On December 10, 2019 the Occupational Health and Safety Administration (OSHA) issued CPL 03-00-022 – The National Emphasis Program (NEP) on Amputations in Manufacturing Industries. This is an updated NEP and supersedes the previously issued NEP (CPL 03-00-019). The intent of the NEP is to identify and reduce or eliminate workplace hazards associated with amputations in manufacturing industries. One of the major changes to the NEP was the employer targeting methodology. The new employer targeting methodology resulted in the generation of a list of 75 6-digit NAICS codes which can be found Appendix B of the NEP. Each OSHA Area Office will generate a list of the employers in their area that fall under these NAICS codes. Each area office may choose to inspect their full list of employers or a subset of them. Additionally, employers outside of these NAICS codes can be added at the discretion of each Area Office due to historic knowledge of injury and illness data in their area. A link to the full NEP and Appendix B with the targeted NAICS codes can be found by visiting https://www.osha.gov.
What does this mean?
Between Dec 10, 2019 and March 10, 2020 each Area Office will conduct outreach to educate and assist with ways to prevent these types of injuries from occurring. After this 90-day period OSHA will begin conducting planned inspections of employers that fall under the NAICS codes listed in Appendix B.
I don’t fall under the NAICS codes in Appendix B, could I still be inspected?
Yes, each Area Office can add employers at their discretion based on historic injury knowledge or knowledge of equipment at an employer that poses an amputation hazard. Additionally, employee complaints and referrals addressing operations that allege potential exposures to amputation hazards will be inspected under this NEP.
What will happen during an inspection?
OSHA will conduct an opening conference where they verify with the employer whether any machinery and/or equipment that could cause amputations is present in the workplace. They will also review the past 3 years OSHA 300 and 301 logs during this time. Afterwards OSHA will conduct a walkaround inspection focusing on nip points, pinch points, shear points, cutting actions, and other points of operation. However, while the inspection is initiated under the NEP and focuses on the previously mentioned hazards the OSHA Compliance office can expand that scope to other recognized hazards if they choose.
How can CAPACCIO help?
CAPACCIO’s Health and Safety Consultants can assess your processes and machinery to suggest controls to minimize hazards that may result in an amputation or broaden the scope to other applicable OSHA regulations. This assessment will not only prepare your site in the event it is inspected by OSHA but will reduce employee risk of injury from amputation hazards. Ensuring employees are safe everyday is not only the right thing to do, but also results in a reduction in downtime and an increase in employee productivity!
At CAPACCIO, we live our mission of “Helping Industry and the Environment Prosper”. We align EHS with your overall business objectives to strategically position you for success. Our unique approach combines our extensive EHS experience with innovative tools, such as our EHS Dashboard™, to effectively address your challenges. Our comprehensive solutions have resulted in award-winning EHS and overall business performance for our clients. We are certified WBENC, WBE. To learn more visit us at www.capaccio.com.