Tag: 1910.212 Machine Guarding

OSHA Amputation National Emphasis Program-Renewed

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On December 10, 2019, the U.S. Department of Labor’s Occupational Safety and Health Administration issued an instruction (Directive)  CPL 03-00-022 cancelling the prior  NEP CPL 03-00-019 National Emphasis Program on Amputations, August 13, 2015, and describes the policies and procedures for the continued implementation of the National Emphasis Program  to identify and reduce Amputation hazards in Manufacturing Industries.
We covered the prior NEP notice in our post HERE

OSHA’s enforcement history shows that employees are often injured when machinery or equipment is not properly guarded or maintained.  This NEP targets industrial and manufacturing workplaces having machinery and equipment that can potentially cause amputations. Our 332- manufacturing NAICS codes are identified in this updated instruction.

See the source image
 

OSHA Instruction: CPL 03-00-022, National Emphasis Program on Amputations in Manufacturing Industries, is now available:

Directive Type: OSHA Instruction

Directive number: CPL 03-00-022

Directive subject:  National Emphasis Program on Amputations in Manufacturing Industries

Effective Date: 12/10/2019

Cancellation/Archive including PDF: CPL 03-00-019, National Emphasis Program on Amputations, August 13, 2015

https://www.osha.gov/enforcement/directives/cpl-03-00-022

To support the purpose of this NEP, OSHA is beginning a three-month period of education and prevention outreach to encourage employers to bring their facilities into compliance with OSHA standards.   Additional outreach and compliance assistance material will be forthcoming in the near future.

We will be providing reminders to our shops to retrain shop personnel in 1910.147 Control of Hazardous Energy and  1910.212 Machine Guarding – General Requirements. These are relevant to preventing amputations as well as being two of the 5 most prevalent general industry related violations in 2019.
We are hopeful that this time around, the Agency will give equal attention to enforcing part (b) of Section 5 of the OSH Act: “Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.”
OSH Act Sect 5 part (b)

OSHA's Top Ten Most Frequently Cited Standards- FY 2015

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OSHA Penalties increased 78% August 1, 2016.

Think of your efforts here as an investment in "Penalty Prevention."
Think of your efforts here as an investment in “Penalty Prevention.”

The following is a list of the top 10 most frequently cited standards following inspections of worksites by federal OSHA for Fiscal Year 2015.

  1. 1926.501 – Fall Protection (C)
  2. 1910.1200 – Hazard Communication
  3. 1926.451 – Scaffolding (C)
  4. 1910.134 – Respiratory Protection
  5. 1910.147 – Lockout/Tagout
  6. 1910.178 – Powered Industrial Trucks
  7. 1926.1053 – Ladders (C)
  8. 1910.305 – Electrical, Wiring Methods
  9. 1910.212 – Machine Guarding
  10. 1910.303 – Electrical, General Requirements

Note,  the standards that are numbered 1926.XXX – Numbers 1. Fall protection, 3. Scaffolding, and 7. Ladders, are Construction industry, rather than General Industry. Nevertheless, Fall Protection and Ladders are relevant in our manufacturing shops as well. Source: Top Ten Standards 2015
In our work with shops involved in OSHA inspections, we have learned that failure to have documented training and evidence is the more likely to be the root cause of the citation. You must train and you must be able to provide documentary evidence of the training.
A savvy management will take steps in their shops to find and fix recognized hazards addressed in these and other standards before OSHA shows up.
 
Action Steps:

  1. Electrical-On your next walk around the shop, look for outlets and power boxes that are not in good condition and schedule their repair ASAP. If you can see wiring or damage- that is likely a violation.
  2. Machine Guarding– This is a particular area of OSHA emphasis. Are all provided guards in place, or are they being removed or defeated? Each instance would be a violation.
  3. Lockout/Tagout– This too is an OSHA emphasis and on their regulatory agenda for review. Now would be a good time to review that all affected employees have been trained. That evidence exists of that training. And that you have audited  to assure performance. (If I went into your shop and saw a machine undergoing a major changeover, would I find it locked out?)

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