Understand – and Act On – These Requirements
Before Jan. 1
As your resource, IWLA offer members this quick guide to the most pressing issues and deadlines facing warehouse logistics companies by the end of 2014.
Pharmaceuticals: Track & Trace
President Obama signed into law the Drug Supply Chain Security Act Nov. 27, 2013:
- The Act requires the U.S. Food and Drug Administration to promulgate uniform national licensing standards for 3PLs by November 2015.
- Beginning Jan. 1, 2015, manufacturers, wholesalers, and repackagers are required to provide the subsequent purchaser with product-tracing information for prescription drugs. (This regulation begins July 1, 2015 for dispensers.) 3PLs are not required to provide product-tracing information.
- Beginning Jan 1. 2015, a 3PL may only do business with an “authorized trading partner” – an FDA-licensed manufacturer or repackager, and a state licensed dispenser.
Health Care: The Law for Large Employers
By Jan. 1, 2015, the U.S. Affordable Health Care Act applies to all employers with 100+ full-time employees or a combination of full-time and part-time employees that is equivalent to 100 or more employees. If an employer falls within one of these two groups, it is subject to the Employer Shared Responsibility Provisions.
Employer Shared Responsibility Provision Basics:
- To determine the number of employees, a company must look back to the number of employees in 2014.
- Employers must offer affordable health insurance that meets the minimum value of coverage to full-time employees and dependents.
- Employers that do not offer affordable, minimum-value coverage are subject to the Employer Shared Responsibility payment if at least one of its full-time employees receives a premium tax credit for purchasing individual coverage.
- The IRS will contact employers to inform them of their potential liability for an Employer Shared Responsibility payment based on the individual’s tax return.
- Employers must offer coverage to full-time employees by Jan. 1, 2015. If an employee is not covered during any of the calendar month, the employer is treated as not offering coverage during the entire month.
Beginning in January 2016, employers must file information returns with the IRS and provide statements to full-time employees about the health coverage that is offered. The tax provisions include:
- Employers must file form 1095-C and transmittal form 1094-C for each employee before Feb. 28 of each year. Reporting for the 2015 calendar year is due in 2016.
- Employers must furnish statements to employees with name, address, and EIN for the employer no later than Feb. 1, 2016.
As a best practice, warehouses that use temporary labor through agencies should confirm the individuals’ coverage through documentation. Common law can transfer responsibility to a warehouse logistics organization if coverage requirements are not being met by the agency.
New Injury Reporting Requirements
On Sept. 11, 2014, the U.S. Department of Labor Occupational Safety & Health Administration (OSHA) changed the industry exemption requirements for injury and illness records and expanded the work-related injuries and illnesses that are required to be reported.
As of Jan. 1, 2015, all employers must report:
1. All work-related fatalities within eight hours of finding out about them.
2. All work-related inpatient hospitalizations, all amputations and all losses of an eye within 24 hours of learning about it.
Employers can report to OSHA in the following ways:
1. Calling OSHA’s free and confidential number at 800.321.OSHA (6742).
2. Calling your closest area office during normal business hours.
3. Using the new online form that will soon be available.
Only fatalities occurring within 30 days of the work-related incident must be reported to OSHA. Further, inpatient hospitalization, amputation, and/or loss of an eye incidents must be reported to OSHA only if they occur within 24 hours of the work-related incident.
Special thanks to IWLA Washington Representative Pat O’Connor for his contributions to this list.