14 MiMfg Magazine February 2017
early March during which we ’ ll develop a strategy for moving forward . At this meeting , you ’ ll be able to meet with other unemployment and government affairs professionals , help develop recommendations for meaningful improvements to Michigan ’ s unemployment system and gain important information to help your company navigate through these potentially costly issues .
New Safety Rule Resources
Check out these resources and contact MMA ’ s Delaney McKinley , at 517-487- 8530 or mckinley @ mimfg . org , for more information :
• OSHA Interpretation of Requirement ( 10 / 19 / 16 )
• OSHA Guidance on Tracking Workplace Injuries and Illnesses ( 12 / 15 / 16 )
Are You Violating the New Safety Rules ?
All MMA members should be aware of the new Michigan Occupational Safety and Health Administration ( MIOSHA ) Recording and Reporting of Occupational Injuries and Illnesses rule , effective 1 / 1 / 17 . The federal interpretation of this rule could hold tremendous implications for you and fellow employers .
The new rule requires employers to inform workers of the right to report work-related injuries and illnesses and establish a “ reasonable procedure ” for reporting those injuries and illnesses . Per federal Occupational Safety and Health Administration ( OSHA ) guidance documents ( see New Safety Rule Resources above ), an employer ’ s internal policies must be designed so as not to discourage employees from reporting injuries and illnesses .
OSHA identified three areas which would discourage employees from reporting , thus violating the requirement for a reasonable procedure :
• Discipline : While employers may discipline employees for violating safety rules , they cannot discipline employees for reporting a work-related injury or illness . A violation will be determined by looking at how the discipline policy is applied to all employees as compared to those that report a work-related injury or illness .
• Incentives : The interpretation indicates that , while employers may have safety incentive programs , they may not take adverse action against employees because they report work-related injuries or illnesses . Per MIOSHA , this difference can be satisfied by basing incentives on “ leading data ,” such as number of safety meetings held or compliance with safety rules , rather than “ trailing data ,” such as number of reports or injury incidents .
Is your company at risk for Employer Non-Compliance Determinations ?
• Drug and Alcohol Testing : The interpretation states that employers must have an “ objectively reasonable basis ” for drug testing employees who report work-related injuries or illnesses . A violation will be determined by looking at whether the employer had a “ reasonable basis for believing that drug use by the reporting employee could have contributed to the injury or illness .” 6
Delaney McKinley is the director of human resource policy and membership development for MMA . She may be reached at 517-487-8530 or mckinley @ mimfg . org .
Your Feedback Needed : Michigan New Jobs Training Program
The hiring , training and retention of talent is one of manufacturing ’ s top challenges in 2017 . The state ’ s Michigan New Jobs Training Program ( MNJTP ) was developed as a tool to support employers in that endeavor but unfortunately , some manufacturers have experienced substantial challenges and inefficiencies with the program . The intent of the MNJTP is good , but changes are needed to ensure job creators receive the most value for the time and resources they put in .
Take Survey
MMA is working to address the challenges with the MNJTP and is seeking the input of manufacturers that have participated in the program to guide legislative change .
If you are a previous or current participant of the program , your company is uniquely qualified to offer insights into what works and what doesn ’ t work . Please complete this brief survey by February 28 . Your responses will be kept confidential and will only be used to direct MMA ’ s Government Affairs team in efforts to improve the MNJTP .