In part one of this series, we introduced readers to the OSHA National Emphasis Program, as well as the top 80 industries that will be targeted. Today, we would like to walk you through the five inspection procedures, and how you can prepare.
As mentioned previously, the selection process is randomized by the area offices, so if you’re part of the 80 industries at risk (and are not part of the VPP), you will likely have an inspector at your door.
If you are among the employers randomly selected, the following inspection procedures are initiated under this NEP will be scheduled and conducted in accordance with provisions of the FOM, Inspection Procedures, except as noted below.
1. Once an inspection has been scheduled in the Area office and assigned for the identified establishment, the OSHA Public Inspection Data Web Page will be searched for the employer’s citation and fatality/accident history prior to the opening conference.
2. At the opening conference, the CSHO will verify with the employer whether any of machinery and equipment in the table below or any other machinery and equipment that could cause amputations are present in the workplace.
|Equipment and Machinery that Will be Checked (Not Inclusive)|
|Agricultural, garden machinery, bailers||Aerial lift platforms|
|Benders, Rollers and Shapers||Cranes (unspecified)|
|Casting Machinery||Conveyors – Belt, Chain, Live Roller, and Auger Screw Conveyors|
|Heating and cooking machinery and appliances||Drills – Stationary|
|Extruding Machinery||Food and Beverage Processing|
|Grinders, Abraders, and Meat Grinders||Material and personnel handling machinery|
|Metal, woodworking, and special material machinery||Milling Machines|
|Mowing machinery||Mixers, Blenders, Whippers, Slicers, and Food Beverage Processing Equipment|
|Packing, Wrapping, Bundling Machinery||Plastic Injection Molding Machinery|
|Press Brakes (All Types)||Presses (Mechanical, Hydraulic, and Pneumatic)|
|Printing Presses||Sawing Machinery – (Band, Table, Radial Arm Saws)|
|Shears (All Types)|
If any machinery and equipment associated with amputations are present in the workplace, the CSHO should exercise professional judgment in conducting an inspection of the machinery and equipment with particular attention to employee exposure to nip points, pinch points, shear points, cutting actions, and other point(s) of operation. The CSHO should consider and evaluate employee exposures during any of the following:
- 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;
- Cleaning of the machine;
- Oiling or greasing of the machine or machine pans;
- Scheduled/unscheduled maintenance; and
- Locking out or tagging out.
3. OSHA 300 logs, and 301 incident reports for current and previous three years will be reviewed during the inspection in order to identify recorded amputations associated with machinery and equipment.
4. Inspections will be scheduled beginning with the current fiscal year, and will continue until further notice or until all establishments on the list have been inspected.
5. ADs, Supervisors, Team Leaders, and CSHOs should ensure that the requirements for Chapter 5. Case File Preparation and Documentation, (including significant cases) are being met.
Understanding Reporting Requirement Updates
As incident reports and logs will be reviewed during the inspection, we would like to highlight again the changes that took place at the beginning of this year.
Occupational Injury and Illness Recording and Reporting Requirements – NAICS Update and Reporting Revisions.
29 CFR Part 1904 has new requirements for reporting work-related fatalities, hospitalizations, amputations or losses of an eye. The new rule, which also updates the list of employers partially exempt from OSHA record-keeping requirements, went into effect on Jan. 1, 2015, for workplaces under federal OSHA jurisdiction. (See 79 FR 56129, Occupational Injury and Illness Recording and Reporting Requirements – NAICS Update and Reporting Revisions, September 18, 2014.) As part of this NEP, if a report of amputation is received and the employers classified activity is one of the identified NAICS codes, AOs will conduct an inspection based on the Serious Injury Report (SIR) guidance; regardless of the outreach period.
There are two major changes to the former reporting requirements:
- First, whereas the former regulation applied to employment incidents that resulted in one or more fatalities or hospitalizations of three or more employees, the regulation is expanded to require the reporting of all work related fatalities, all work-related in patient hospitalizations of one or more employees, all work-related amputations and all work-related losses of an eye.
- Second, for any in-patient hospitalization, amputation, or eye loss employers must report the incident within 24 hours of learning about it. Fatalities must be reported within 8 hours of learning of the incident.
Employers have three options for reporting the event:
- Telephone the nearest OSHA Area Office during normal business hours.
- Telephone the 24-hour OSHA hotline (1 800-321-OSHA or 1-800-321-6742).
- OSHA is developing a new means of reporting events electronically, which will be released soon and accessible on OSHA’s website.
At Optimum Safety Management, we are committed to helping you minimize the injuries in the workplace and recognize the productivity, profitability, and engagement that comes with an effective safety management system.
Learn more about how we can help you not only ensure compliance to OSHA rules, but also to create a safety culture to drive returns.
Watch our webcast, Five Critical Elements of an Effective Safety Management System, and if an inspector is at your door, call our Safety Helpline at 1-888-70-SAFT-T.