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OSHA is currently requesting action on two concerns that affect employers.

OSHA Seeking Silica Standard Feedback

OSHA is considering potential revisions to Table 1 of its Respirable Crystalline Silica Standard for Construction, and requesting input on additional engineering and work practice control methods to effectively limit exposure to silica for the equipment and tasks currently listed. The agency is also requesting information about other construction equipment and tasks that generate silica that it should consider adding to Table 1, along with information about their associated engineering and work practice control methods.

Among the revisions OSHA is those in paragraph (a)(3) of the Respirable Crystalline Silica Standard for General Industry to make the circumstances under which general industry and maritime employers would be permitted to comply with the silica standard for construction as an alternative to the general industry standard more broad.

The information submitted to OSHA will help the agency consider new developments and enhanced control methods for equipment that generates exposures to silica, and provide additional data on exposures to silica from equipment and tasks using a variety of control methods under different workplace conditions. Expanding Table 1 to include additional engineering and work practice control methods, equipment, and tasks provides employers with more flexibility and reduce regulatory burdens while also maintaining protections for employees.

Feedback can be electronically submitted to OSHA at, or by fax or mail by November 13, 2019. View the Federal Register notice for more information.

Our upcoming live webinar, “OSHA’s Silica Rule: What You Need to Do to Comply” on October 24, 2019 from 11am – 12pm ET reviews the basics of the rule, and what different industries will need to do in order to be prepared if inspected by OSHA.

Late Injury and Illness Report Forms

OSHA is also reminding employers subject to its Recordkeeping Rule who have not already done so to submit their 2018 OSHA Form 300A (Summary of Work-Related Injuries and Illnesses).

Under the Improve Tracking of Workplace Injuries and Illnesses final rule, establishments with 250 or more employees that are required to keep injury and illness records, as well as those with 20 to 249 employees in certain high-hazard industries, must submit Form 300A – a yearly summary of injury and illnesses data – via OSHA’s Injury Tracking Application (ITA) each year.

In 2019, the submission deadline was moved to March 2, which was significantly earlier than it had been for the previous two reporting years since the final rule went into effect. As a result of the confusion, some covered employers may have inadvertently missed the deadline.

Still have questions? Learn more about OSHA’s ITA Submission Deadline on our blog, and download our OSHA ITA Cheat Sheet for a helpful guide for navigating the submission process.