COTTON FARMING IS THE OFFICIAL PUBLICATION

OF THE GINNING INDUSTRY.

OSHA Changes RuleOn Injury Reporting

The Occupational Safety and HealthAdministration (OSHA) has ratherabruptly issued a new rule, changing therequirements for reporting injuries andfatalities. Under the old rule, employerswere required to notify OSHA withineight hours of the event if they had aworkplace-related fatality, or if a work-place accident resulted in the hospitaliza-tion of three or more employees.

The requirement for fatalities hasremained essentially the same under thenew rules, but requirements for reportinginjuries have changed significantly.

First of all, they have changed the timerequirement for reporting injuries. Youhave 24 hours from the time you learn ofan injury to report it. On the other hand,you now have to report any time a singleworker is hospitalized for treatment dueto a work-related injury. In addition, anyeye loss must be reported, as well as any amputation.

The amputation requirement is wherethe real issues begin. When OSHA origi-nally proposed this updated reportingrequirement, it had used a definition ofamputation that required the loss of bonebefore an injury would count as an ampu-tation. This rule was sent out for publiccomment in 2011 and was then left dor-mant. Last month, OSHA suddenlyissued the final rule, which goes intoeffect on Jan. 1, 2015.

The big surprise comes when you readthe final rule carefully and discover thatthe definition of amputation has beenchanged to one that does not require lossof bone or hospitalization. So, now thatthe rule is final, the loss of a fingertip ortip of a toe without any bone loss or hospi-talization is supposed to be reportedto OSHA, according to this updatedfinal rule.

In the final rule, OSHA stated thatthere were 14 hospitalization incidentsreported in 2010 under the old rule. Theagency is estimating there will bebetween 66,000 and 100,000 injuriesreported per year under the new rule.Stay tuned as employers and our

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associations work to figure out how to work withthese new definitions, but be aware that startingin 2015, most employers will find themselveshaving to report fairly minor injuries to OSHA.

There is always the chance that someone willdecide to challenge this rule in court, but most ofthe experts seem to think that a challenge wouldbe difficult. On the other hand, it remains to beseen what OSHA will do with the increase inreports. If it receives the numbers being predict-ed, it is hard to imagine how the agency will findthe time to read them all, much less actuallyrespond to each one.

Kelley Green of the Texas Cotton Ginners’Association contributed this article. Contact himat kelley@tcga.org.

Cotton’s CalendarNov. 11-12 – Pink Bollworm Meeting, Phoenix, Ariz.Nov. 11-14 – CCI Sourcing Summit, Scottsdale, Ariz.Nov. 12-13 – CI Crop Mgt. Seminar, Tifton, Ga.Nov. 19 – PCCA Board meeting, Lubbock, Texas.Dec. 2-3 – Boll Weevil Action Comm. – Little Rock, Ark.Dec. 9-11 – Cotton Board meeting – St. Petersburg, Fla.Dec. 17 – Staplcotn Board Meeting, Greenwood, Miss.Jan. 5-7 – BWCC, San Antonio, Texas.Jan. 14 – PCG Quarterly Meeting, Lubbock, Texas.Jan. 14-16 – Cotton/Rice Conference, Baton Rouge, La.

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