Issue link: http://palletcentral.uberflip.com/i/1212207
PalletCentral • January-February 2020 31 points, cutting actions, shear points and other points of operation. The inspector will consider clearing jams or upset conditions, set up exposures, regular operation of machines, making adjustments during operations, oiling and greasing of machines, maintenance and LOTO procedures. Because these standards also require worker training, OSHA will interview employees as to their understanding of SOPs, and evaluate the adequacy of training. According to U.S. Congress, OSHA currently has the lowest number of inspectors since the Agency was created in 1970, and if all things were equal, each employer would be able to be inspected once every 165 years! However, for workplaces that fall within the North American Industrial Classification System (NAICS) codes covered by any OSHA National Emphasis Program, the odds of being inspected increase dramatically. For the Amputation NEP, OSHA has targeted 27 five-digit NAICS codes, 81 percent of which are in the manufacturing sector. All NAICS listed in Appendix A begin with NAICS Code 31, 32 or 33 – so the wood pallet NAICS of 321920 and 321999 are included. These manufacturing employers must also file on-line injury and illness reports under OSHA's electronic recordkeeping rule, for all worksites with 20 or more workers. The NEP applies to general industry workplaces identified pursuant to paragraph IX(B)(7) where any machinery and/or equipment that are likely to cause amputations are present. OSHA states, as background in support of the initiative: "Operating machinery or equipment can be extremely dangerous when it is not properly guarded or maintained. Injuries involving machinery or equipment often result in death or permanent disability." OSHA's enforcement history shows that employees performing servicing or maintenance work on machinery or equipment often are injured when no machine guarding is present. The main changes from the 2015 NEP include: • Revision of the coding requirements for all OSHA amputation inspections in the OSHA Information System; • Revision of the targeting methodology to include data from the amputation reporting requirement under 29 CFR 1904.39 (the "Severe Injury Reporting" rule); and, • Modification of the list of covered worksites (the old version relied on the outdated "SIC" code OSHA Safety Resources N WPCA collects articles like this one on NEPs, and other valuable resources specific to the wood packaging industry. OSHA's role is to ensure safe working environments for America's working men and women by setting and enforcing standards, and providing training, education and assistance. Visit PalletCentral.com/ OSHASafety to access past articles written specifically for the wood packaging industry, direct links to OSHA-free consultation, and sign-up for OSHA QuickTakes Newsletter.