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January 20, 2016
Federal OSHA issues new NEP on amputations

Nearly 5,000 American workers suffered job-related amputations in 2014, according to the U.S. Bureau of Labor Statistics. Partial or total amputations of fingers are the most common job-related amputations, but workers also lose hands, feet, arms, and legs at a disturbing pace.

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Amputations have long been a source of concern for federal OSHA, which first issued a National Emphasis Program (NEP) on amputations in 2006. In late 2015, the agency updated its amputations NEP, and state plan states like California that have their own job safety and health programs will be required to follow suit.

Causes of amputations

An amputation is the “traumatic loss of limb or other external body part,” according to OSHA. Completely or partially severed body parts are considered “amputated.” At work, amputations can result from a variety of causes, including crushing incidents, falls that break bones badly, and motor vehicle accidents.

By far the most common cause of amputations in the workplace, however, is machinery hazards. These hazards—employee exposures to unguarded or inadequately guarded machinery and equipment, together with associated hazardous energy exposures during servicing and maintenance activities—are the focus of OSHA’s updated NEP.

Targeted employers

The NEP targets general industry establishments in 80 NAICS (North American Industry Classification System) codes, primarily in manufacturing and agriculture, where amputation injuries or fatalities related to machinery and equipment have occurred within the past 5 years. Employers that have had 10 or fewer employees at all times during the previous 12 months and worksites that are enrolled in a voluntary protection program (VPP) are excluded.

Inspection procedures

During the inspection, a compliance officer will review your Log 300 and 301 forms for the most recent 3 years, looking for amputation incidents. The compliance officer will also look for the presence of specific machinery and equipment that could cause amputations. (You can find a list in Appendix A of the NEP, as well as the list of covered NAICS codes, at http://1.usa.gov/1QO6P4b.)

If your workplace has any of the specified types of machinery and equipment associated with amputations, the compliance officer will focus on those. The officer will look for employee exposure to nip points, pinch points, shear points, cutting actions, and other points of operation.

The compliance officer will evaluate the possibility that workers could be exposed to amputation hazards during:

  • Regular machine operation
  • Setup, threading, or preparation for regular operation of the machine
  • Clearing jams or upset conditions
  • The making of running adjustments while the machine is operating
  • Cleaning of the machine
  • Oiling or greasing of the machine or machine pans
  • Scheduled or unscheduled maintenance activities
  • Lockout/tagout operations

Practice Tip

In workplaces covered by federal OSHA, inspectors will also look for compliance with OSHA’s new amputation reporting requirements.

Spot check

To address concerns about machinery safety and amputation prevention, you’ll need to look at two compliance areas that work in tandem: machine guarding and lockout/tagout.

Machine guarding prevents amputations by putting a barrier between workers’ bodies and the hazardous areas of machinery. It can do this by:

  • Preventing operation if a hand or body part is placed in the danger area;
  • Restraining or withdrawing the hands from the danger area during operation;
  • Requiring use of both hands on machine controls or the use of one hand if the control is mounted a safe distance from the danger area; and
  • Providing a barrier that is synchronized with the operation cycle to prevent entry to the danger area.

Lockout/tagout prevents amputations by ensuring that machinery cannot move or cycle while workers are in a danger zone. Your lockout/tagout program should include written procedures that cover, for each piece of equipment:

  • Its energy sources
  • Steps to shut it down and secure it
  • How to verify lockout
  • How to apply locks
  • How to restart it
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