With a new National Emphasis Program (NEP) targeting the primary metals industry (dealing with the extraction of metals from rock) OSHA is addressing issues uncovered from the Bureau of Labor Statistics Census of Fatal Occupational Injuries. The census showed worker exposure to hazardous materials and working conditions such as excessive noise and heat.
OSHA announced the new NEP yesterday, with OSHA’s assistant secretary, Dr. David Michaels, saying, "OSHA's new enforcement program will raise awareness of the dangers of exposure to metals and other chemicals, so that employers can correct hazards and comply with OSHA standards."
A primary concern is that employees are not properly protected and are overexposed. According to the NEP, primary metal industries accounted for 26% of the establishments having at least one worker with highly elevated blood lead levels.
More specifically, OSHA is focused on the following areas for the primary metals NEP:
a. Respiratory Protection
b. Personal Protective Equipment Safety
c. Noise and Hearing Conservation
d. Heat Stress Safety
e. Silica Hazards
f. Hazard Communication Standard
g. Lead Safety
The NEP will mean increased inspections for primary metal establishments. And while the NEP states inspections are to be mostly limited to evaluating worker exposure to physical and chemical hazards, the NEP does say that Compliance Safety and Health Officers (CSHOs) “may expand the scope of the inspection if other safety and health hazards or violations are observed and/or brought to their attention.”
Furthermore, the NEP specifically instructs CSHOs to check MSDSs, employee access to MSDSs and review injury and Illness records. Based on this, primary metal industry would be wise to get out in front of HazCom Standard violations, which is one of the most visible and frequent violations OSHA cites each year across all industries.
Additionally, many (if not most) inspections result from worker complaints; so employee outreach, making sure employee concerns are heard and addressed, is another good idea.