Workplace Safety Developments on the Horizon

Safety on the job is a key concern at GAI, and the primary responsibility of our guest blogger Pamela Walaski, CSP, CHMM, GAI Health & Safety Director. Ever alert for new developments, Pam shares some upcoming issues associated with workplace safety practice and policy.

Is your AEC firm in the know about workplace safety related happenings that are on the horizon for the end of the year? Here’s a quick summary of developments to watch in the near future:

New Assistant Secretary of Labor

Scott Mugno

Just as the final edits to this blog were being completed, Scott Mugno was nominated to lead the Occupational Safety and Health Administration (OSHA) as assistant secretary of labor. Scott hails from Western Pennsylvania, where he is the currently vice president of Safety, Sustainability, and Vehicle Maintenance for FedEx Ground.

Given that the largest cause of workplace fatalities continues to be motor vehicle accidents, Mugno’s experience in the trucking industry and his current role at FedEx is expected to bring a focus on vehicle safety. As a business representative, early commentary about his tenure (should he be approved), indicates Mugno can be expected to try and shift the current balance from the enforcement focus of previous Assistant Secretary David Michaels, to more compliance assistance for employers.

It remains to be seen how Mugno would handle OSHA’s budget, which has been essentially flat since 2010. As a member of a Republican administration with a rule of one-in, two-out (every new regulation instituted is required to be offset by the repeal of two existing regulations), early speculation is that several workplace safety initiatives currently on the regulatory agenda will either be scrapped or delayed; these initiatives include new workplace violence and cellphone tower standards, as well as revisions to the Process Safety Management standard.

The next step in the nomination process is Mugno’s appearance before the Senate Health, Education, Labor, and Pensions Committee (HELP), which is chaired by Republican U.S. Senator Lamar Alexander from Tennessee. The ranking Democrat is U.S. Senator Patty Murray from Washington State. A date for that hearing has not been announced as of this writing.

New OSHA Electronic Reporting Requirements

Speaking of OSHA, the first major implementation deadline for electronic reporting of recordable incidents of workplace illness or injury is approaching. December 1, 2017, is the day when all establishments with 250 or more employees—and those with between 20 to 249 employees in certain high-hazard industries—are required to electronically provide OSHA with information from their 2016 Form 300A. It should be noted that, while many AEC firms meet the 250 employees threshold, few, if any, will fall under the high-hazard industries required to report, which include construction, transportation, forestry, fishing, and utilities. The original deadline of July 1, 2017, was extended earlier this year in part due to problems with the online reporting system.

December 1, 2017, is the day when all establishments with 250 or more employees are required to electronically provide OSHA with information from their 2016 Form 300A.

This is the just the first of several additional reporting requirements that will be phased in over the next two years. In 2018, larger employers will be required to electronically submit their Forms 300A, 300, and 301s, and smaller employers will see their submission deadline moved up from December 1 to July 1. Starting in 2019, submissions deadlines for both groups will be moved up to March 2.

Of critical importance in the OSHA regulatory language is the use of the word “establishment”; according to OSHA, an establishment is a single physical location where business is conducted. That means an AEC firm with multiple offices (establishments) will only have to submit reportable incident documents for offices that meet the 250 threshold. An AEC firm like GAI Consultants—which has a corporate office staffed by more than 250 employees, and many smaller offices staffed by less than 250 employees—will only need to submit its Form 300A for the corporate office.

For more information and resources on the OSHA electronic recordkeeping submission requirements, visit the dedicated web page on the OSHA site.

Workplace Safety Is Everyone’s Business

Workplace safety is a concern that we all share and an issue that affects every industry. For AEC firms, the challenge is to adopt and apply effective safety policy and practice across a diverse range of worksites. At GAI, we are ever vigilant for ways to optimize our workplace safety performance and always watchful for advances and challenges that affect meeting our safety goals. Please feel free to contact me to share your workplace safety questions and insights.


Pam WalaskiPamela Walaski, CSP, CHMM has provided health, safety, and environmental support for more than 20 years. She is skilled in risk management, occupational safety and health management systems, and training for curriculum development, implementation, and auditing. Pam may be reached by phone at 412.399.5143 or follow her on Twitter at @safetypam.

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