.
1. January: Lockout/Tagout
If you have a lockout/tagout program, OSHA requires you to review your energy control procedures at least annually to ensure that the procedure is in compliance with the standard, and that workers are following them.
2. February: Annual Posting
By February 1, all employers that are required to keep records of work-related injuries and illnesses must post Form 300A in a conspicuous place where notices to employees are customarily posted. The form must remain on display until April 30.
The annual summary compiles information recorded on OSHA Form 300, Log of Work-Related Injuries and Illnesses (also known as the OSHA 300 Log), during the previous calendar year. For example, the Form 300A posted from February 1 to April 30, 2014, must include injuries and illnesses recorded on the OSHA 300 Log from January 1, 2013, to December 31, 2013.
3. March: Hearing Conservation
For employers who have a hearing conservation program in place, some portions of the program have annual requirements.
Annual audiograms. For each employee who has received a baseline audiogram and who is exposed at or above 85 decibels as an 8-hour time-weighted average, you must complete a follow-up audiogram annually, for comparison purposes. The annual audiogram must be compared to the baseline audiogram to determine if a standard threshold shift (a permanent change in the worker’s hearing) has occurred.
Audiometer calibration. Audiometers used to perform audiograms must be calibrated acoustically at least once a year.
Training. Workers enrolled in a hearing conservation program must be retrained annually, and the training materials must also be updated annually.
4. April: Bloodborne Pathogens
For workplaces with bloodborne pathogens exposures, some parts of the program require annual review and updates:
The exposure control plan must be reviewed and updated at least annually, to reflect new or modified tasks and procedures affecting occupational exposure, to reflect new or revised employee positions with occupational exposure, and to make note of any changes in available technology. In addition, affected employer must document annually that they have considered and implemented any newly-available devices or technologies that can minimize exposures.
The biosafety manual. If you have a biosafety manual, it must be reviewed and updated at least annually.
Training. Workers with occupational exposure to bloodborne pathogens must receive annual training.
May: Process Safety Management
For employers who are subject to the process safety management standard (29 CFR 1910.119), many of the requirements for periodic review and updating run on three- or five-year cycles. However, there is one set of documents that must be reviewed at least annually: your operating procedures. Under the standard, you must review your operating procedures “as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities,” but you must certify at least once a year that your operating procedures are current and accurate.
For employers subject to HAZWOPER rules, there are annual retraining requirements. Employees, managers, and supervisors must receive eight hours of annual refresher training covering specified topics, as well as any incidents that occurred in the past year that could serve as training examples. The requirement also applies to workers in TSD operations.
Specialist employees and emergency responders must either receive training or demonstrate competency in their area of specialization once a year.
Tomorrow, we’ll finish out the year with additional annual requirements.