Injury Recording Requirements
If your electrical contracting firm had more than 10 employees at any time during the last calendar year, you must keep the following injury and illness records.
- Worker’s and Employer’s Report of Occupational Injury or Disease (Form 801)
- Log of Work-Related Injuries and Illnesses (OSHA Form 300)
- Summary of Work-Related Injuries and Illnesses (OSHA Form 300A)
The Log (Form 300) is used to classify work-related injuries and illnesses and to note the extent and severity of each case. Injuries that require more than minor first aid treatment are considered recordable and must be entered on the Log within 7 calendar days of the event.
At the end of the year, employers review the Log, calculate incident rates and transfer category totals onto the Summary (Form 300A). This summary is to be posted by February 1st through April 30th in a conspicuous place accessible to employees.
If you have more than one establishment, you must keep a separate Log and Summary for each physical location that is expected to be in operation for one year or longer.
Cases listed on the Log are not necessarily eligible for workers’ compensation or other insurance benefits. Listing a case on the Log does not mean that the employer or worker was at fault or that an OSHA standard was violated.
While the OSHA 300 Log and Summary are mandatory recordkeeping requirements that once completed and posted satisfy OSHA, they can also be used as an instrument to help identify areas where your safety program may need to be modified. Your OSHA 300 reports should be incorporated into your safety committee meetings and jobsite toolbox talks.
While post-accident reports are considered a lagging indicator, they can still provide valuable information to assess trends such as severity and frequency of workplace injuries. From there, adjustments to safety policies, procedures, training and PPE can be implemented to prevent recurrence.
Updated Online Injury Reporting Requirements
Construction employers with 20 or more employees are also required to electronically submit information from their 300A Summary forms to Federal OSHA using the Injury Tracking Application portal. It must be uploaded no later than March 2nd, 2023.
NEW – The OSHA Injury Tracking Application has transitioned its login procedure to the public’s one account access to government applications, Login.gov. All current and new account holders must connect their ITA account to a Login.gov account with the same email address to access the application for the 2023 collection of Calendar Year 2022 Form 300A data. Be sure to review the guidance and then create your new account. This sounds more complicated than it really is. Review this short video if you are having any troubles linking your existing ITA account to your new Login.gov account, or contact me for assistance.
As you compile your 2022 injury and illness records for internal review, posting and online reporting, please keep in mind the Commercial CBA requirement to notify your NECA-IBEW Joint Safety Committee of injuries to apprentices and Journeymen. Injury trends you identify and share with the Committee help us meet our mission statement and overall duties to the industry.
OSHA’s “New” Instance-by-Instance Citation Directive
Employers who use leading indicators to measure and improve their safety programs tend to have better outcomes than those who are more reactionary in nature, focusing only on lagging indicators, such as injury rates or the number of OSHA citations they receive.
Even so, it is still important to understand the strategies OSHA can use to “motivate” employers towards compliance. OSHA’s consultation program, a leading indicator, can provide good insight to employers on areas of improvement needed before an injury occurs, or a citation is issued.
Citation. Singular. Currently, OSHA can, and does, issue citations for multiple violations however, a new directive and enforcement memo recently issued from Federal OSHA may now cause employers to receive multiple citations for the same individual violation.
This strategy is known as their “instance-by-instance” or “IBI” policy. Penalty adjustments are a tool that OSHA enforcement personnel can use to cite and assess penalties for each instance of a workplace health & safety violation separately. Since introducing the policy in 1990, OSHA has used instance-by-instance citations for only the most egregious, willful employer violations.
OSHA now aims to apply IBI penalties to “achieve an additional deterrent effect” for noncompliance with some of the most frequently violated Standards applicable to the industries we commonly work in, Construction and General Industry. This includes:
As of March 26, Federal OSHA compliance officers will be able to use IBI citation policy to determine penalties for violations of the hazards listed above. Oregon OSHA has yet to weigh in on how / if this will apply locally however, State OSHA Plans, like Oregon and Washington, must be “equally as effective” as OSHA in their enforcement activity.
As I previously reported, Oregon is already under scrutiny from OSHA due to not meeting minimum number of inspections over the last 3 years (FAME report) and I expect them to apply the IBI to minimize any further negative audit reports.
OSHA Recordkeeping – Posting & Online Reporting Due Soon
Injury Recording Requirements
If your electrical contracting firm had more than 10 employees at any time during the last calendar year, you must keep the following injury and illness records.
