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OSHA Updates Its National Emphasis Program on Amputations

  • September 2, 2015

Noting that the manufacturing sector experienced more than twice the rate of amputations as that of the entire private sector in 2013, the Occupational Safety and Health Administration has updated its nine-year-old National Emphasis Program (NEP) on amputations.

The NEP targets industries with high numbers and rates of amputations, using current OSHA enforcement data and data from the Bureau of Labor Statistics (BLS). The targeting methodology is identical to that used in the original NEP, dating from 2006. According to OSHA, the amputation rate in the manufacturing sector in 2013 was 1.7 per 10,000 full-time employees, compared to 0.7 for all of the private sector. The rate equates to 2,000 amputations in the manufacturing sector that year, OSHA said.

“This directive will help ensure that employers identify and eliminate serious workplace hazards and provide safe workplaces for all workers,” OSHA Assistant Secretary Dr. David Michaels said in an August 13 press release announcing the revised NEP, which went into effect on June 30, 2015.

The NEP applies to general industry workplaces in which any machinery or equipment likely to cause amputations are present and includes a list of 80 industrial activities with BLS-reported high numbers and rates of amputations.

The directive includes a 90-day program during which establishments newly added to the targeting list will be offered outreach prior to inspection. The NEP advises OSHA compliance officers to pay particular attention to potential employee exposure to nip points, pinch points, shear points, cutting actions, and other point(s) of operation when inspecting machinery and equipment.

In addition, inspectors are directed to evaluate employee exposures during regular operation of the machine, setup/threading/preparation for regular operation, clearing jams or upset conditions, making running adjustments while the machine is operating, cleaning, oiling or greasing of the machine or machine pans, scheduled/unscheduled maintenance, and locking out or tagging out. An official of OSHA’s area office in Colorado said the agency will look at lockout/tagout programs and if there has been a guarding analysis of each machine in use.

OSHA also reminded employers of new requirements for reporting work-related fatalities and severe injuries, such as amputations. Employers must now report fatalities within eight hours of learning of the incident and any in-patient hospitalization, amputation, or loss of an eye within 24 hours. OSHA noted in the NEP that data available to the agency “suggest that amputation-related inspections were being under-reported.”

Employers can reduce the risks of enforcement by auditing and reviewing their injury records and reporting guidelines to ascertain whether there is a need for program changes consistent with the OSHA mandates.

©2015 Jackson Lewis P.C. This Update is provided for informational purposes only. It is not intended as legal advice nor does it create an attorney/client relationship between Jackson Lewis and any readers or recipients. Readers should consult counsel of their own choosing to discuss how these matters relate to their individual circumstances. Reproduction in whole or in part is prohibited without the express written consent of Jackson Lewis.

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