National Enforcement Program to Address Amputations in Manufacturing

After recordkeeping rules were updated at the end of last year to include hospitalizations, loss of an eye, and amputations, it became clear that OSHA was putting additional focus preventing and highlighting major injuries in the workplace. To further address the risk and frequency of amputatins—especially in the manufacturing industry—OSHA updated its National Emphasis Program on Amputations earlier this year.

With amputations in manufacturing occurring at a rate more than twice that of the private sector as a whole (1.7 incidence rate vs. 0.7), the new directive focuses on 80 activities with heightened risk of amputation.

Industry Focus: What High-Risk Industries Are Targeted?

The following 80 industries were highlighted as part of the NEP, derived through a progression of evaluating data from primarily four factors in three categories:

Category 1 (High IMIS and OIS Numbers):

OSHA selected five standards (29 CFR 1910.147, .212, .213, .217, and .219) that are generally recognized as related to amputation hazards, followed by identifying those industries with 40 or more OSHA inspections with one or more violations.

Category 2 (High Amputation rates from the Bureau of Labor and Statistics (BLS))

OSHA used the most recent five years of BLS Data (Calendar year 2009, 2010, 2011, 2012 and 2013) on incidence rates for nonfatal occupational injuries and illnesses involving days away from work per 10,000 full-time workers, selecting NAICS with incidence rates of 10.0 or greater for any given year.

Category 3 (High Amputation numbers from BLS)

OSHA used the most recent five years of BLS Data (Calendar year 2009, 2010, 2011, 2012 and 2013) on the number of amputations. OSHA selected NAICS with BLS numbers of 50 or more amputations per year.

The 80 Industries Highlighted in Amputation NEP

The 80 6-Digit NAICS codes that comprise the scope of this NEP have either High IMIS/OIS Numbers coupled with High BLS Amputation Rates or High IMIS/OIS Numbers coupled with High BLS Amputation Numbers.

• There are 14 6-digit NAICS codes with high inspection counts and high BLS rates (categories 1 and 2 above).
• There are 76 6-digit NAICS codes with high inspection counts and high BLS case counts (categories 1 and 3 above).

After eliminating the overlap between the two groups, the final total is the following 80 6- Digit NAICS codes.

How NEP Selection Works

For employers in these industries, inspections are scheduled and conducted according to the following priorities. Excluded from this list are Employers with less than 10 employees (CPL 02-00-051).

Selections are made by cycle, and a “Cycle” can be defined as a subset of establishments from the master list. Creating cycles from a randomized list allows the Area Office to use its enforcement resources more efficiently. Inspecting firms within a cycle in the order that makes the most efficient use of OSHA’s resources does not diminish the plan’s neutrality.

An Area Office (AO), can schedule inspections in the following manner:

• If the AO intend to inspect the entire master list, it can schedule the inspections in any order. If the AO uses this method, it must account (through inspections and deletions) for the entire list. The AO cannot inspect off a new list until the entire previous list is completed.
• The AO can inspect the facilities in the random number order provided. If the AO uses this method, it does not need to complete the entire list.
• The Area Office can create cycles by choosing a set number of establishments from the establishment list sorted in random number order. For example the AO can select the first ten establishments on the list sorted by ascending random number as a first cycle of 10 establishments. The AO can then inspect those establishments in any order, but must finish the cycle prior to beginning a second cycle. Once the first cycle is complete, the office can select the next ten establishments from the randomized list as its second cycle

This results in a randomized inspection process that is unbiased. This also means that if you are in the industries above, you can expect your name to be drawn.

We look forward to sharing with you part 2 of this guide, “what to expect during an Amputation NEP Inspection,” to be published tomorrow.

Need immediate help? Call the Optimum Safety Management Safety Helpline at 1-888-70-SAFE-T (707-2338).