Issue link: http://palletcentral.uberflip.com/i/1212207
32 PalletCentral • January-February 2020 palletcentral.com 32 PalletCentral • January-February 2020 palletcentral.com system) using the NAICS system; and changes to the machinery and equipment from the previous NEP and removal of certain ANSI/ASME standards from the previous NEP. The main rules referenced to be enforced under the NEP include: • 29 CFR Part 1904 injury/illness reporting and recording requirements – failure to include amputations on the employer's logs or failure to timely report are among the items that could be cited, and while classified as "other than serious" such paperwork violations can be cited per employee and can be characterized as willful or repeat, with a maximum OSHA penalty of $134,937. • 29 CFR Part 1910, Subpart J – this includes general environmental controls, as well as 1910.147, control of hazardous energy (Lockout/Tagout or LOTO). • 29 CFR Part 1910, Subpart O – this includes all machinery and machine guarding standards (most cited is 1910.212). • 29 CFR Part 1910, Subpart P – this covers hand and portable power tools and other hand-held equipment. In the 2019 NEP directive, OSHA also cross- references its guidelines for point-of-operation guarding for power press brakes (1997), slide-locks enforcement policy (2007), and its CPL 02-00- 147, addressing enforcement policy and inspection procedures for the LOTO standard, 1910.147. These should all be reviewed by employers in preparing for an OSHA NEP inspection, for the applicable equipment. In particular, the relevant OSHA standards for guarding (which cover different classes of equipment, from band saws to power presses, and conveyor systems) should be reviewed as they set forth measures for the safe operation, servicing and maintenance of machinery and equipment. OSHA often will impute knowledge of appropriate guarding and work practices from a manufacturer's handbook or maintenance manual and will not accept as a Relevant OSHA standards for guarding (which cover different classes of equipment, from band saws to power presses, and conveyor systems) should be reviewed as they set forth measures for the safe operation, servicing and maintenance of machinery and equipment.