Safety Consulting & Training
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The Heat is On in Texas! -Precautions Required for Indoor Work with no AC

Heat Advisory next 3 days

Sizzling heat has begun early this summer in Texas. This is evident from the salt lines on my black tee-shirt at the end of the day after helping clients with forklift observations. Most manufacturing companies have warehousing and shipping employees working in areas that are not air-conditioned. Some companies also perform production operations areas with no AC. We are blessed to not have to deal with working in the sun much.


In addition to the deaths of children in hot cars, and some August football practices that are reported on the news, we are still having 30-60 work-related heat illness deaths  each year in the U.S. Of course, there are way more cases of heat illness on-the-job where no-one dies happening as well.


It’s critical that each manufacturer put preventive measures to prevent heat illnesses in place now. I’ve listed some common and effective best practices below to get you started: (more…)

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Large Facilities have up to 4 Regulatory Filing Requirements in March

Large companies - This is your crunch time for EHS regulatory reporting!

Annual Waste Report (AWS) is due to TCEQ by March 1, 2022

This report is a summary of all the Hazardous and Class 1 wastes generated or shipped from the facility during the year. Companies normally have their waste hauler help them classify industrial wastes into regulatory waste streams categories. Some classifications are non-hazardous (which do not go on this report), an others may be deemed to be Hazardous or Class 1 wastes.

Tier 2 Report is due to TCEQ by March 1, 2022

Tier II is required for companies that have over 10,000 lb of a hazardous chemical on-site or 500 lb (and sometimes less) of extremely hazardous substances (EHS). The data from these reports is required  by the Emergency Planning and Community Right-to-Know Act (EPCRA) - Fire departments may access this during emergencies.

Uploading OSHA 300A Data for 2021 is due by March 2, 2022

Uploading 300A summary data on work-related injuries and illnesses during 2021 is required if your company performs industrial activities (such as manufacturing or printing) and had 20 or more employees during 2021. Companies in less hazardous industries don't need to report unless they have 250 or more employees.

Emissions Inventory Report is due to TCEQ by March 31, 2022

Companies with facilities that have significant air pollutants must prepare an annual Emissions Inventory Report (EI) showing monthly emissions for 2021.  The report summarizes the monthly VOCs used/emitted and the monthly HAPs (Hazardous Air Pollutants).

For more information on whether your company needs to make any or all of these filings click here.


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Reminder: Complete and Post the OSHA 300A Summary of 2021 Injuries & Illnesses by February 1, 2022

It’s time to complete your OSHA 300A Summary form of work-related injuries and illnesses for 2021. To complete the form, you will need your OSHA 300 log from 2021, the average number of employees during 2021, the business SIC or NAICS code, and the cumulative number of manhours worked by employees during 2021. The form needs to be signed by the owner or highest ranking company official working at the site, and posted for employees.

"The OSHA 300A Summary form for 2021 must be posted in the workplace for all of February, March and April"

Who needs to do this? If your company had 10 or more employees some time during the past year (and is not part of the government), you need to do this. (more…)

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OSHA Mandates a COVID Protection Program involving Vaccination, Testing & Masking for Large Employers

(Update note: Supreme Court Says No to OSHA Employers Vaccine-or-Test Mandate 1/13/2022, but leaves mandate in place for healthcare workers.)

WOW! OSHA ruling is Issued on Thursday, then a Circuit Court of Appeals grants an emergency stay on the ruling Saturday….  And so the roller coaster ride begins.

You may recall that President Biden announced on September 9 that OSHA was being tasked to create new regulation requiring large employers to keep a roster of employee vaccination status and implement specific COVID protections,  and that gives employers the green-light to mandate COVID vaccination for their employees, if they choose to. OSHA shared a plan with the legislature on October 12, and on November 4, the legislation was enacted.

COVID Vaccination Card

This new regulation is called “Emergency Temporary Standard (ETS) on Protecting Employees from COVID-19”. The media has begun calling it the “Vax or Test Rule”. The rule has language that limits states and municipalities from trying to ban employers from requiring vaccinations, face coverings, or COVID testing. The COVID ETS is being enacted for a 6 month period, with plans to re-evaluate it at the end of that period (When there is no longer a grave danger from COVID for workers, the ruling will be discontinued).

Prior to the ETS being issued, 27 states had announced plans to challenge the COVID ETS, and on Saturday (November 6) the 5th Circuit Court of Appeals granted an emergency stay of the newly enacted OSHA Emergency Temporary Standard. The government is expected to issue a response to this legal challenge on Monday (November 7). The Labor Department says they are confident in having legal authority to issue the ETS rule, and OSHA says they are fully prepared to defend the standard in court. Therefore, we should expect legal tussling over the new OSHA rule to be in our nightly news this week.

What does the Standard Require?

