Issue link: http://palletcentral.uberflip.com/i/1194984
28 PalletCentral • November-December 2019 palletcentral.com those related to OSHA emphasis programs and its relaunched site-specific targeting program, account for about 14,000 OSHA inspections, while unprogrammed events trigger about 18,000 inspections per year at the federal level. When the Trump administration began, there were over a dozen National Emphasis Programs (NEPs); now there are only eight remaining. However, in October 2019, OSHA launched 13 new regional and local emphasis programs, designed and implemented at the regional office and/or area office levels which are intended to address hazards or industries that pose a particular risk to workers in the office's jurisdiction. The main NEPs applicable to pallet operations are: Combustible Dust (CPL 03-00-008); and Hazardous Machinery (CPL 03-00-019, including amputation emphasis). Operators in an industry covered by one of the national, regional or local emphasis programs have an increased likelihood of seeing an OSHA inspection at their sites. Courts have held that random selection of a company covered under one of these emphasis programs may constitute probable cause for a search and inspection when OSHA attempts to obtain a warrant. When an NEP inspection is appropriate, the agency will conduct random, target inspections in accordance with the agency's Field Operations Manual. The cheapest citations to defend are the ones that are never issued, and companies with zero injuries are the least likely to experience an OSHA visit. Make a new year's resolution to focus on OSHA compliance and injury/illness prevention. Have a safe and healthy 2020! PC SAFETY Adele L. Abrams is an attorney and safety professional who represents companies in litigation with OSHA and also provides safety training and consultation. Sarah Korwan is an attorney who handles cannabis, employment and safety law in WV. The Law Office of Adele L. Abrams PC has three offices: Beltsville, MD; Denver, CO; and Charleston, WV. They may both be reached at www.safety-law.com or phone: 301-595-3520. OSHA is continuing to be driven by the tens of thousands of "severe injuries" being reported as a result of fatalities, in-patient hospitalizations, eye loss and amputations.