OSHA has had a national emphasis progam (NEP) for amputations since 2006. In July, OSHA updated this NEP for the first time since its inception. The update includes a number of additional NAICS codes that will be included. As of now, none of the NAICS codes included in the NEP has anything to do with agriculture except the manufacturers of agricultural machinery and equipment. So, cotton gins are not necessarily included in the NEP.
So, why are we even bringing it up? Whenever there is an NEP, the targeted industries are the ones that extra inspections and targeted to get higher fines etc. but any time they are made aware of an incident that involves a NEP injury, OSHA pays extra attention to the report even if it’s not at a targeted industry.
With the expanded reporting requirements that we’ve discussed in past articles, amputations will run a greater risk of drawing an OSHA inspection even if they would only normally be required to do a self inspection and root cause analysis.
It will be interesting to see how this new NEP works in with the rest of the new programs and policies that OSHA has been doing in the past few years. OSHA’s staff has not been expanded significantly and they will be hustling to deal with the additional reports they will be receiving under the new reporting requirements.
These new requirements are going to be one of the major discussion topics at our upcoming state meetings in September.
Don’t hesitate to call if you have any questions.