The regulation requires that employers with 100 or more employees (companywide) keep a roster on COVID vaccination status of their employees. They can either mandate that all employees be vaccinated, or they can allow any choosing to remain not-fully-vaccinated to go take a COVID test weekly (reporting any positive tests quickly, and staying out of work if diagnosed with COVID). In addition those choosing to remain unvaccinated will be required to wear a face-covering at all times when indoors at work or in a vehicle with another person for work. (more…)

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Companies must update their Stormwater Filings with TCEQ by Nov 12, 2021

Most all industrial sites and manufacturing companies are required to have a stormwater filing. Printing companies are included in this group. Stormwater filings must be updated every 5 years, and all companies have the same due date in Texas. The Texas Commission for Environmental Quality (TCEQ) has posted notice on their website that stormwater renewals are due by November 12, 2021. Your company likely received a notice from TCEQ as well.

Each company will need to have a company profile account with TCEQ. You can check your profile by going to and scrolling down to "Central Registry" and putting in your company name.

One person at your company likely already has a STEERs account with TCEQ, but if that person has left the company, you will need to contact them to set up a new authorized person to make  filings with the on-line e-permitting system.

Since most don't have paper scraps or chemicals outside, most printing companies can file a Stormwater No Exposure Certification (NEC). There will be a fee of around $100 due. The filing is fairly simple with eleven basic questions. The hardest part of the form is (more…)

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Steep Increase in Number of OSHA Compliance Officers for 2022

OSHA is really getting a boost from the Biden administration.  The OSHA budget was increased from $591 million in 2021 to $665 in 2022. A good portion of the funding will be used to significantly increase the number of safety & health compliance officers.

OSHA had a record low number of compliance officers in 2019, but they are slated to have way more in 2022. OSHA’s manning for site audits will be 32% higher in 2022 than it was in 2019.

OSHA conducted 33,000 inspections in 2019. Based on the increase in workforce, we are likely to have over 43,000 inspections in 2022. What does this mean for manufacturing companies?


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Small Aerosol Plays a Big Role in Spread of COVID-19

Scientists say there is mounting evidence that with indoor situations, tiny aerosols emitted when we talk are playing a significant role in the spread of COVID-19. This is very important information, since the initial message and focus was to contain the emission of larger particles when people cough, sneeze, sing, or yell, in hopes that catching these larger particles would be enough to contain the virus. The initial message implied that since the large particles normally don’t travel more than 6 feet (unless a fan of some type is in use), masking may not be necessary if people are reasonably distanced.

The current message from some scientists is that when we simply talk (and of course, cough), tiny invisible aerosols are also emitted and that the aerosol floats and disperses like cigarette smoke. This means that (more…)

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Determining whether a COVID Case is OSHA –Recordable Illness

OSHA has not made any official changes to exclude any work-related COVID-19 cases from OSHA logs. This link has some information on the topic: .

I was in a zoom meeting with JP Walsh, of OSHA this morning –and I asked about how we should make the call on which COVID cases would be considered “work-related”… This post reviews my understanding on this topic:

Examples on making calls on COVID cases  Work-Related. These call can sometimes be pretty subjective and difficult. Thereforeit’s important to conduct a basic investigation as soon the company is aware of the COVID case.  These are some examples of situations and what would be considered a reasonable call on work-relatedness:

* If a worker tells the company they recently tested positive for COVID and the company asks or allows them work with others (Is Work-Related).

* If two employees that do not work near each other, but went to lunch together a couple of times the week they both came down with COVID (Not Work-Related).

* The company follows local guidelines (masks, distancing, barriers, etc). If it seems possible that a 21 year old that never had symptoms (but was randomly tested and it came back positive) may have spread COVID to a couple of close co-workers…( A company could consider this Not Work-Related) because there is no screening that would have detected this case and prevented the spread.

* If three employees work closely together all get COVID in within a week … (For the two that have typical exposures at grocery stores, have friends over, etc –Not Work-Related. For the one that lives in total isolation from others (other than work) – Consider this one Work-Related, especially if contagion in the area was low).  On the other hand, if the city required masks in the plant and the company allowed these three to not wear masks at work for multiple close conversations per day without splash barriers between… Could consider all three cases as work-related).

The company should investigate (and document) whether a COVID case of an employee is work-related or not (to determine whether the case goes on the OSHA log). Some things you might want to determine: (more…)

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Rack Spacing and Anchoring in Warehouses

Most of our clients have some warehousing. When selecting, staging, and anchoring racks there are many factors to consider including the following:

    • Pallet depth vs rack depth
    • Aisle width vs lift trucks to be used
    • Where to place rows compared to structural beams
    • Can racks be moved without disassembly?
    • Length of spacers between back to back rack rows
    • How level is level enough?
    • How high can we stack leveling shims?
    • What size and anchor type should be used?
    • Should we use a racking contractor?


Download this pdf primer for insights on staging and anchoring racks.


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