The Log (Form 300) is used to classify work-related injuries and illnesses and to note the extent and severity of each case. Injuries that require more than minor first aid treatment are considered recordable and must be entered on the Log within 7 calendar days of the event.
At the end of the year, employers review the Log, calculate incident rates and transfer category totals onto the Summary (Form 300A). This summary is to be posted by February 1st through April 30th in a conspicuous place accessible to employees.
If you have more than one establishment, you must keep a separate Log and Summary for each physical location that is expected to be in operation for one year or longer.
Cases listed on the Log are not necessarily eligible for workers’ compensation or other insurance benefits. Listing a case on the Log does not mean that the employer or worker was at fault or that an OSHA standard was violated.
While the OSHA 300 Log and Summary are mandatory recordkeeping requirements that once completed and posted satisfy OSHA, they can also be used as an instrument to help identify areas where your safety program may need to be modified. Your OSHA 300 reports should be incorporated into your safety committee meetings and jobsite toolbox talks.
While post-accident reports are considered a lagging indicator, they can still provide valuable information to assess trends such as severity and frequency of workplace injuries. From there, adjustments to safety policies, procedures, training and PPE can be implemented to prevent recurrence.
Updated Online Injury Reporting Requirements
Construction employers with 20 or more employees are also required to electronically submit information from their 300A Summary forms to Federal OSHA using the Injury Tracking Application portal. It must be uploaded no later than March 2nd, 2023.
NEW – The OSHA Injury Tracking Application has transitioned its login procedure to the public’s one account access to government applications, Login.gov. All current and new account holders must connect their ITA account to a Login.gov account with the same email address to access the application for the 2023 collection of Calendar Year 2022 Form 300A data. Be sure to review the guidance and then create your new account. This sounds more complicated than it really is. Review this short video if you are having any troubles linking your existing ITA account to your new Login.gov account, or contact me for assistance.
As you compile your 2022 injury and illness records for internal review, posting and online reporting, please keep in mind the Commercial CBA requirement to notify your NECA-IBEW Joint Safety Committee of injuries to apprentices and Journeymen. Injury trends you identify and share with the Committee help us meet our mission statement and overall duties to the industry.
Apprentice Termination Notice ROF
Contractor Injury Reporting Requirements
Electrical Vehicle Infrastructure Training Program (EVITP)
EVITP- Get Certified “for free”
The BALMCC has offered to reimburse any member who has completed the EVITP online course and certification exam.
Members should register for the course now, as the sponsorship will end July 2023.
With an increased interest in “going green” and Electric vehicle Infrastructure at a local and National level, the EVITP certification is a worthy accomplishment that could open doors to future opportunities only available to Certified installers.
The Training Center will facilitate the documentation process of notifying the BALMCC upon course completion to reimburse those that have become Certified.
For course info: https://secure.tradeschoolinc.com/v5/nietc-org/classSchedule/index.php
Oregon to Washington Reciprocation
If you have an Oregon General Journeyman License you may reciprocate to Washington to acquire your Washington Certificate.
The following is from the Washington L&I website:
“Washington reciprocal certificates are generally available to those electricians who obtained their Oregon general journeyman electrician (J) licenses after completing 8,000-hour Apprenticeships requiring at least 576 classroom hours of education and passing Oregon exams. Anyone having an Oregon General Supervising Electrician (S) license obtained by Oregon examination is also eligible.
If this describes you, and you have never held a Washington (01) general journey level electrician certificate before, or failed to pass an exam for one in the last two years, and you are not otherwise disqualified by conditions in WAC 296-46B-942(20), you are likely eligible.”
To apply, submit an Application for a Reciprocal 01 General Journey Level Electrician Certificate (F500-148-000).
Here is the link: https://lni.wa.gov/forms-publications/F500-148-000.pdf
No waiting periods apply. Oregon license holders can apply any time after they receive their Oregon license.
For licensing verification from Oregon, submit Part C of the Washington reciprocal application to Oregon as follows:
By mail:
Department of Consumer and Business Services Building Codes Division
PO Box 14470
Salem, OR 97309
By fax: 503-378-2322
Oregon charges no fee to process verification requests. Once completed, the original form will be returned by mail if you do not provide instructions requesting it be returned by fax and a fax number to send it to. Please direct questions about Oregon licensing verification to:
license.bcd@oregon.gov.
NIETC Graduation Ceremony at the Hyatt Regency Hotel
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