OSHA Emphasis Programs — What is On Regulator’s Radar for Precision Machining

OSHA uses Emphasis Programs to focus on issues they deem to merit extra attention.

OSHA uses Emphasis Programs to focus on issues they deem to merit extra attention. These can be national or regional in scope, and some seem to overlap. Variously called “directions,” “directives” or “instructions,” these describe OSHA’s approach to inspections for these hazards of special interest. Check out the dates on some of these to affirm the wisdom of Milton Friedman that, “Nothing is so permanent as a temporary government program.”

National Emphasis Programs Applicable to Precision Machining Manufacturing Shops

Coronavirus Disease 2019 (COVID-19) DIR 2021-01(CPL-03)
The NEP augments OSHA’s efforts addressing unprogrammed COVID-19-related activities (for example, complaints, referrals and severe incident reports) by adding a component to target specific high-hazard industries or activities where this hazard is prevalent. (03/12/2021)

Primary Metal Industries (CPL 03-00-018)
Applicable primarily to PMPA Technical Members in primary metals. This instruction describes policies and procedures for implementing a National Emphasis Program to identify and reduce or eliminate worker exposures to harmful chemical and physical health hazards in facilities in the primary metal industries. (10/20/2014)

Lead (CPL 03-00-009)
This instruction transmits policies and procedures for implementing a National Emphasis Program to reduce occupational exposures to lead. (08/14/2008)

Hexavalent Chrome (CPL 02-02-076)
Note: metallic chrome is not hexavalent
National Emphasis Program to identify and reduce or eliminate the health hazards associated with occupational exposure to hexavalent chromium and other toxic substances often found in conjunction with hexavalent chromium. (02/23/2010)

Hazardous Machinery CPL 03-00-022
National Emphasis Program to identify and reduce or eliminate amputation hazards in manufacturing industries.

Local Emphasis Programs

Please visit PMPA.org to access the links for the following programs:

Region 1 - CT, ME, MA, NH, RI, VT

CPL 04-00-024G Local Emphasis Program for Noise in the Workplace
CPL-04-00-023G Local Emphasis Program for Powered Industrial Trucks
CPL-04-00-002I Region Wide Local Emphasis Program - Fall Hazards

Region 2 - NJ, NY, Puerto Rico, VI

2019-08 Regional Emphasis Program — Health High Hazard Top 50
CPL 2020-11 - Regional Emphasis Program — Noise Hazards

Region 3 - DE, DC, MD, PA, VA, WV

2019-14 (CPL 04) Local Emphasis Program for Health Hazards in Metal Fabrication (Except Structural)
2019-02 (CPL 04) Regional Emphasis Program for High Level Noise

Region 4 - AL, FL, GA, KY, MS, NC, SC, TN

CPL 20/03 (CPL 04) Regional Emphasis Program (REP) for Electrical Hazards
CPL 20/05 (CPL 04) Regional Emphasis Program (REP) for Noise Hazards
CPL 21/07 (CPL 04) Regional Emphasis Program (REP) for Powered Industrial Trucks
CPL 19/10 (CPL 04) Regional Emphasis Program (REP) for Safety Hazards in Auto Parts Industry – NAICS 3363XX (Motor Vehicle Parts Manufacturing)

Region 5 - IL, IN, MI, MN, OH, WI

CPL 04-00-014 Cancellation of Local Emphasis Program for Lead
CPL 04-00 (LEP 008) Emphasis Program for Fall Hazards in Construction and General Industry
CPL 04-00 (LEP 025) Emphasis Program for Federal Agencies
CPL 04-00 (LEP-100) Emphasis Program for Maritime Industries
CPL 04-00 (LEP 002) Emphasis Program for Powered Industrial Vehicles

Region 6 - AR, LA, NM, OK, TX

CPL 2 02-00-024A Regional Emphasis Program for Fall Hazards in Non-Construction Industries
CPL 2 02-00-027A Regional Emphasis Program for Heat Illnesses
CPL 2 02-00-023A Regional Emphasis Program for High Noise in Manufacturing Industries
CPL 2 02-00-022B Regional Emphasis Program for Safety & Health Hazards in the Manufacture of Fabricated Metal Products

Region 7 - IA, KS, MO, NE

CPL 2-15-01F Regional Emphasis Program (REP) for Powered Industrial Trucks and Other Material or Personnel Handling Motorized Equipment in Construction, General Industry and Maritime
CPL 02-16-03E Regional Emphasis Program (REP) High Hazard Safety and Health Workplace Inspections
CPL 02-11-01K Regional Emphasis Program (REP) – Work Places with Noise and Respiratory Hazards
CPL 02-08-02H St. Louis Local Emphasis Program (LEP) for Electrical Hazards in General Industry

Region 8 - CO, MT, ND, SD, UT, WY
No directives targeting fabricated metal precision machining shops.

Region 9 - AZ, CA, HI, NV, and American Samoa, Guam and Northern Mariana Islands

CPL 04-00-01 Regional Emphasis Program for Amputations

Field Operations Manual

The OSHA Field Operations Manual was issued as Directive CPL 02-00-164 on April 14, 2020. It has been subsequently adopted by most state-plan states. However it was not accepted identically by Alaska, Connecticut, Illinois, Michigan, New Mexico, New York, Oregon, Virginia, Vermont, Washington and Wyoming. Please see those states’ websites for details. This information is up-to-date as of 3/21/2021.

COVID-19, Lead, Noise, Amputation Hazards/Hazardous Machinery, Fall Hazards, Electrical and Industrial Trucks appear to be topics meriting the most attention by OSHA across the country. Use all the links referenced in this article to understand what the inspection approach is all about.

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About the Author

Miles Free III

Miles Free III is the PMPA Director of Industry Affairs with over 40 years of experience in the areas of manufacturing, quality, and steelmaking. He helps answer “How?, “With what?” and “Really?” Miles’ blog is at pmpaspeakingofprecision.com; email – mfree@pmpa.org; website – pmpa.org