OSHA Renews Their National Emphasis Program (NEP) on Amputations

By Phil Molé, MPH

OSHA has recently revised and renewed it’s NEP on amputations in the manufacturing sector. In fact, OSHA’s latest Amputation NEP is now in effect and actively being used to target inspections. If you’re in an industry sector targeted under OSHA amputations NEP, you’ll need to make sure you’re prepared for a potential inspection and that you’re doing everything you can to prevent amputation injuries and other serious workplace accidents.

In what follows, we’ll explain the background of the OSHA amputations NEP, what facilities OSHA will be targeting, what they’ll specifically be looking at during inspections, and key takeaways about the NEP that EHS professionals need to know.

What’s the Background of OSHA’s NEP on Amputations?

OSHA issued the original version of its NEP on Amputations (CPL 03-00-022) on December 10, 2019. Throughout its history, OSHA has continued to review industry data on occupational injuries and illnesses to identify patterns of serious incidents such as hospitalizations and fatalities and has prioritized regulatory and enforcement to address those patterns.

OSHA’s enforcement history shows that employees performing service and maintenance on machinery or equipment most often suffer amputation injuries when no machine guarding is present and/or energy control procedures are not implemented and followed. They developed the NEP to target industrial and manufacturing workplaces with machinery and equipment that can potentially cause amputations.

OSHA’s NEPs are typically time-bound and while they are in effect, OSHA continues to collect and assess data to help determine whether to renew and revise the NEP, and to help focus inspection and enforcement priorities. During their most recent review OSHA analyzed OSHA Information System (OIS) data for calendar years 2019-2023 and Bureau of Labor Statistics (BLS) data for calendar years 2019-2022 to identify high-risk industries for targeting under the NEP, and their analysis supported renewal.

As OSHA states, “OSHA’s enforcement history shows that employees are often injured when machinery or equipment is not properly guarded or safely maintained, or when hazardous energy is not controlled,” the NEP directive states. This NEP targets industrial and manufacturing workplaces having machinery and equipment that can potentially cause amputations.”

What’s Changed with OSHA’s NEP on Amputations?

Based on its review of OIS and BLS data, OSHA revised the NEP and reissued it on May 29, 2025 with a new directive number (CPL 03-00-027).

The newly revised NEP on amputations includes the following provisions:

• Any establishment that had an inspection initiated under the NEP in the previous 24 months, with no reported amputations within those 24 months, may be deleted from the programmed inspection list.

• Enforcement officers may expand unprogrammed inspections to an Amputations NEP inspection, but only if the NAICS code is listed in Appendix B of the NEP.

• Any establishment with 10 or fewer employees and that has their primary NAICS code listed on the “Low-Hazard Industry Table” of the Appropriations Act Directive should not be inspected under the NEP.

• Revises the OSHA Information Systems (OIS) coding instructions in Section XII for all OSHA amputation inspections.

• Revises the industry targeting methodology in Appendix A – Amputations Targeting Methodology.

• Updates Appendix B – Covered NAICS Codes, to reflect the revisions to Appendix A as well as data from 2019-2023.

Which Worksites Will OSHA Target Under the Revised NEP on Amputations?

The NEP states that local OSHA enforcement offices will use two criteria for selecting which facilities to inspect. These criteria are:

OSHA Information System (OIS) Inspection Data

OSHA selected five standards (29 CFR § 1910.147, 1910.212, 1910.213, 1910.217, and 1910.219) which the agency recognized as being relevant to amputation hazards. The agency then used OIS data for calendar years 2019-2023 and identified NAICS codes (within the two-digit NAICS range for manufacturing sectors) that had 40 or more federal OSHA inspections with one or more violations of at least one of the standards listed. This process resulted in 66 five-digit NAICS codes to be covered under the NEP.

Selection of Industries with High Bureau of Labor Statistics (BLS) Amputation Numbers

OSHA reviewed BLS Data for calendar years 2019-2022 on numbers of amputations across industry sectors and selected manufacturing NAICS codes (beginning 31-33) covering which had 50 or more amputations per year for that period. This process added 39 NAICS codes to the list covered by the NEP.

Exemptions from Coverage Applicability for OSHA’s NEP on Amputations

According to the NEP, regional enforcement offices will delete establishments with 10 or fewer employees that have their primary NAICS code listed on the “Low-Hazard Industry Table” of the Appropriations Act Directive from their master list of facilities to potentially inspect. The regional office may also delete establishments they find to be unlikely to have machinery and equipment that could cause amputations, and establishments known to be out of business, and will document the basis for such determinations.

What Will OSHA Enforcement Officers Review While Conducting Inspections?

