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Large Facilities may have up to 4 Regulatory Filing Requirements in March 2026

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

As commercial printers become larger, some environmental and community hazard reporting requirements may be needed (in addition to the OSHA reporting requirements discussed in a previous email).

a) Annual Waste Report (AWS) (listing hazardous wastes shipped in 2025) is due to TCEQ by March 1, 2026

b) Tier 2 Report (summarizing significant quantities of hazardous materials kept on-site in 2025) is due to TCEQ by March 1, 2026

c) Uploading OSHA 300A Summary Data for 2025 is due by March 2, 2026

d) Emissions Inventory Report (on significant quantities of VOCs and HAPs emitted into the air) is due to TCEQ by March 31, 2026

(For more information  follow this link)

 

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DEADLINE: Post the OSHA 300A Data on OSHA's ITA Website by March 2

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I hope you have your OSHA 300 Log finalized and your OSHA 300A Annual Summary for 2025 already posted in your facility. Remember, Form 300A must be posted in your facility from February 1 through April 30.

Now, there is another important OSHA deadline on March 2, 2026. Each site that has manufacturing (including printing) that had 20 or more employees at any time during 2025 must electronically submit the OSHA300A summary data from 2025 to OSHA's Injury Tracking Application (ITA).

Manufacturing companies (includes printing and various other industries) with  20 or more employees at any time during 2025, must electronically submit the OSHA 300A summary data through OSHA's Injury Tracking Application (ITA).

If your company is in one of OSHA's very high hazard industries (printing is not on the current list), you may also be required to submit: OSHA Form 300 (Log of recordable cases) and related OSHA 301 forms for each recordable Injury/Illness case.

Basic steps to file your 300A data in the ITA

  1. Prepare your data: (Have your EIN, NAICS code, and completed 300A summary handy)
  2. Navigate to ITA site on a computer: Start at the official ITA portal. (https://www.osha.gov/injuryreporting/ita/)
  3. Log in/Sign Up: Select login, which will direct you to connect via Login.gov.
  4. Enter your Data and Submit: Choose to manually enter (or upload a CSV file) of your 300A records.
  5. Save any confirmation of your filing

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WORKER COMP: What’s the deal with the Experience Mod Factor?

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The average experience mod factor (EMR) for each industry is 1.0. When you apply for State Worker Comp insurance (or non-state options in Texas) the company will assign a mod factor (EMR) based on the quality of your safety program and your last three years history of claims stemming from work-related injuries & illnesses. If the mod factor is above 1.0, your company injury claims are higher than average, so you will pay more for insurance than your competitors. If your mod factor is less than 1.0, your injury claims are more reasonable than most, so you will be charged less for insurance than your competitors are charged. Having a very expensive claim will cause your worker comp insurance premiums to be elevated for three years.

Is your safety program is good enough to bring the company a 10% discount in WC insurance premiums?

Impact Safety helps companies build and maintain OSHA-compliant safety programs that employees are proud to participate in.
www.safeimpact.com

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Finalize your 2025 OSHA 300 log and Post the OSHA 300A by Feb. 1, 2026

 

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Who updates your site's OSHA 300 Log of work-related injuries and illnesses?

If you are not the person, please forward a copy of this reminder to them now.

Most companies have production and/or safety leaders completing incident reports and presenting the information to someone in HR, and HR updates and maintains the OSHA 300 log (since they have secure offices).  All non-governmental companies that have 10 or more employees are required to maintain a OSHA 300 log each year.

January is the time to check the OSHA log (of work-related injuries & illnesses) for the previous year, then finalize and print a summary of the incidents/illnesses for the year on the OSHA 300A (annual summary form). The OSHA 300A form must be signed by the local President or GM, then posted in the workplace for employees to view. The 300A summary must be posted for all of February through all of March, but most companies keep it posted year-round. Note that companies are not allowed to post the OSHA 300 log itself (privacy issue), so only post the annual 300A summary form. (more…)

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What Safety Training Topics and How Frequently?

Many companies look for a checklist or a list of OSHA training topics and exact training frequencies.

