OSHA launched a new version of the National Emphasis Program (NEP) on amputations, targeting industries with a history of amputation reports to OSHA, violations related to guarding, and/or high reported rates in the Bureau of Labor Statistics (BLS) survey. The amputations NEP has been one of OSHA's most active programs. Violations for machine guarding and lockout/tagout tend to generate high fines because they are almost always cited as Serious with a high gravity exposure (severity x probability).
What makes the new NEP different? The new NEP uses employers' reports to OSHA of amputations, along with the traditional BLS data. This means that a new list of industries will be covered. The program, which will run for five years, targets 75 types of manufacturing (from 10 broad manufacturing industry sectors). These are manufacturers of:
- Fabricated metal products (NAICS 332) - 20 industries
- Food (NAICS 311) - 13 industries
- Machinery (NAICS 333) - 11 industries
- Wood products (NAICS 321) - 10 industries
- Furniture (NAICS 337) - 5 industries
- Plastics and rubber (NAICS 326) - 4 industries
- Transportation equipment (NAICS 336) - 4 industries
- Paper (NAICS 322) - 3 industries
- Primary metal (NAICS 331) - 3 industries
- Concrete (NAICS 327) - 2 industries
The inspection process. Once a site is selected, the OSHA inspector will verify with the employer whether any machinery or equipment that could cause amputations is present. In addition, OSHA 300 logs and 301 incident reports will be reviewed during the opening conference to identify amputations associated with machinery and/or equipment.
The inspector will then conduct a walkaround, looking at employee exposure to nip points, pinch points, shear points, cutting actions, and other points of operation. The inspector will likely look at exposures during:
- 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.
Employers in any of the 75 industries should review their current guarding practices, as well as their lockout/tagout compliance program and procedures.