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March-April 2024

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Pallet C e nt ral • Ma rch -Ap r il 2 0 24 33 to a hazard (where multiple people have exposure to one source, such as an unguarded conveyor) or the agency can issue multiple citations where the same defect exists on multiple units—such as bandsaws—within the same facility. Normally, such citations are "grouped" in a single item with one penalty, so this enhancement allows employers to quickly hit substantial penalties arising from a single violation if they meet the IBI criteria (bad history of violations including repeat or willful citations within previous five years, or fatalities and catastrophic injuries). Recordkeeping violations can even be included if omissions are connected with the injury events at issue. For those companies that may deliver pallets or materials to mine sites under the jurisdiction of OSHA's sister agency, the Mine Safety & Health Administration, their penalties are now at nearly $324,000 against companies (including visiting caveats. e injury data is lagging, which means that for specific sectors, the most recent data available is generally from 2021 to 2022. By contrast, OSHA is able to give more current annual data on its enforcement activities, for the fiscal year that ends September 30th of each year. Manufacturing is considered one of the most hazardous industry sectors, which is why employers in any NAICS code starting with 32 or 33 have to report injuries and illnesses electronically to OSHA by March 2nd of the following year, and those data are publicly searchable by employer on OSHA's website. Only employers with 20 or more employees at their worksite (not company-wide) need report, and for those with 20–99 employees, only the OSHA Form 300A needs be filed. Under the new electronic recordkeeping rule that took effect contractors and vendors), and individual agents of management can be personally fined up to $88,000 if they know of a violation and fail to implement corrective action. One of MSHA's hot button issues right now is falls from trucks, including flat-bed trailers, while unloading materials and equipment. And a new MSHA rule takes effect July 17, 2024, that requires those operating mobile equipment on mine sites to have more comprehensive written programs and training. All of these penalty hikes can put the hurt on employers . . . even as failing to maintain a safe, healthful, and compliant worksite can put the hurt on workers, or even cost them their lives. How do the most-cited standards in the pallet and container sector (NAICS 321920) compare with the types of injuries that workers in this sector incur? It's worth taking a look. First, a few

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