Machine Guarding Real Focus of Renewed OSHA Emphasis Program
OSHA has updated and renewed its National Emphasis Program on amputations in manufacturing facilities.
OSHA has updated and renewed its National Emphasis Program on amputations in manufacturing facilities. With this emphasis, OSHA will be targeting manufacturers and industrial facilities, with a focus on machine guarding and lockout-tagout.
⚡ TL;DR: OSHA is targeting ~130 NAICS codes for machine guarding and LOTO inspections starting March 2020. Facilities with higher violation or amputation rates in 2015–2018 are on the list. OSHA inspectors will review 4 years of logs, examine machinery for pinch points and shear hazards, and verify LOTO procedures. Companies with 10+ employees in targeted industries should prepare now.
Who’s On the List?
Machine guarding and lockout-tagout are annual residents on OSHA’s top 10 list of violations and cause amputations and injuries each year. OSHA has had amputations on its national emphasis since before 2015, but they’ve updated it with a new list of potential NAICS codes to target based on data from 2015 to 2018.
OSHA is going to target industries with higher rates of machine guarding and lockout-tagout violations, higher rates of related incidents, higher rates of amputations, those with amputations within the past 5 years, and those with machine-related injuries or fatalities. They’ve developed a target list of around 130 targeted NAICS codes. Companies with less than 10 employees will not be on the target list, even if their NAICS code matches.
⚠️ Why this matters: If your facility is in a targeted NAICS code, inspections starting March 2020 will prioritize machine guarding and LOTO. OSHA will review your entire injury log history (4 years), inspect every machine for hazards, and examine your LOTO procedures in detail. A single machine guarding violation carries serious penalties—and amputations trigger willful violation classifications, which can exceed $140K per violation. The time to prepare is now, not March.
Please remember that as with all OSHA emphasis programs, if OSHA is onsite for another inspection, they can add this to their scope.
Is your facility in a targeted NAICS code? A machine guarding and LOTO audit before the emphasis program begins can identify and fix gaps before OSHA walks in.
What Will Be Looked At?
In addition to reviewing 4 years of OSHA logs, they will be inspecting your machinery and equipment, looking for hazard potentials in:
Pinch, Nip and Shear Points Cutting Actions Setup and Operation Clearing Jams or Upsets Making Adjustments When Operating Cleaning/Greasing/Oiling Scheduled and Unscheduled Maintenance During the Lockout-Tagout Process
Machine guarding is used to protect both the operator and everyone else who could come in contact with a machine. Any machine, part, function or process that can cause injury must be safeguarded. The best way to ensure you are ready for an inspection is to make sure you’re compliant with the following standards. These will be the ones used by inspectors as they’re the ones that have the greater potential to cause amputations:
1910 Subpart J – General Environmental Controls 1910.147 Control of Hazardous Energy (Lockout-Tagout)
1910 Subpart O – Machine and Machine Guarding 1910.212 General Requirements 1910.213 Woodworking Machinery Requirements 1910.217 Mechanical Power Presses 1910.219 Mechanical Power Transmission
Inspection Start Date
As with all new and revised emphasis programs, there will be a 90-day period where OSHA will provide outreach efforts to alert the industry about the changes before starting targeted inspections. This puts targeted inspections starting around March 10, 2020.
More Information
For more information, check out the OSHA inspector directive here, which also includes the affected list of NAICS codes.
Frequently Asked Questions
Q: What is OSHA’s National Emphasis Program on amputations and who is targeted?
OSHA’s National Emphasis Program targets manufacturers and industrial facilities with higher rates of machine guarding and lockout-tagout violations, higher incident and amputation rates, or previous amputations within the past five years. OSHA selected approximately 130 targeted NAICS codes based on 2015-2018 injury data, though companies with fewer than 10 employees are exempt from the targeting list.
Q: What specific machinery hazards does OSHA focus on during machine guarding inspections?
OSHA inspectors evaluate machinery for hazards in pinch points, nip and shear points, cutting actions, setup and operation procedures, jam clearing processes, adjustments made while operating, cleaning and greasing operations, and maintenance activities. These areas represent the highest amputation risks and are inspected under 1910 Subpart O (Machine Guarding) and 1910.147 (Lockout-Tagout) standards.
Q: What machine guarding standards do manufacturers need to comply with?
Manufacturers must comply with 1910.212 (General Machine Requirements), 1910.213 (Woodworking Machinery), 1910.217 (Mechanical Power Presses), and 1910.219 (Power Transmission). These standards require physical guards, interlocked safety devices, and administrative controls to prevent worker contact with hazardous machine parts and functions.
Q: What is the timeline for OSHA’s machine guarding emphasis program enforcement?
OSHA provides a 90-day outreach period before targeted inspections begin under the National Emphasis Program, allowing facilities time to become aware of the initiative and make necessary corrections. After the outreach period, OSHA begins targeted inspections at facilities matching the affected NAICS codes.
💰 Cost of machine guarding violations: Serious OSHA citations for inadequate guarding: $15K–$50K per violation. Willful machine guarding violations (leading to amputation): $100K–$140K+. A comprehensive machine guarding audit before the emphasis period typically costs $3K–$10K and prevents both.
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