July-August 2015

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24 PalletCentral • July-August 2015 or a number of years, OSHA has taken aim at amputation hazards across many industries, including pallet manufacturers and companies that disassemble pallets. In 2002, OSHA's initial amputation National Emphasis Program (NEP) was expanded to cover a variety of machine types associated with this hazard. The NEP was renewed in 2006 and still is a major trigger for inspections of pallet facilities. Moreover, with the new injury reporting requirements that took effect on January 1, 2015, in federal OSHA states, employers must notify OSHA within 24 hours of any amputation (full or partial), loss of an eye, or other injury that requires in-patient hospitalization. State plan states will have until early next year to comply, although some states have already adopted their version of the requirements. So far, about 60 percent of establishments filing such reports are visited by OSHA for a full-blown incident investigation, while the remainder must complete a "Rapid Response Letter" within 5 calendar days or they too will be inspected. The convergence of these two programs has put band saw safety back in the spotlight for pallet companies because this equipment has historically been the source of serious workplace injuries. During the 1990s, the wooden pallet manufacturing industry experienced a much greater than average overall rate of non-fatal injuries (288 percent higher than average) and an even worse rate of amputations (1317 percent higher than average), cuts and punctures (818 percent higher than average). Even with the progress made over the past several decades—including a period in the George W. Bush administration when NWPCA had an alliance with OSHA to work on improvements in this area—band saws will still come under scrutiny during OSHA routine inspections, NEP-based inspections and in accident investigations. A study by the National Institute for Occupational Safety and Health (NIOSH) more than a decade ago, which arose from an alliance with NWPCA, led to recommendations on how best to protect workers, and efforts are ongoing. Best Practices for Band Saw Safety By Adele L. Abrams, Esq., CMSP SAFETY F

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