OSHA's 2025 Amputations NEP (CPL 03-00-027): What Changed From the 2019 Program

OSHA's directive CPL 03-00-027, signed May 29, 2025 and effective June 27, 2025, supersedes CPL 03-00-022 of December 10, 2019 as the National Emphasis Program on Amputations in Manufacturing Industries. OSHA lists six significant changes: a 24-month deletion rule for recently inspected establishments with no amputations, expansion of unprogrammed inspections only for NAICS codes in Appendix B, no NEP inspection for establishments with 10 or fewer employees in low-hazard industries, new OIS coding instructions, a revised targeting methodology, and an updated list of 91 NAICS codes based on 2019 to 2023 data.

The six significant changes at a glance

Who is in and who is out: the deletion and exemption rules

Section X.C sets out the deletions an Area Office applies to its master list. It shall delete establishments with 10 or fewer employees whose primary NAICS code is on the Low-Hazard Industry Table. It may delete, based on local knowledge, establishments unlikely to have machinery that could cause amputations and those known to be out of business, documenting why. And it may delete establishments with an NEP inspection initiated in the previous 24 months and no reported amputations in those 24 months.

Note the difference in wording. The small-employer rule is mandatory for the Area Office; the 24-month rule is discretionary. The base does not contain the Low-Hazard Industry Table itself, which sits in the Appropriations Act directive (CPL 02-00-170 of July 18, 2024, or successor guidance), so check that document for your code. VPP worksites remain exempt for the duration of their approved participation.

Unprogrammed inspections: the Appendix B condition

Unprogrammed inspections are those triggered by complaints, referrals or fatalities and catastrophes (FAT/CAT). Under the 2025 directive, the Area Director may expand such an inspection into an Amputations NEP inspection only if the NAICS code is listed in Appendix B and the establishment is not exempt under the Appropriations Act. For a manufacturer outside the list, a complaint about a single machine therefore stays a complaint inspection for NEP purposes.

How the new NAICS list was built

Appendix A describes a three-category method applied to manufacturing (NAICS 31-33):

1. Category 1, high OIS inspection numbers: five standards linked to amputations (1910.147, 1910.212, 1910.213, 1910.217, 1910.219); codes with 40 or more federal OSHA inspections with at least one violation of those standards in 2019-2023. Result: 66 five-digit codes.
2. Category 2, high BLS amputation numbers: codes with 50 or more amputations per year in BLS data for 2019-2022. Result: 39 five-digit codes.
3. Category 3, employer-reported amputations: codes with 25 or more reported amputations per year in OIS referrals for 2019-2023; 25 was used instead of 50 because OIS data are federal-plan only, roughly half the BLS data. Result: 78 five-digit codes.

The 183 codes found across the three categories reduced to 67 unique five-digit codes, expanded to 178 six-digit codes. OSHA then removed 87 six-digit codes that did not appear to present a high risk, looking at BLS incidence rates, amputation-related injuries or violations, the number of AMPUTATE-coded inspections, the type of work and the likely presence of amputation-capable machinery. That leaves 91 six-digit codes (178 − 87 = 91) in Appendix B.

Industries added in 2025

Codes marked with an asterisk were not in the 2019 NEP. Examples from Appendix B include soybean and oilseed processing (311224), beet and cane sugar (311313, 311314), soft drinks and bottled water (312111, 312112), iron and steel foundries (331511, 331513), aluminum foundries (331524), spring manufacturing (332613), electroplating and anodizing (332813), farm machinery (333111), automobile and light truck manufacturing (336111, 336112), ship building and repairing (336611) and boat building (336612). The directive also notes that some codes covered in 2019 are no longer included, without listing them in the base's copy.

Long-standing metalworking codes such as 332710 Machine Shops, 332721, 333514 and 333517 carry no asterisk: they were covered in 2019 and remain covered. To check a specific code, the OSHA machine guarding knowledge base searches Appendix B for you.

Outreach, State Plans and expiration

• 90-day outreach: each Regional and Area Office must run a 90-day outreach program focused on industries not targeted in 2019, before compliance inspections begin for them.
• State Plans: must submit a notice of intent within 60 days of notification and should complete adoption within six months; their policies must be at least as effective as the federal ones.
• Expiration: the directive terminates five years from its effective date, so in June 2030 (June 27, 2025 + 5 years) unless replaced.
• Data years: OIS data for 2019-2023 and BLS data for 2019-2022; BLS now aggregates some case data over two-year periods starting with 2021-2022.

How Area Offices schedule NEP inspections

Section X describes the mechanics. OSHA's Office of Statistical Analysis gives each Area Office software and a database of establishments in the covered NAICS codes; only federal OSHA and State Plans have access. The resulting master list can be worked in one of two ways:

1. Whole list: inspections in any order that uses resources effectively, accounting for every establishment through inspections or deletions; a new list cannot be started until the previous one is complete.
2. Random order: establishments taken in the random number order provided, in cycles of a set size, without needing to finish the list.

Area Offices may also add, based on local evidence such as OIS incident data, employer-reported amputations or workers' compensation data, manufacturing establishments in targeted NAICS codes where machinery-related amputations or fatalities occurred in the five years before the effective date, provided they have not had an NEP inspection in the previous 24 months. The list is then re-randomized.

What did not change: the inspection itself

The way an NEP inspection is conducted is described in Section XI. Inspections are programmed, planned, partial safety inspections covering operation, servicing, maintenance, hazardous energy control and machine guarding of equipment that can cause amputations. At the opening conference the CSHO collects OSHA 300, 300A and 301 records for the current and previous three calendar years and requests the energy control program and training records. On the walkaround, the CSHO examines nip, pinch and shear points, cutting hazards and points of operation, during setup, jam clearing, adjustments, cleaning, lubrication and maintenance. Because the base does not hold the 2019 text, it cannot confirm whether any of these procedures were reworded.

What compliance managers should do now

1. Check whether your primary NAICS code is in Appendix B, and whether it carries an asterisk (newly targeted).
2. If you have 10 or fewer employees, check the Low-Hazard Industry Table in the current Appropriations Act directive.
3. If you had an NEP inspection in the last 24 months with no amputations since, keep that record; deletion is possible but not automatic.
4. Prepare the four years of injury records and the lockout/tagout program the CSHO will request.
5. Review guarding against the five standards OSHA used for targeting.

The source document is CPL 03-00-027 on osha.gov. The machine guarding base pairs it with the Subpart O standards, so you can go from "Am I targeted?" to "What does 1910.212 require on my lathes?" in one place.