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Copyright 2025 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
FEATURED NEWS
2025-11-26T06:00:00Z
NewsIndustry NewsSafety & HealthConstruction SafetyGeneral Industry Safety300-A Annual SummaryIn-Depth ArticleInjury and Illness RecordkeepingEnglishFocus AreaUSA
Review the 300 Log before preparing the Annual Summary
Before you prepare the 300A Annual Summary, OSHA requires you to review the 300 Log and verify that the entries are complete and accurate. This does not require examining every entry, but you should spot check a sampling of cases. Below are some common errors on the 300 Log.
Column (E) requires listing a location. Just writing “warehouse” or “office” may not provide enough detail. Ideally, someone else should be able to locate the area where the incident occurred. OSHA gives examples like “loading dock north end.” The location doesn’t appear on the Annual Summary, but it’s good to review in case OSHA inspects your records.
Column (F) requires describing the injury, body part, and cause of the injury. A common error is listing a body part (like “lacerated forehead”) but missing the description of how it happened. Also, for body parts such as arms or legs, the entry should specify left or right. OSHA gives an example, “Second degree burns on right forearm from acetylene torch” to describe an injury, body part, and cause.
Day count extends to next year
If an injured employee is still on work restrictions (or days away) into the next calendar year, do not add the case to next year’s Log. That would indicate a new injury. It may seem odd if, for example, an employee injured on December 13th had 73 days away listed under that date. However, the day count simply indicates the severity of the incident. For that purpose, it doesn’t matter if the days occurred in the next calendar year.
Also, if an injured worker is still away from work (or on restrictions) when you prepare the Annual Summary, you must estimate the day count and use that to complete the summary, per 1904.7(b)(3)(ix). You might use a doctor’s estimate or make a guess based on experience with similar cases. You’ll then post the summary using the estimated days.
Once you know the exact day count, you must update the 300 Log. However, you do not have to update the Annual Summary after it is posted. Consider this: An injury in December could involve a return-to-work date after April 30, at which point the 300A no longer needs to be posted.
Certify and post the 300A
Finally, a company executive must review and sign the completed 300A. In a letter of interpretation from January of 2009, OSHA clarified that employers keeping electronic records can use electronic signatures for this.
You must post a physical copy of the 300A from February 1 through April 30. In a large facility, this may require more than one posting. Some employers post the summary on the company intranet, which is fine, but that’s not a substitute for physical posting. You must also ensure that the summary is not altered, defaced, or covered by other material.
OSHA does not require sending the 300A to people working from home, but check state requirements. For example, California does require providing the summary to remote workers who do not report to the office at least weekly during the posting period.
Key to remember: Review the 300 Log for accuracy and, if needed, estimate day counts before preparing and posting the 300A Annual Summary.
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RECENT INDUSTRY HIGHLIGHTS
2025-11-26T06:00:00Z
NewsIndustry NewsFleet SafetyRisk Management TransportationRisk Management - Motor CarrierBusiness planning - Motor CarrierBusiness policies and procedures - Motor CarrierFocus AreaIn-Depth ArticleFleet OperationsEnglishTransportationBusiness planning - Motor CarrierUSA
Create a culture of safety in trucking, part 1: Moving from reactive to proactive
Safety in trucking isn’t just about meeting regulatory requirements. It’s about creating a proactive culture that prevents accidents and injuries before they occur. Many companies still operate with a reactive mindset, addressing problems only after an incident happens.
This approach is costly and ineffective. Transitioning to a proactive strategy means identifying risks early and implementing solutions that protect drivers and warehouse workers. Consider the following steps to assist in becoming more proactive than reactive.
Step 1: Know the regulations
Compliance is the foundation of safety, and failing to meet these standards can lead to violations, accidents, and injuries.
The first step is understanding all compliance requirements that impact safety, including
- Hours-of-service regulations,
- Load securement standards, and
- Warehouse safety protocols.
A proactive company regularly audits its processes to:
- Ensure compliance, and
- Identify gaps before they become hazards.
2. Leverage video technology
Technology is a powerful tool in accident prevention. Dash cameras provide visibility into driver behavior and road conditions, enabling managers to coach effectively. Coaching should focus on positive reinforcement and actionable feedback rather than punishment. When drivers understand how to improve and feel supported, they are more likely to adopt safer habits. With consistent use of dash cameras and coaching, companies can realistically achieve a 10 percent reduction in total accidents. This represents fewer injuries, less downtime, and lower insurance costs.
