Are you targeted under an OSHA emphasis program?

Did you know that OSHA publishes detailed documents on which business operations the agency plans to target for inspection? OSHA currently has 12 National Emphasis Programs (NEPs) and more than 100 Regional and Local Emphasis Programs (LEPs). These directives instruct the OSHA offices around the country on which topics they should prioritize for inspection, and which violations the compliance officers should look for during walkarounds.

Some of the more recently adopted NEPs include:

• Fall prevention/protection (covers roof work, window washers, and similar operations);
• Warehousing and distribution centers (plus high-risk retail operations like home centers, hardware stores, building material dealers, and supermarkets); and
• Indoor and Outdoor Heat-Related Hazards (covers many industries including warehousing, hotels, wholesalers, and nursing care).

In addition to listing the targeted industries by North American Industry Classification System (NAICS) codes, these documents describe the specific enforcement focus areas. For example, the warehousing NEP instructs compliance officers to focus on forklift operations, material handling/storage, walking-working surfaces, means of egress, fire protection, heat stress, and ergonomic hazards.

Impact on any industry

Even if your particular industry isn’t listed in the NEPs or LEPs, those documents can still provide clues to what OSHA will likely look for at your facility. Most OSHA compliance officers don’t memorize all of the agency’s regulations. Before heading out to visit an employer, the inspector will brush up on standards most likely to apply at that location. And if the inspector recently reviewed the citations guides for things like forklifts or heat stress, those areas will likely remain in the inspector’s mind.

Not all the programs are specific to industries. Eight of OSHA’s ten regions have LEPs on noise exposure, and several have programs on powered industrial trucks. In addition, a number of emphasis programs mention heat-related hazards. OSHA inspectors may look for these hazards while visiting your facility even if the emphasis program doesn’t mention specific industries.

Safety, not just citations

OSHA chooses to focus on particular areas for several reasons. First, inspectors regularly encounter those violations, which tells the agency that many employers could be doing better. In fact, when launching a new emphasis program, OSHA usually begins with a few months of outreach to increase employer awareness.

Second, the selected focus areas usually have the potential for serious or even fatal injuries. As every safety professional knows, risk is a function of both probability and severity. If OSHA inspectors frequently encounter similar violations with a high severity potential, the agency has identified a high-risk problem that employers must address.

Every OSHA inspector’s job is to identify violations, and those usually result in citations and penalties. The agency issues citations and penalties to encourage employers to identify and correct hazards before a tragedy happens. The emphasis programs focus on areas or industries where OSHA frequently finds violations. If many other employers fall short in those areas, chances are that your facility has room for improvement also. Finding and fixing those hazards before an OSHA inspector arrives not only reduces your risk of facing a citation, it keeps your employees safer.