The NEP describes a general procedure that OSHA compliance safety & health officer (CSHOs) will follow while conducting inspections under the NEP, consisting of the following elements:

• An opening conference, in which the CSHO will verify the site’s NAICS code and number of employees to verify that the employer is covered by the NEP and verify that specific types of machinery with a potential to cause amputations are in the workplace.

• A review of copies of OSHA Recordkeeping forms (300, 300A and 301) for the current year, as well for the previous 3 years, and review the records for evidence of amputation hazards.

• A review of relevant records for machinery present on site, including hazardous energy control procedures (i.e. lockout/tagout) and machine guarding plans.

• A walkaround of the site, in which the CSHO will evaluate employee exposure to nip points, pinch points, shear points, cutting hazards, and other points of operation. According to the NEP, the CSHO will “consider and evaluate all employee exposures to amputation hazards during setup, regular operation of the machine, clearing jams or upset conditions, making adjustments while the machine is operating, cleaning of the machine, oiling or greasing of the machine or machine parts, scheduled/unscheduled maintenance and/or servicing, and activities related to the control of hazardous energy.”

• Depending on the nature of how work is organized at the site, the CSHO may expand the time spent on-site. For example, if the CSHO learns that the site has multiple shifts or is a multiple employer worksite, she/may decide that it’s necessary to observe work across different shifts or under different employer supervision.

CSHOs will typically conduct a closing interview following the walk-through, indicating at least high-level findings and observations from their inspection. The local enforcement office will follow up with a letter to the site describing violations found, if any, or observations for potential safety improvement opportunities.

How Long will OSHA’s NEP on Amputations Be in Place?

The revised NEP went into effect on June 27, 2025, and according to Section VII of the NEP, it will expire five years from the effective date, on June 27, 2030.

We can assume that during the next roughly five years, OSHA will be assessing data to determine whether they will renew and potentially revise the NEP.

What are the Major Takeaways on OSHA’s NEP on Amputations?

If you’re in a manufacturing industry sector targeted under OSHA’s revised NEP on amputations, your worksite now has an increased potential for inspections and/or records requests. Here are some key takeaways for EHS professionals potentially affected by OSHA’s revised NEP on amputations.

Maintain Good Occupational Injury and Illness Records

OSHA CSHOs will most certainly ask for copies of OSHA Forms 300, 300A and 301 when they arrive on site. They’ll be reviewing those records for evidence of amputation injuries and hazards, but it’s safe to say that any perceived deficiencies or gaps in the records will likely prolong the CSHO’s presence on site, or potentially even lead to an expanded investigation scope.

Accurate, accessible injury and illness records aren’t just critical to regulatory compliance, either – they’re also critical for effective safety management, in general. The reason OSHA requires employers covered under the Recordkeeping Standard to maintain injury and illness records is that they realize that employers need to have details about what happened, how it happened, and why it happened to be able to prevent workers from getting hurt.

Now’s a great time to make sure there are no gaps in your injury and illness recordkeeping practices. You need fast and efficient ways to conduct and document incident investigations, and to be able to generate and maintain accurate copies of OSHA Forms 300, 300A and 301. Mobile incident management software is a great way to ensure you and your team can conduct incident investigations without delay and even attach documentation like photographs and videos to the incident report.

Identify Risks with Potential to Cause Serious Injuries and Fatalities (PSIF)

Having accurate and thorough incident records, as described above, is a critical part of safety management. Doing so plays directly into the ability to use those records to make meaningful safety management improvements.

Amputations are among the most severe injury types, which is why OSHA’s Recordkeeping Standard requires employers to report any workplace incidents involving an amputation (as well as any incidents involving eye loss or hospitalization) to OSHA within 24 hours. OSHA’s focus on preventing fatalities and severe injuries is the reason why OSHA is prioritizing inspections to identify amputation risks in the revised NEP. As an EHS professional, you should also prioritize identification and control of the most severe risks in your workplace, including risks of amputation injuries.

The challenge is that injury and illness data doesn’t always speak for itself. The larger and more complex your workplace is, and the more workplaces you have within your organization, the more difficult it is to focus your attention where it’s most needed and to quickly and effectively flag the biggest risks, especially those with the potential for severe injury or fatality (PSIF).

The best incident management software makes this easier with AI/ML capabilities that identify PSIF risks by scanning records for incidents (including near hits/close calls and assessing risk levels) to identify trends and point out priority hazards. If you are inspected by OSHA under this NEP, CSHOs will want to know what methods you use to find and control PSIF risks. Incident management software with AI/ML PSIF capabilities are a systematic way to demonstrate your due diligence and, more importantly, help you fulfill your primary duty as an EHS professional by keeping your people safe.

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Don’t wait for more serious accidents or an OSHA inspection to start improving your safety management program. Give us a call today or set up a meeting to see for yourself how our software can help you keep your workplace safe.