For Machine Shop Supervisors: Preparing for an OSHA Amputations NEP Inspection

Yes, machine shops are targeted: NAICS 332710, Machine Shops, is listed in Appendix B of OSHA's National Emphasis Program on Amputations in Manufacturing Industries, CPL 03-00-027, effective June 27, 2025. An inspection under this program is a programmed, planned, partial safety inspection that covers all locations and practices involving the operation, servicing, maintenance, hazardous energy control and machine guarding of equipment that can amputate. At the opening conference, the compliance officer (CSHO) should collect your OSHA 300, 300A and 301 records for the current and previous three calendar years and request your energy control program, procedures and training records.

Is your shop on the list?

Appendix B of CPL 03-00-027 lists 91 six-digit NAICS codes. For metalworking shops the relevant entries include 332710 Machine Shops, 332721 Precision turned product manufacturing, 332722 Bolt, nut, screw, rivet, and washer manufacturing, 333514 Special die and tool, die set, jig, and fixture manufacturing, 333515 Cutting tool and machine tool accessory manufacturing, 333517 Machine tool manufacturing and 332119 Metal crown, closure, and other metal stamping (except automotive). None of these carries an asterisk, which the directive uses to mark industries that were not in the 2019 program, so they were already targeted before 2025.

How establishments are chosen matters for planning. OSHA's statistical office gives each Area Office a database of establishments in the covered NAICS codes; the resulting master list is used either in full or in random number order, in cycles. Area Offices may also add manufacturing establishments in covered codes where amputation injuries or fatalities related to machinery occurred in the five years before the effective date, then re-randomize the list. In other words, being in a covered code puts you in the pool; it does not tell you when or whether you will be visited.

Who should not be inspected under the NEP

• Establishments with 10 or fewer employees whose primary NAICS code is on the Low-Hazard Industry Table of the Appropriations Act directive. The base does not contain that table, so check the current Appropriations Act directive (CPL 02-00-170 or its successor) before assuming you qualify.
• Establishments whose NAICS code is not in Appendix B.
• Establishments in a listed code where the CSHO finds no machinery, equipment or process presenting amputation hazards.
• Participating VPP worksites, for the duration of their approved participation.
• Establishments that had an inspection initiated under this NEP in the previous 24 months with no reported amputations in those 24 months may be deleted from the programmed list (it is discretionary).

The opening conference: what the CSHO will ask for

Section XI.B of the directive describes the opening conference. The CSHO should verify the site's NAICS code and number of employees to confirm you are not exempt under the Appropriations Act, and verify with you whether any machinery, equipment or work processes that could result in amputations are present. Have the following ready:

1. OSHA 300 logs, 300A summaries and 301 incident reports for the current and previous three calendar years; the CSHO reviews them to identify injuries associated with amputation hazards.
2. Your energy control (lockout/tagout) program and procedures.
3. Training records.
4. Other documents related to the scope of the inspection. For mechanical power presses, that includes the inspection and maintenance certification records required by 1910.217(e).

The scope can widen. The directive allows expansion where there is evidence, such as injuries recorded on both the 300 and 301 forms, an employee statement or a plain-view observation, that violations may be found in other areas of the establishment.

The walkaround: where amputation hazards are examined

During the walkaround (Section XI.C), the CSHO pays particular attention to employee exposure to nip points, pinch points, shear points, cutting hazards and other points of operation. Exposures are evaluated across the whole life of the machine, not just production:

• setup and regular operation;
• clearing jams or upset conditions;
• making adjustments while the machine is operating;
• cleaning, oiling or greasing;
• scheduled and unscheduled maintenance and servicing;
• activities related to the control of hazardous energy.

The CSHO uses employee interviews and may evaluate exposures across multiple shifts. CSHOs on these inspections are expected to know general and specific machine guarding as well as lockout/tagout requirements. The standards OSHA associates with amputation hazards, and used to select the targeted industries, are 1910.147, 1910.212, 1910.213, 1910.217 and 1910.219. If you want to check how a particular machine maps to those standards, the machine guarding base answers with the paragraph concerned.

Machine-by-machine preparation for a typical shop

Training your people will be asked about

Because the CSHO interviews employees, training shows up in their answers as much as in your files. For presses, 1910.217(f)(2) requires the employer to train and instruct the operator in the safe method of work before starting work on any covered operation and to ensure, through adequate supervision, that correct procedures are followed. Under (e)(3), the employer must also ensure the original and continuing competence of the people who inspect and maintain presses.

OSHA's Machine Guarding eTool describes what thorough operator training covers:

• the hazards of the particular machine;
• the safeguards, how they protect and against which hazards;
• how to use the safeguards and why;
• how, when and by whom safeguards can be removed (in most cases, repair or maintenance personnel only);
• when lockout/tagout is required;
• what to do, for example contact the supervisor, if a safeguard is damaged, missing or not protecting adequately.

The eTool says this training is needed for new operators, maintenance and setup staff, when new or altered safeguards are put into service, and when workers move to a new machine or operation.

Ninety-day preparation checklist

1. Confirm your primary NAICS code and headcount; check whether the Low-Hazard Industry Table applies.
2. Pull the last four calendar years of 300, 300A and 301 records and look for amputation-related entries.
3. Walk every machine during setup, jam clearing and cleaning, not only during production.
4. Verify lathes, drill presses, mills and grinders against 1910.212 and 1910.215.
5. Check all power-transmission parts within 7 feet of the floor are enclosed.
6. Review the lockout/tagout program, machine-specific procedures and training records.
7. For presses, assemble 1910.217(e) inspection and maintenance records.
8. Brief supervisors and operators: the CSHO will interview them.

Penalty amounts are not part of this base, so it will not estimate fines. For guarding questions, the OSHA machine guarding knowledge base answers questions like "Is a general machine shop (NAICS 332710) one of the industries targeted by OSHA's 2025 Amputations NEP?" with the directive's own wording. The full directive is published by OSHA as CPL 03-00-027; it terminates five years from its effective date.