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September-October-2015

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palletcentral.com PalletCentral • September-October 2015 39 • Cleaning of the machine; • Oiling/greasing of the machine or its parts; • Scheduled/unscheduled maintenance; and • Locking out or tagging out. The inspector will also review OSHA 300 logs and 301 incident reports for several years, to identify recorded amputations. OSHA's regional administrators will have to report annually on the number of NEP inspections planned for each fiscal year and ensure that adequate resources are designated for the program. The NEP inspections have a higher priority than other scheduled program inspections, but may be combined with other existing federal initiatives, such as the combustible dust NEP, or local emphasis programs that target establishments on a different basis. However, if a worksite has been accepted into OSHA's Voluntary Protection Program (VPP), it will be exempt from these NEP inspections, although it can still be inspected if a reportable accident occurs. The launching of the amputation NEP will likely result in more inspections and citations for the wooden pallet and container industry. Guarding practices, training and lockout/tagout procedures will all come under heavy scrutiny. This makes it more critical than ever to document all training, and to refresh the training when a new task is assigned or equipment is modified or replaced. In addition, take care not to modify the design of equipment by removing or altering guards without the manufacturer's approval. Finally, make sure that each worksite has written lockout/tagout procedures for each piece of equipment in the facility and ensure that affected and authorized employees understand the procedures. Inspections under the NEP will start very soon! PC Adele L. Abrams is an attorney and safety professional who represents companies in litigation with OSHA and also pro- vides safety training and consultation. The Law Office of Adele L. Abrams PC has three offices: Beltsville, MD; Denver, CO; and Charleston, WV. Adele can be reached at 301-595- 3520 or www.safety-law.com. Guarding practices, training and lockout/tagout procedures will all come under heavy scrutiny. This makes it more critical than ever to document all training, and to refresh the training when a new task is assigned or equipment is modified or replaced.

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