Injury prevention is equally critical. CCTV cameras on docks allow managers to review incidents and near misses, such as forklift collisions or improper lifting techniques. This footage helps identify patterns and implement corrective measures. Simple steps like slowing down, asking for help with heavy freight, and using proper lifting techniques can significantly reduce injuries. These behaviors should be reinforced through training and recognition programs.
3. Address physical hazards and communicate with employees
Physical hazards must also be addressed, such as:
- Replacing broken dock plates and malfunctioning dock doors.
- Ensuring pallet jacks are in good working condition.
- Maintaining clean, clutter-free surfaces.
- Outside the warehouse, repairing potholes and improving yard lighting to prevent slips, trips, and falls during nighttime operations.
These improvements show employees that safety is a priority, not an afterthought.
Finally, communicate these changes clearly. Drivers and warehouse workers need to understand why these measures matter and how they protect them. Use newsletters, meetings, and digital platforms to share updates and success stories. When employees see results, they buy into the process.
Proactive safety is not a one-time effort. It requires continuous improvement and engagement. By combining compliance awareness, technology, and hazard elimination, companies can create a safer environment for everyone involved in the supply chain.
Key to remember: A proactive approach saves lives, reduces costs, and builds trust across the organization.
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2025-11-25T06:00:00Z
NewsVehicle breakdown and road repairIndustry NewsFleet SafetyCMV Parts and MaintenanceParts and Accessories - Motor CarrierFocus AreaIn-Depth ArticleFleet OperationsEnglishVehicle maintenanceTransportationUSA
Smart maintenance strategies for small fleets: Minimize downtime, maximize profit
For many small fleets, maintenance and repairs can be an ongoing battle. In-house shops are often not cost effective, and freight lanes sometimes require drivers to have trucks serviced at locations far from terminals. Inevitable breakdowns result in unscheduled downtime, resulting in late deliveries or missed loads. Proactive planning can help minimize downtime.
The first line of defense
Every manufacturer has a scheduled maintenance recommendation. Carriers may have policies and procedures that require maintenance to be done at shorter intervals. To be proactive about breakdowns on the road, getting an overall inspection with each oil change will help identify potential problems before they happen. Scheduled downtime is always less costly than unexpected delays.
When trucks don't often visit terminals, identifying quality shops can be difficult. Start by identifying your most common routes and looking for shops along the way. Truck stops are often the most convenient place to have maintenance performed but often limit their services to only the oil change without any additional inspection. There is usually a cost for convenience, and this can sometimes be a more expensive way to go. Looking for a trusted chain, or having independent shops on your list, can help in coordinating maintenance between a delivery and the next pickup.
Major repairs
When your chain of vendors chosen to do your preventive maintenance identifies potential problems, they may not be equipped to do the repairs themselves. Choosing to have major repairs done far from home can be questionable at best. Deciding where to have your work done when it is discovered makes a huge difference in the time required, expense of the repairs, and quality of work. Waiting to get to a known vendor to have the repair made can result in a costly roadside breakdown. Dealers usually provide quality work but often take longer to do the repairs due to the volume of business they do. Local repair shops may have limited inventory, having parts overnighted at your expense will just add to the cost of repairs and may add additional delays. Most shops will provide a warranty for their work, but that is little help if the repair fails and your driver is now 1000 miles away.
Your network of maintenance providers may be able to help you find reputable repair shops near them. They value your business and would not intentionally send you to a shop that could not meet your needs. They could be your best partner for major repairs.
When the unexpected happens
Breakdowns are inevitable. No matter how well you plan, or how proactive your maintenance, unforeseen failures will happen eventually. The time to look for a mobile mechanic is before you need one, not when you need one. The internet has made finding a quality roadside tech easier. Ratings and reviews can tell you a lot about past customer experiences. There are maintenance subscriptions for commercial vehicles that can help locate the nearest mechanic, and they take some of the guesswork out of the process.
Key to remember: A proactive approach to vehicle maintenance helps eliminate downtime, schedule service between loads, and keep your trucks moving.
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2025-11-25T06:00:00Z
NewsIndustry NewsIndustry NewsFleet SafetyDefensive drivingCMV drivingFocus AreaEnglishTransportationUSA
Winter survival guide to the rescue
Cold temperatures are quickly approaching (or have already arrived) in many states, so it’s important for drivers to be prepared for whatever winter hazards they may face.
