By Amanda R. Strainis-Walker
OSHA recently launched a Regional Emphasis Program (REP) that will focus enforcement resources on employers operating in the automotive supply manufacturing industry. This new Auto Supply Manufacturers enforcement program will target manufacturers in the southeast that supply engines, airbags, trim, or any other automotive products. The specific geographic areas covered by the inspection program include at least Georgia, Mississippi, and Alabama.
“Hazards associated with the Auto Parts Supplier Industry that are the focus of this REP continue to be the source of serious injuries, including amputations, and deaths to employees,” OSHA explained in the REP. “The objective of this REP is to reduce employee exposures to safety related hazards in the Automotive Parts Supplier Industry.”
As a result of the REP, most automotive supply manufactures located in the Southeast can expect a comprehensive, wall-to-wall OSHA inspection within the next two years. The only way these automotive supply manufacturers can avoid such an inspection is if they were already the subject of a comprehensive OSHA inspection during the preceding two years, or if they were mistakenly identified as an automotive supply manufacturer under NAICS classification code – 3663XX.
OSHA Area Offices have started to send letters notifying automotive supply manufacturers about the REP, as well as common causes of occupational injuries in the industry—machine guarding, lockout/tagout (LOTO), and electrical hazards. These topics will also be the primary focus of inspections under the enforcement program. The automotive supply manufacturers receiving the letter will be at the beginning of the inspection cycle, and should take steps now to prepare for OSHA’s knock on the door.
Recommended Steps to Prepare:
- Ensure injury and illness recordkeeping forms are current, accurate, and ready to produce to OSHA.
- Review written programs to confirm they are up-to-date, compliant, and consistent with what is happening on the plant floor. Focus on LO/TO, including the requirement to conduct annual LO/TO certifications.
- Certify employee training is current, and fill in any gaps as needed.
- Conduct regular walkthrough inspections to affirm employees are following company policies and training.
- Consider having a third-party safety audit conduct conducted, preferably under the protection of the attorney-client privilege.
Here is a copy of the Auto Parts Industry Emphasis Program directive. Please contact us with questions about this new emphasis program.