OSHA is still fulfilling its mission promoting worker and workplace safety. Safety, Amputations, and Planned Inspections led the OSHA inspection categories for NAICS 332721 so far this year.
At PMPA we take a look twice a week at the OSHA inspections posted online for our industry. In the event that one of our members is on that list, we call immediately to offer our assistance. If it is a non-member, we look to learn what vulnerabilities are being encountered in the industry shops not belonging to PMPA.
Here’s what we found out.
So far this year, OSHA has posted notices of 53  inspections for our NAICS code- 332721 online. 53!

Chart of OSHA inspections frequency for 2018 NAICS 332721 Precision Machining Shops

 
The single largest category were for “Safety” – 15 of 53, 28% of all inspections posted.
Go figure.
The second most frequent category was “Amputations“-12 of 53, 23%.
This really is aggravating. There is no excuse for anyone to be losing body parts. We need to contact our people immediately to review the basics about pinchpoints, rotating equipment, and the pointlessness of trying to stop a lathe with our fingers or thumb. 
I won’t display the photos but if you want to see what a drill can do to a human hand click this link:  Graphic Image
Programmed (planned ) Inspections were third  with 7 of 53 or 13%. Routine enforcement is still a “real thing” at OSHA.
Complaints  came in at fourth  with 4 out of 53 inspections being initiated as a result of a complaint- 8% of inspections due to complaints..
Health tied with Complaints at 4 inspections out of 53- 8% of inspections due to occupational health concerns
Rounding out the ten causes were Noise, Reinspections, Accidents, Referrals, and Inspections.
Reasons cited for OSHA Inspections for NAICS 332721 (frequency) Calendar year 2018 YTD

 
OSHA is still fulfilling its mission promoting worker and workplace safety. The above reasons show how your peers are being examined. Are you ready for an OSHA inspection?
Photocredit: Mystalk
Data and Chart Preparation credit Veronica Hopson, PMPA
Original Data sourced from USDOL OSHA.

The U.S. Department of Labor’s Occupational Safety and Health Administration today announced that it is withdrawing its proposed interpretation titled “Interpretation of OSHA’s Provisions for Feasible Administrative or Engineering Controls of Occupational Noise.”  The interpretation would have clarified the term “feasible administrative or engineering controls” as used in OSHA’s noise standard.  The proposed interpretation was published in the Federal Register on Oct. 19, 2010.
PMPA alerted the industry  and other metalworking associations to this proposed reinterpretation when it was first published in the Federal Register. We wrote requesting an extension for comments and fact finding. We have been gathering data to establish the cost burden of the proposal on the small manufacturing businesses that we serve.
Thanks to all who joined with PMPA, our members who commented, and other metalworking associations who also commented and made their concerns known.
As a result of effective associating, this ill-conceived proposal has been withdrawn.
You can read the OSHA Announcement here.
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Summary: A change in the interpretation of  the word ‘FEASIBLE’ by OSHA could cause all shop owners whose shops noise level exceeds 85 dB to be REQUIRED by OSHA under this new definition to install expensive engineering or administrative controls to abate the noise  to levels below the action level. PPE could no longer be acceptable as the sole means of addressing noise exposure in our shops.
Action You Need to Take:
1)      Determine the noise level in your shop to see if it exceeds 85dB TWA.
2)      Determine cost to install noise guarding on machines necessary to abate noise levels to below 85dB (engineering control)
3)      Determine how many machines must be taken out of service at a time to prevent the noise level from exceeding the 85dB level ( administrative control )
4)      Perform a business case analysis to see if your company can remain in business if this change to the definition becomes law, requiring you to purchase sound dampening or reduce production.
5)      Document the cost to comply, loss of jobs, and any reduction in competitiveness, capacity or other issue that is a result.
6)      Send to Miles Free  gro.apmp@eerfm so that I can include in PMPA’s formal comments.
7)      Send a letter to the Docket for comments on this proposed change in interpretation as well as one to your congressman and please copy PMPA.
Submit comments at http://www.regulations.gov. Individuals who mail or deliver comments must submit three copies to the OSHA Docket Office, Docket No. OSHA-2010-0032, U.S. Department of Labor, Room N-2625, 200 Constitution Ave., N.W., Washington, D.C. 20210. Submissions not longer than 10 pages may be faxed to 202-693-1648 
Don’t delay.
PMPA and other metalworking associations requested, and received an extension on the Comments deadline so that we could obtain facts needed to properly assess the consequences of this new interpretation. Comments are now due by March 21, 2011. We need your facts to make our case!
 We need your data now to effectively represent you on this potentially shop closing issue.
 All data that we have seen from Member shops so far has shown that these shops will need to add sound dampening equipment.
Links: Extension letter:
Notice of Proposed Reinterpretation:
PMPA Extension Request Letter:
The shop (and machininst jobs) you save may be your own.
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