OSHA recently renewed its national emphasis program focused on preventing amputations in manufacturing, effective June 27. The national emphasis program will remain in place for five years, and programmed inspections may begin on September 25. The renewal of the program is not surprising, given that LOTO and machine guarding are continuously listed in OSHA’s annual Top 10 most frequently cited standards. Amputations are also a common reason why manufacturing employers are required to self-report a severe injury, which typically triggers an OSHA inspection.
The renewed program includes a number of revisions to the prior national emphasis program, including updating the NAICS establishment codes covered by the program, allowing establishments under the former program that did not report an amputation in the previous 24 months to be deleted from the programmed inspection list, and some changes to OSHA’s coding instructions.
Manufacturing facilities should strongly consider taking affirmative steps to review their LOTO and machine guarding policies and practices. Some potential actions could include internal or external safety audits, including random self-audits; supervisory and employee retraining; conducting regular safety meetings covering these topics; forming safety committees and/or increasing employee participation to identify amputation hazards; and reviewing OSHA logs to identify noticeable patterns. Employers should pay particular attention to pinch points on any equipment where specialized modifications have been made, the physical location has changed, and/or the equipment is older. All such preventive measures should be documented. These types of self-initiatives both minimize the likelihood of amputations or similar injuries and may serve as valuable defensive tools if the establishment is targeted for an OSHA inspection under the program or in response to a complaint.