Here's the reality:

OSHA does not tell us how often to train on many topics. Instead, they expect training to be effective. The real goal of safety training isn't to avoid citations. It's to ensure that when hazards are present, most people recognize what to do to work safely.

During OSHA inspections, this shows up clearly. Inspectors don't just review training records” they interview employees. If workers can't explain safe procedures in their own words, training frequency and effectiveness quickly come into question.

A practical way to plan safety training is to: (more…)

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Ever feel like your production employees are Risk Cowboys?

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Production employees don't want to get hurt, but they are used to figuring things out on their own.

Sometimes operators have been conditioned to "just get er done" rather than risking another brushoff from an over-stressed supervisor, so they stop asking. They improvise in ways that work around safe practices, and push forward to keep production moving.

This sort of decision will sometimes lead to an injury. These decisions also tend to be repeated by the operator and all the workers involved, making risk of injury increase over time.

But when a supervisor goes out of their way to make it easier for an operator to work safely, something changes. Trust builds. That operator is far more willing to speak up and help identify additional improvements in the future.

Good safety systems don't slow production, they remove the need for shortcuts.

Impact Safety helps companies build and maintain OSHA-compliant safety programs that employees are proud to participate in.

www.safeimpact.com, joe@safeimpact.com

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February 19, 2025

Reporting Deadline: Share Your Company OSHA 300A Data Online by March 1

I hope you have your OSHA 300 log finalized and the OSHA 300A annual summary for 2024 already posted in your plant (February 1 deadline for posting the 300A). Note: Plants that never had 10 or more employees during 2024 are not required to post this.
Normally we want to keep Human Resources (if your site has an HR person) in the driver seat, or at least involved in this process (since they have a place to lock files such as the OSHA log).
Now we have another OSHA deadline on March 1.  All plants with industrial activity, or sites on a list of industries that have moderate to high incident rates (includes printing), must enter the OSHA 300A summary form data into OSHA's online Incident Tracking Application (ITA). This is only for sites that had 20 or more employees at some point during 2024.

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February 19, 2025

President Trump's Impact on OSHA

There are rumors of Trump's administration considering whether to convert all OSHA enforcement to state run plans. States have always had this option, and 22 have managed their own enforcement for many years. Safety enforcement in Texas is currently under Federal OSHA.  Going to a Texas plan instead should not result in a big change for Texas manufacturers (since all states must enact plans that are at least as protective as Federal OSHA regulations).

I found an article that summarizes some other potential changes in the air...

  • Will the new Heat Protection standard still be issued as planned this year?
  • Will union officials from outside the company be allowed to participate in OSHA audits?
  • Will the program requiring manufacturers to share electronic safety records with OSHA each year remain as is?
  • Will the new OSHA Chief lean more into compliance assistance and VPP programs (like happened in the last Trump Presidency)?
  • Will the 10 to 1 rule lead to dropping or easing a many regulations that seem over-burdensome to industry to bring in a new regulation or two?
  • Will Trump's Sidekick (Rocketman) and the DOGE crew bring their wood chipper to OSHA?

Of course, all bets are off on predictions these days, but we should keep our eyes open to changes that can affect our businesses and lives.

What’s Next for OSHA Under President Trump?

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January 7, 2025

Finalize your OSHA 300 log and Post the OSHA 300A -January 2025

Who updates your site's OSHA 300 Log of work-related injuries and illnesses?

If you are not the person, please forward a copy of this reminder to them now.

Most companies have production and/or safety leaders completing incident reports and presenting the information to someone in HR, and HR updates and maintains the OSHA 300 log (since they have secure offices).  All non-governmental companies that have 10 or more employees are required to maintain a OSHA 300 log each year.

January is the time to check the OSHA log (of work-related injuries & illnesses) for the previous year, then finalize and print a summary of the incidents/illnesses for the year on the OSHA 300A (annual summary form). The OSHA 300A form must be signed by the local President or GM, then posted in the workplace for employees to view. The 300A summary must be posted for all of February through all of March, but most companies keep it posted year-round. Note that companies are not allowed to post the OSHA 300 log itself (privacy issue), so only post the annual 300A summary form.

(more…)

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