Issue link: http://palletcentral.uberflip.com/i/579895
38 PalletCentral • September-October 2015 palletcentral.com clinics, and through meetings with employers, associations and unions to help identify and eliminate hazards associated with machinery and amputations. The outreach will include the smallest employers—those with 10 or fewer workers—although they are exempt from NEP-triggered inspections (but not from those arising from a reported amputation injury). When targeting worksites for inspection, area offices will add to the master inspection list those establishments where amputation injuries or fatalities related to machinery and equipment have occurred in the five years preceding the effective date of the directive (6/30/15). Inspections of the listed establishments will be "randomized" once the full list is compiled. Evidence of amputations will be based on OSHA's own data, worker's compensation data, OSHA 300 log data, NIOSH data, and other reliable sources of information such as hospital reports, EMS, fire department, and police reports. The area offices can also delete establishments from the list if they are not likely to have the targeted equipment, or if they are known to be out of business. However, if a new business is using the equipment or plant of the predecessor business, an inspection will proceed. If a listed site has not had any actual amputations and also had a comprehensive OSHA safety inspection within the previous 24 months, it will be deleted from the NEP inspection list. Once an employer's work establishment is scheduled for inspection, OSHA will do an updated citation/fatality/accident history search. Any citations that became final within the previous five years can be used as a trigger for a "repeat" citation (with penalties from $7,000 to $70,000 per violation) and so it can be expected that OSHA will pay special attention to the conditions or equipment involved in past violations or with prior accidents. At the opening conference, the inspector will verify with the employer whether any of the equipment and machinery listed in Appendix A of the NEP Directive is present in the workplace. If it is, the inspector will examine the machinery with particular attention to employee exposure to nip points, pinch points, shear points, cutting actions and other points of operations. The inspector is told to use "professional judgment" in determining employee exposure during: • Regular operation of the machine; • Setup/threading/preparation for regular operation of the machine; • Clearing jams or upset conditions; • Making running adjustments while the machine is operating; SAFETY Resources OSHA QuickTakes Newsletter http://1.usa.gov/1qF1fUe Safeguarding Equipment and Protecting Workers from Amputations http://1.usa.gov/1Rwjy7d OSHA Library (By Topic, By Type, Bilingual) http://1.usa.gov/1TNfUd4 OSHA-NWPCA-NIOSH Documents http://1.usa.gov/1QQ0BBj The launching of the amputation NEP will likely result in more inspections and citations for the wooden pallet and container industry.