January 2011- OSHA Recordkeeping & EPA Deadlines

Am I required to post OSHA forms?

According to OSHA the 300A Summary of Work-Related Injuries and Illnesses is required to be posted from February 1 to April 30 of each year.

How can I get copies of the recordkeeping forms? 

Copies of the forms can be obtained on OSHA's web site or from the OSHA publications office at (202) 693-1888.

Are the recordkeeping requirements the same in all of the States?

The States operating OSHA-approved State Plans must adopt occupational injury and illness recording and reporting requirements that are substantially identical to the requirements in Part 1904. For more information, see the discussion under "State Requirements," §1904.37.

Am I exempt from keeping Work-Related Injury and Illness Logs?

All employers covered by the Occupational Safety and Health Act (OSH Act) are covered by these Part 1904 regulations. However, some employers do not have to keep OSHA injury and illness records. For example, employers with 10 or fewer employees and business establishments in certain industry classifications are partially exempt from keeping OSHA injury and illness records.

Check out if you are exempt:

Partial exemption for employers with 10 or fewer employees.
Partial exemption for establishments in certain industries.
Partially Exempt Industries

How can I get help to find my SIC Code and determine if I'm partially exempt from the recordkeeping rule?

You can access the statistics section of OSHA's Statistic home page.  Go to the website and choose SIC Manual and follow the directions. If you still cannot determine your SIC code, you can call an OSHA area office, or, if you are in a state with an OSHA-approved state plan, call your State Plan office. OSHA Office Directory.

If I am partially exempt what am I still required to do under the standard?

All employers, including those partially exempted by reason of company size or industry classification, must report to OSHA any workplace incident that results in a fatality or the hospitalization of three or more employees (see § 1904.39).

Do I need to file Tier II's?

If you can answer “No” to any of the following questions then you may be in the clear:

Question #1: Do you do any one of the following; manufacture, use, store or process chemicals? (The simplified definition for “chemical”, pertaining to these regulations, is a product that you are required to maintain a MSDS. They include solids, liquids and gases.)

Question #2: Do you have chemicals contained within these products that contain any of the extremely hazardous chemical (EHS) list?

Question #3: Do any of these “Chemicals”, either by themselves or aggregated (based on your maximum amounts on any given day), meet or exceed the EHS Threshold Planning Quantities (TPQ) or 500 lbs.? (The only way that we can help you with this one is to screen for them.)

Note: Even if you answered “No” to either question 2 or 3 you still may have a requirement if you have any chemical that exceeds 10,000 lbs on hand any given day at you facility.

Upcoming EPA Deadlines

 Topic  Brief Overview  Deadline  Links
SARA Title III, 301-312
Emergency Planning and Community Right-to-Know Act (EPCRA)
Tier II reporting is a snapshot of a facilities hazardous materials storage activities. A report detailing the chemical and hazardous materials storage activities must be sent to the state and local authorities. SARA reports must be submitted for chemicals that meet the following criteria.

  • Extremely Hazardous Substances (EHS) in excess of 500 lbs or the listed Threshold Planning Quantity (TPQ) whichever is lower.
  • Hazardous substances in excess of 10,000 lbs.
Tier II Reports due March 1st of each year Laws and Regs

EPCRA – Local Emergency Planning Requirements

E&SSG Solution
Annual / Biennial Haz Waste Reporting
Facilities generating hazardous waste must submit annual and biannual reports to the state. Reporting frequency varies by state. Annual Reporting
March 1 of every year
Biennial Reporting
March 1 of even numbered years covering generator activities for the previous year.

Basic Info

Guidance, Policy and Resources

RCRA Online Brochure

Training requirements question


Video on how to fill out your forms (47 minutes).  Get your forms here

Disclaimer: These Regulatory Reminders are not intended to be an exhaustive source for all of your particular facility’s compliance issues. They are designed to address the basics requirements with which most companies are required to comply. Following the Regulatory Reminder’s deadlines and Monthly Focus will not guarantee your compliance as these reminders are simply designed to help in your environmental/safety compliance efforts. You should always refer to the federal and your state’s regulations for all your requirements. Ultimately, your compliance with federal and state regulations is your responsibility. E&SSG assumes no liability for your compliance or the resources provided in these “Reminders”.

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