In December of 2019, OSHA issued an updated National Emphasis Program (NEP) focused on amputation hazards in manufacturing industries. The intent of this NEP is to reduce or eliminate amputations across the manufacturing sector through increased enforcement of OSHA standards. This increases the likelihood of an OSHA Inspector arriving at your facility – which means your organization must be prepared to manage this event.
In this directive, OSHA offers an extensive list of industries that will be targeted under this NEP. Among this list are food manufacturing, concrete products manufacturing, metal fabricators, and many more.
Our goal in this article is to provide an overview of the NEP and highlight ways your organization can prepare for an inspection.
What is a National Emphasis Program?
According to OSHA, National Emphasis Programs are “temporary programs that focus OSHA’s resources on particular hazards and high-hazard industries.” OSHA issues various NEPs focusing on different industry sectors or hazards throughout the year. For a list of current NEPs, visit this webpage on OSHA.gov.
What Does the New NEP on Amputations Mean?
This new NEP is intended to reduce or eliminate amputation hazards in manufacturing industries as the number of amputations remains high – according to BLS data, there were 6,200 amputations in manufacturing in 2018. One of the largest sources of amputations across manufacturing is machines – meaning OSHA Inspectors will be checking thoroughly for proper machine guarding and maintenance when conducting inspections.
Here’s what the NEP directive says: “If any machinery or equipment associated with amputations is present in the workplace, the [Inspector] should exercise professional judgment in conducting an inspection, paying particular attention to employee exposure to nip points, pinch points, shear points, cutting actions, and other points of operation. The [Inspector] should consider and evaluate employee exposures during setup, regular operation of the machine, clearing jams or upset conditions, making adjustments while the machine is operating, cleaning of the machine, oiling or greasing of the machine or machine pans, scheduled/unscheduled maintenance, and locking out and/or tagging out.”
Here’s the bottom line – OSHA Inspectors
will be looking for any hazard that could cause an amputation.
And your organization must be prepared for an OSHA Inspector to arrive any day.
We’ve already heard from several organizations across the manufacturing sector
who have been inspected under this NEP. The time to prepare is now.
How Do I Prepare for an Inspection?
To prepare your organization for an inspection under this NEP, here are a couple things to focus on:
Ensure OSHA Inspection Procedures are Up to Date and Available to Employees
If your organization currently has an inspection procedure, ensure it is up to date and available to key staff members. However, if your organization does not have a clear inspection procedure, the time to get one is now. Every organization in the United States is susceptible to an OSHA Inspection and should be prepared to navigate this event.
Our team at Optimum helps organizations across the country – and in various industries – create procedures for OSHA inspections that are unique to each organization. Feel free to give us a call anytime at 630.759.9908 and we can help direct your organization to next steps.
Conduct a Mock OSHA Inspection
Take a critical perspective and inspect your facility as an OSHA Inspector would. Walk through the facility and list any areas of exposure or concern. Anything an Inspector sees while visiting the facility is open to citation, so be extra critical in observing areas of exposure.
It’s important to note since you are in this facility every day, it may be difficult to see exposures in plain sight. When we’re in an environment so often, we can become blind to the exposures around us, so don’t be afraid to seek 3rd party assistance. Our team at Optimum helps organizations every day find exposures that would’ve otherwise been overlooked. It can be incredibly beneficial to have a fresh set of eyes on the facility.
Address Any Potential Sources of Amputations
After the mock inspection, work diligently to address the exposures. Remember to keep a sense of urgency since an inspector can arrive at any time – and at the end of the day, these exposures could produce a life-altering injury for an employee. This certainly isn’t something to take lightly.
Become Educated on Best Practices
No matter your position in the organization, it will be helpful to learn about the inspection process and how you can create a better outcome. Our team recently published a whitepaper highlighting our best practices for navigating an OSHA Inspection like a professional. This shares our experience managing countless inspections in a way that’s applicable to your organization. You can access this resource here.
There are many more resources available on the internet regarding OSHA Inspections. However, it is important to find resources from experienced professionals – not simply those interpreting the law. Experience goes a long way in this situation.
Our team recently put together a guide titled What to Do When OSHA Shows Up. This resource is filled with practical tips to help you successfully manage an OSHA inspection.
As we’ve mentioned, the time to prepare for an OSHA Inspection is now. Wherever you are in the safety journey, there are always ways to improve and become better – both as an organization and as individuals. Should you have questions, feel free to reach out to our team at Optimum. We’re here to help you.