OSHA Focuses Inspection Efforts on Ergonomics & Process Safety Management in High Hazard & Health Workplace Industries (*See Lists Below)

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OSHA is adding yet another Regional Emphasis Program (REP) to their list of already active inspection programs.  The most recent REP has an effective date of January 25, 2016 and will last through (at a minimum, September 30, 2016).  Though this will likely be renewed for a longer time frame.  Below are the two main areas of emphasis you need to be educated on regarding this new emphasis program

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Ergonomic Emphasis for General Industry

Does your company have a high rate of back injuries, sprains, strains &/or repetitive motion industries?  Well, OSHA is tired of seeing these rates continue to increase in what they consider high hazard general industry companies.  They're ready to nip it in the bud & bring awareness to these industries by means of random inspections, citations & heavier penalties.  Read this excerpt from OSHA regarding their citation policy on this subject:

"Before issuing any citation alleging ergonomic hazards, OSHA will consider the evidence in the particular case, as well as other relevant factors. The basic criteria OSHA will use in deciding whether to cite are those imposed by the General Duty Clause itself:

• whether an ergonomic hazard exists
• whether that hazard is recognized
• whether the hazard is causing, or is likely to cause, serious physical harm to employees
• whether a feasible means exists to reduce the hazard

OSHA will not focus its enforcement efforts on employers who are making good faith efforts to reduce ergonomic hazards. This means the employers must implement ergonomic efforts at individual worksites. OSHA has issued citations to companies that have evidenced corporate commitment to lowering ergonomic hazards in their workplaces BUT have failed to effectively implement that commitment at specific sites. The General Duty Clause applies to conditions at individual worksites. Therefore, corporate commitment must be translated to positive action at the individual workplaces, or OSHA will not hesitate to issue citations where appropriate."

"Even in cases where OSHA does not cite an employer, if ergonomic hazards exist, it may issue hazard alert letters describing ways to reduce the hazards and resources available to assist employers in this process. An important new feature is that OSHA will follow up with some companies that receive these letters, checking to evaluate what actions the employers have taken to address ergonomic hazards."

*Talk to a SSG Consultant about ways we can assist you with the detailed process necessary to both train on & assess the various departments within your organization.

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Process Safety Management Emphasis for General Industry & Healthcare Companies

The second major emphasis in this REP relates to Process Safety Management (PSM).  The following is a definition of PSM:

"Process safety management is an analytical tool focused on preventing releases of any substance defined as a "highly hazardous chemicals" by the EPA or OSHA. Process Safety Management (PSM) refers to a set of inter-related approaches to manage hazards associated with the process industries and is intended to reduce the frequency and severity of incidents resulting from releases of chemicals and other energy sources (US OSHA 1993). These standards are composed of organizational and operational procedures, design guidance, audit programs, and a host of other methods."

Within the current REP Notice, this statement below gives us greater insight into what they will be targeting regarding your PSM program:

"Process Safety Management (PSM) related processes will include an initial evaluation of only the following: employee participation, training, contractors, hot work permits, incident investigation, and emergency planning, and response."

*Talk to a SSG Consultant about the 14 elements of an effective PSM Program as well as conducting an overall assessment on the effectiveness of your current program.

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Ongoing Emphasis Programs Still Active

What many companies fail to realize is that there are several other emphasis programs still active.  Not only do they have the right to check for the current emphasis items, they can also expand their scope into a comprehensive, wall-to-wall audit that includes everything within the 1926 & 1910 standards.  Please be mindful of this and allow SSG to assist you in keeping your team safe & your company compliant.  The other active OSHA programs SSG can continue to assist you with are:

• Lead
• Silica
• Isocyanates
• Formaldehyde
• Methylenechloride 
• Amputations/Machine Guarding

*All of these can be tested/assessed by a SSG Consultant

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NAICS Codes Associated with the Ergonomic & PSM Emphasis Program

Rank    Industry  (Safety)                                                          NAICS
1          Furniture and Related Product Manufacturing         337
2          Computer and Electronic Product Manufacturing   334
3          Food Manufacturing                                                      311
4          Nonmetallic Mineral Product Manufacturing            327
5          Fabricated Metal Product Manufacturing                  332
6          Machinery Manufacturing                                            333

Rank    Industry  (Health)                                                         NAICS
1          Printing & Related Support Services                           323
2          Beverage & Tobacco Product Manufacturing           312
3          Miscellaneous Manufacturing                                     339
4          Wood Product Manufacturing                                     321
5          Primary Metal Manufacturing                                      331