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January-February 2020

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30 PalletCentral • January-February 2020 palletcentral.com O n December 10, 2019, OSHA launched a revised National Emphasis Program (NEP) on Amputations in Manufacturing Industries. The Directive, CPL 03-00-022, took effect immediately in federal OSHA states, and supersedes an earlier amputation-related NEP, which had been issued in 2015 under the previous administration. The program will continue for five years from the effective date. However, if there is a change in administration in 2021, new OSHA leadership could still revisit the program and make modifications or expand its scope. While the NEP was issued by federal OSHA, the Agency is requiring state-plan OSHA agencies to adopt a comparable program of equivalent effectiveness. These states are required to notify federal OSHA within 60 days as to whether they will adopt an identical amputation prevention NEP or adopt and maintain different inspection policies and enforcement procedures. Such differences must be identified on the state plan's website and the changes submitted to OSHA. Regardless of whether an identical NEP is being adopted, or a modified approach is taken by a state, the NEP enforcement must take effect by June 10, 2020. OSHA says that the intent of the amputation NEP is to target workplaces with machinery and equipment that cause (or are capable of causing) amputations, and workplaces where amputations have historically occurred, in order to reduce amputation injuries while maximizing the Agency's limited inspection resources. OSHA believes that the failure to properly apply machine guarding techniques and the failure to ON GUARD OSHA launches new amputation NEP that targets prior offenders. adequately control associated energy hazards during servicing and/or maintenance activities are primary causes of amputations. The NEP states that OSHA will generate "establishment lists" using the targeting system that includes the covered NAICS codes for operations in each area office's geographic area. The area office can add to the list, based on local evidence, other facilities where amputation injuries or fatalities related to machinery and equipment have occurred in the five years prior to December 10, 2019, regardless of their NAICS status. The local evidence can be based on OSHA database injury/illness records, employer reports of amputations, and worker's compensation data. The amended lists are randomized prior to use. Inspections generally will be scheduled in any order, if the entire master list will be inspected, and the entire list must eventually be inspected before any new list is compiled. If a random number order will be used, then the entire list need not be inspected by the OSHA area office. Importantly, establishments with 10 or fewer employees will be deleted from the NEP inspection list. Where possible, OSHA will combine an NEP inspection with other programmed inspections of the worksite or with unprogrammed ones (triggered by injury reports or worker hazard complaints). After an opening conference verifies the size of the employer and the NAICS code, the inspector will verify that equipment that could cause amputations is present in the workplace. The inspector will review the employer's OSHA 300/301 logs for three years to identify recorded amputations and associated equipment and machinery. There will be a walkaround inspection, paying attention to worker exposure to nip and pinch SAFETY By Adele L. Abrams, Esq., CMSP

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