2022 RETA Breeze March-April

By James Marrella Q A

ANSWER: What a great question and with an equally great answer! Yes they did. On January 13, 2022, the United States Occupational Safety and Health Administration (OSHA) announced that they increased their maximum monetary penalties by nearly 5%. (Ctrl+Click to follow link 2022 Annual Adjustments to OSHA Civil Penalties Occupational Safety and Health Administration) And the last time OSHA increased their penalties before that was on January 8, 2021. Yes just over a year ago. So don’t be surprise that they do it at least 2 more times (2023 and 2024) and beyond. Due to the Federal Civil Penalties Inflation Adjustment Act. (Federal Register / Vol. 86, No. 10 / Friday, January 15, 2021 / Rules and Regulations). The Inflation Adjustment Act required agencies to: (1) adjust the level of civil monetary penalties with an initial “catch-up” adjustment through an interim final rule and (2) make subsequent annual adjustments for inflation, no later than January 15 of each year. Before we get started, we need to establish some “Ground Rules” or “Mind Set”. It is very important to understand when we are addressing a given requirement set by a federal/state/local regulation is to be prepared to defend our action or better yet defend our thought (Thinking) process. We need to show that our approach is in line with the “agency in question”methodology and that it FITS our circumstance, and apply some common sense. Try not to over think the issues at hand. We need to ask a few simple questions as we maneuver through our decision process. The questions. “Does this make sense?” and “Is this new procedure overburdening your staff?”Or the most important question “Can you modify an existing procedure to fit your needs today?” With that said, I would like to add 2, simple laws of operating. Consider them “food for thought”. Marrella’s 1st and 2nd laws that influence our little “World of Industrial Refrigeration” they are as follows:

QUESTION:

DID OSHA RECENTLY INCREASE THEIR PENALTIES?

Marrella’s 1st Law: Anything complex can be broken down into simple elements.

PART 1

Marrella’s 2nd Law: Nothing is as simple as it seems.

Now, after saying all that, where do we start?

Well, I believe it is very important that we have an understanding of regulations or at the very least, know where you can get help if the need ever occurs. I would also be the first to tell you that this subject is very dry and may overwhelmed you at first. But it is still needed just the same. On this subject we will give you a general view, just enough to make you dangerous, and I strongly recommend that you review our IR4, Chapter 2 Occupational Safety and Health Administration and Environmental Protection Agency for Part 2. Question to all RETA Chapters: Do you make the Q and A part of your chapter meeting or general discussion? If you have a question or comment for Jim visit our website or he can be reached at 5720 South Austin Avenue, Chicago, Illinois, 60638.

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