February 20, 2020
The 90-day education and outreach program for the National Emphasis Program (NEP) to identify and reduce or eliminate amputation hazards in manufacturing industries is nearing its end date of March 10, 2020. After this date, OSHA’s enforcement activities will begin. Managed by the U.S. Department of Occupational Safety and Health Administration (OSHA), NEPs are programs that focus OSHA’s resources on high-hazard industries and on specific hazards known to frequently occur or be at increased risk of happening due to the nature of the equipment used in a facility.
OSHA recently updated its NEP on amputations to further refine its targeting methodology and to revise coding requirements for amputation inspections in the OSHA Information System. The 90-day outreach program, which started in December 2019, allows manufacturers impacted by the revisions to receive support in the form of education and notifications of intent before the implementation of OSHA’s changes to the program.
“OSHA’s methodology for determining which industries to target is very comprehensive. We have been notified that seventy-five North American industries have been placed on the targeted list,” said Ken Hackworth, a licensed professional engineer and UL machine safeguarding expert. “Employers are advised to take a training class in modern machine safeguarding and risk assessment. Machine safeguarding technology is not what it used to be,” he advised.
Tony Robertson, business development manager for UL’s Energy and Power Technologies division, agreed with Hackworth’s recommendation. “It’s a very diverse list of industries,” he said. “One that stood out to me is the semiconductor industry. Manufacturers and employers need to take a look to see if they will be subject to increased inspection activities.”
The NEP directive covers facilities within the fabricated metal product, food, furniture and related products, machines, nonmetallic mineral product, paper, plastics and rubber, primary metal, transportation equipment and wood product manufacturing subsectors.
Programmed and planned inspections
Inspections under this NEP are to be programmed and planned according to the executive summary released by OSHA. Area offices will generate establishment targeting lists using software provided by OSHA’s Office of Statistical Analysis. Inspectors will pay particular attention to hazards such as nip points, shear points, cutting actions and other aspects of operation during the workplace assessment.
“The methodology used by OSHA is systematic and comprehensive,” Robertson said. “It’s emphasizing the employer’s awareness of the potential hazards within their machines — machine safeguarding and functional safety are key aspects of compliance and risk reduction.”
“It’s imperative that whenever a machine is installed, you have specific risk reduction measures in place,” Hackworth said. “Well trained safety engineers are aware of the OSHA regulations and methods needed to comply. For example, one of the most critical aspects is ensuring that you have effective alternative protective measures in place, including adequate functional safety performance “control reliability” and compliant safeguarding.”
“For manufacturers that have been identified for the NEP amputation program, they are going to be subject to inspection over the next five years, and it’s best to be proactive on whether their machinery meets OSHA guidelines,” he said. “We highly recommend updated training and third-party machine safety audits to make sure you’re in the clear.”
“Many employers simply overlook machine hazards until it’s too late. UL can help you be proactive in identifying machine safety issues and provide practical guidance on how to improve machine safeguarding.”
Is your facility ready to meet the new guidelines? UL’s Machine Risk Assessment Services includes on-site risk assessments and machine safeguarding audits of industrial machinery to OSHA, ANSI, NFPA, RIA and applicable ISO standards. Discover how our services can help you proactively meet regulatory workplace safety needs.