New OSHA requirement for New Mexico Manufacturers

As New Mexico MEP’s Jeff Abrams travels about New Mexico meeting with clients to plan the year’s goals and objectives, he is learning that New Mexico manufacturers are not aware of a new requirement initiated by OSHA: All manufacturers employing more than 20 employees must electronically submit the OSHA form 300A Summary of Work Related Injuries and Illnesses. In the past a company’s top executive was required to review the forms 300 and 301 and summarize them on 300A, certify them and post them at the organization for employees to be able to review. The new requirement adds to the original requirement that the 300A data be entered in an online OSHA database in addition to being posted internally.

Some articles on this matter state 10 employees or more as the requirement, but the actual code of federal regulation states 20. If you are one of the few companies in New Mexico that have greater than 250 employees, please note that the requirements to post the form 300, 301 and 300A have changed — only the 300A must be posted. They apparently do not want to force companies to violate HIPPA requirements.

OSHA’s belief is that if a company has to report its performance to OSHA, it will make efforts to improve that performance. Though no one may be available to review each submission, the database provides company ranking parameters that could be used to complete an on-site inspection. With the current staffing levels of OSHA inspectors, a company’s performance would have to be fairly poor to be subject to regulation.
The deadline to post internally was February 2, and the deadline to electronically enter the data is March 2.

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