Remind drivers of the following three actions to remain safe during the harsh season.
1. Pack a winter survival kit
All drivers should have a winter survival kit in their vehicle. In addition to the items that should be in their vehicle at all times (warning devices, a jump box, tool kit, first-aid kit), they should also carry the following items:
- Snow brush and scraper,
- Shovel,
- Traction devices,
- Brightly colored cloth,
- Blankets/sleeping bag,
- Extra food and water,
- Extra medications (if necessary), and
- Proper outerwear (extra coat, gloves, hat, boots).
2. Stay calm when stranded
Once they’re prepared, make sure drivers know how to handle being stranded in cold weather without panicking. At minimum, a stranded driver must remember to:
- Stay in the vehicle.
- Dial 911 to summon help.
- Run the vehicle’s engine, with the heater on, for about 10 minutes every hour to keep warm, opening a window slightly during that time to prevent carbon monoxide poisoning. Also, to prevent carbon monoxide poisoning, make sure the vehicle’s exhaust pipe is clear and free of snow.
3. Watch for hazards working around the vehicle and loading docks
Accidents can happen just as easily outside the vehicle as they can on the road during snow and cold, so drivers should always take precautions. A slip, trip, or fall is less likely to occur if drivers:
- Employ the 3-point rule when mounting or dismounting from the truck, trailer, equipment, loading docks, and ladders.
- Always use the handrail when available.
- Walk like a penguin for balance (arms outstretched, feet pointed to the sides, small strides).
- Avoid blocking their vision when carrying objects.
- Watch for that last step or change in surface height.
- Inspect equipment (ladders, railings, steps) for damage before using.
- Check whether steps are slippery before using.
- Walk around, rather than over, obstructions.
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2025-11-25T06:00:00Z
NewsIndustry NewsIndustry NewsAssociate Benefits & CompensationAssociate RelationsHR GeneralistFamily and Medical Leave Act (FMLA)Family and Medical Leave Act (FMLA)HR ManagementEnglishFocus AreaHuman ResourcesUSA
‘I need leave to care for my pregnant wife’ was enough FMLA notice
Teryl was a freight handler loading and unloading trailers from 5:30 p.m. to 2:30 a.m. Before clocking out at the end of the shift, freight handlers had to check with the dock supervisor to make sure no other trailers required loading or unloading. If there were still trailers that needed to be unloaded at the end of the shift, freight handlers were expected to work overtime.
In March, Teryl announced that his wife was pregnant. Shortly afterward, he asked Rickey, a manager, about taking time off under the Family and Medical Leave Act (FMLA) in case he needed it for his wife’s pregnancy. Rickey told James he was “moving too fast” and that he didn’t need to ask about leave until after the child was born.
In June, the pregnancy was deemed “high risk,” and she could no longer drive, so Teryl needed to care for her as much as possible. Teryl told his supervisors that there would be times he had to leave early or miss days to care for his wife. No one told Teryl of his FMLA rights.
On June 25, Teryl told a supervisor that he had to leave at the end of his shift to ensure his wife was okay and drive her to an appointment. After finishing his shift, he was leaving work for the day when a supervisor stopped him and told him he had to work overtime. Teryl refused to stay. Management recorded the incident as his refusal to work overtime when needed.
On July 1, throughout his shift, his wife was giving him updates on the pain she was experiencing and her fear that something was wrong with her pregnancy. At the end of his shift, Teryl clocked out and began to leave the worksite. A manager stopped him, telling him that if he left, it would be considered job abandonment. Teryl left. The next day, Rickey requested Teryl’s termination.
On July 2, Teryl took his wife to the hospital. The pregnancy was in such a dangerous state that the baby had to be delivered immediately — two and a half months early. After the baby was born, Teryl applied for and received paid parental leave from July 6-17.
On July 20, Teryl submitted FMLA paperwork for additional leave, which the employer later approved. A couple of days later, the employer terminated Teryl.
Teryl sued, claiming that the employer interfered with his FMLA rights. The employer asked that the case be thrown out; that Teryl didn’t give notice of the need for leave. The court disagreed with the employer.
The court held that a jury could find that Teryl was fired from his job as a direct result of leaving after completing his shift to care for his wife, and he had given enough notice.
