Issue link: http://palletcentral.uberflip.com/i/666889
n February 2016, the Occupational Safety & Health Administration (OSHA) notified NWPCA that the pallet manufacturing industry would be subject to a "Local Emphasis Program" (LEP) in the state of Wisconsin, focusing on the hazards associated with pallet assembly and disassembly, and the use of powered industrial trucks. The LEP for the Wood Pallet Manufacturing Industry is CPL 03-00 (LEP-028) and details of the initiative can be downloaded at http://www.osha.gov/dep/leps/leps.html#R5. The pallet industry sector is already targeted under existing OSHA National Emphasis Programs covering amputation prevention, lockout/tagout, and combustible dust, but the new local program is another example of how the industry is now in OSHA's crosshairs for enforcement. In the letter announcing the LEP, OSHA notes that it is critical that employers evaluate their workplaces to "identify potential hazards that may be present and implement corrective actions to protect workers from injuries and illnesses. It also highlights the need for proper employee training (and this would also apply to workers furnished by temporary staffing agencies), both prior to initial assignments, and whenever the workplace changes. Monitoring the workers to ensure that safe work practices are learned and followed is also expected by OSHA under the LEP. When OSHA comes knocking under these emphasis programs, they will pay specific attention to safe guarding of equipment, control of hazardous energy (the LOTO program), electrical safety, wood dust, general housekeeping, powered industrial vehicles (e.g., forklifts), hazard communication, personal protective equipment, stacking of materials, and exposure to occupational noise. In other words, this will be virtually a wall-to-wall inspection covering most aspects of workplace safety and, given that OSHA penalties are set to rise from a current maximum (per citation) of $70,000 to over $127,000 starting in August 2016, a bad inspection could threaten the ability of small companies to remain in business. Concurrent with the issuance of the targeted LEP, OSHA also released new guidelines for implementation of Safety & Health Management Programs (SHMP) in all OSHA-regulated workplaces. While the comment period on the proposed update to the 1989 SHMP Guidelines has closed, the agency is still collecting input from the regulated community through discussions at stakeholder meetings and through its federal advisory committees. While the revised Guidelines will be "voluntary" (at least at this point), OSHA is increasingly making adoption of an approved 22 PalletCentral • March-April 2016 palletcentral.com I Hazard Identification and Mitigation: Critical Elements of Safety Management By Adele L. Abrams, Esq., CMSP SAFETY