James v. FedEx Freight, Inc., 11th Circuit Court of Appeals, No. 24-12907, November 7, 2025
Key to remember: Once an employee puts their employer on notice of the need for leave, which supervisors must recognize, employers have 5 business days to give employees an eligibility notice.
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2025-11-25T06:00:00Z
NewsCERCLA, SARA, EPCRASafety Data Sheet ReportingIn-Depth ArticleHazard CommunicationEnglishTier II Inventory ReportingSafety Data SheetsIndustry NewsSafety & HealthConstruction SafetyGeneral Industry SafetyAgriculture SafetyMaritime SafetyEnvironmentalHazard CommunicationSARA ComplianceFocus AreaUSA
EPA’s SDS/Tier II reporting now in lockstep with OSHA HazCom
EPA issued a direct final rule to update its safety data sheet (SDS) reporting and Tier II inventory reporting requirements. The changes align EPA 40 CFR 370 with OSHA’s Hazard Communication (HazCom) standard at 29 CFR 1910.1200.
The biggest change is that facilities will be able to copy the hazard categories directly from section 2 of the SDSs to their Tier II report forms. This eliminates the guesswork. However, facilities may face added strain with their first Tier II submission under the rule. Instead of relying on the grouped hazard categories selected in the previous year’s forms, it looks like facilities will need to spend extra time retrieving specific categories from their SDSs.
Who’s impacted by the rule?
EPA 40 CFR 370 applies to a facility owner or operator if:
- The OSHA HazCom standard requires the facility to prepare or have available an SDS or material safety data sheet (MSDS) for a hazardous chemical;
- The hazardous chemical is not exempted at 370.13 or 1910.1200(b)(6); and
- The hazardous chemical is present at or above certain threshold levels.
If the applicability criteria are met, the facility owner/operator must submit to the state emergency response commission (SERC), local emergency planning committee (LEPC), and local fire departments:
- An SDS or MSDS for each covered hazardous chemical or a list of all covered hazardous chemicals; and
- A Tier II hazardous chemical inventory form by March 1 annually for all covered hazardous chemicals.
A state may make its own laws and regulations in addition to or more stringent than federal Part 370.
What’s changing in Part 370?
Last year, OSHA amended its HazCom standard to conform to the seventh edition of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Changes to the chemical hazard classifications and categories were part of the amendments to 1910.1200. This is important because EPA Part 370 relies on the OSHA HazCom standard for the definition of “hazardous chemical” and the hazard categories that must be reported.
In the latest rule published November 17, 2025, EPA takes several actions to harmonize its regulations with OSHA’s. The preamble offers a complete list of amendments to Part 370. Here’s a summary:
| Change: | Details: | Sections affected: |
| Adopts all 112 OSHA hazard categories |
| 370.3, 370.30, 370.41, and 370.42 |
| Updates terminology |
| 370.3 and 370.66 |
| Removes the term MSDS |
| 370.3, 370.10, 370.12, 370.13, 370.14, 370.20, 370.30, 370.31, 370.32, 370.33, 370.60, 370.62, 370.63, and 370.64 |
| Makes minor plain language, clarifying, and consistency corrections |
| 370.1, 370.2, 370.3, 370.10, 370.14, 370.30, 370.32, 370.33, 370.40, 370.41, 370.42, 370.43, 370.44, 370.45, 370.60, 370.61, 370.62, 370.64, 370.65, and 370.66 |
When will the changes take effect?
The direct final rule is effective January 16, 2026, unless EPA receives an adverse comment during its 30-day comment period. If that happens, the agency will publish a timely withdrawal. Then, it will move along with the proposed rule (also published in the November 17, 2025, Federal Register) and address public comments in a subsequent final rule.
Assuming no adverse comment is received on the original direct final rule, EPA gives covered facilities time to prepare. The rule offers a compliance date of December 1, 2026, for both SDS reporting and Tier II reporting. Note that for Tier II reporting, the updates kick in for the 2026 inventory reporting year, which impacts forms due by March 1, 2027, and thereafter. (Forms due on or before March 1, 2026, are unchanged.)
Key to remember
EPA took action to harmonize Part 370 with the changes OSHA made to 1910.1200 last year. The latest amendments to Part 370 have a compliance date of December 1, 2026. For Tier II reporting, the updates start with forms due on or before March 1, 2027.
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Copyright 2025 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.