OSHA's 2025 Amputations NEP Update (CPL 03-00-027): What Changed Since the 2019 Programme

In 2025 OSHA issued CPL 03-00-027, signed on 29 May 2025 and effective from 27 June 2025, replacing CPL 03-00-022 of 10 December 2019. The directive lists six significant changes: sites with an NEP inspection in the previous 24 months and no amputations may be removed from the programmed list; complaint and referral inspections may be expanded into NEP inspections only for listed NAICS codes; employers with 10 or fewer employees in low-hazard industries should not be inspected under the NEP; OIS coding is revised; the targeting methodology is rewritten; and the industry list now has 91 NAICS codes based on 2019-2023 data.

Six changes in one table

The deletion rules in practice

Area Offices must remove establishments with 10 or fewer employees whose primary NAICS code is on the Low-Hazard Industry Table of the Appropriations Act directive. They may remove, on local knowledge, establishments unlikely to have amputation-capable machinery or known to be out of business, documenting the reason. And they may remove establishments inspected under the NEP within the last 24 months with no reported amputations in that period. Participants in OSHA's Voluntary Protection Programs are exempt while their participation lasts.

The Low-Hazard Industry Table itself is not part of the base: it belongs to the Appropriations Act directive (CPL 02-00-170, 18 July 2024, or successor guidance). For a small US subsidiary, check that table before concluding the site is outside the programme.

Expanded inspections now depend on the NAICS list

Complaints, referrals and fatality or catastrophe investigations are unprogrammed inspections. Under the 2025 text, the Area Director may expand one into an Amputations NEP inspection only where the site's NAICS code is in Appendix B and the site is not exempt under the Appropriations Act. Expansion follows the Field Operations Manual. For groups with mixed US operations, this makes the NAICS code of each site an important piece of information to hold centrally.

The new targeting method, step by step

1. Category 1: manufacturing codes with 40 or more federal OSHA inspections in 2019-2023 that found at least one violation of 1910.147, 1910.212, 1910.213, 1910.217 or 1910.219. Yield: 66 five-digit codes.
2. Category 2: codes with 50 or more amputations per year in Bureau of Labor Statistics data for 2019-2022. Yield: 39 codes.
3. Category 3: codes with 25 or more employer-reported amputations per year in 2019-2023; the lower threshold reflects that federal-plan OIS data represent roughly half of the BLS data. Yield: 78 codes.
4. Consolidation: 183 hits became 67 unique five-digit codes, expanded to 178 six-digit codes.
5. Review: 87 six-digit codes were removed as not presenting a high amputation risk, leaving 91 (178 − 87).

The review step looked at each code's BLS incidence rate compared with manufacturing as a whole, its history of amputation-related injuries or violations, the number of AMPUTATE-coded inspections from 2019 to 2023, the type of work and the likely presence of machinery that could cause amputations.

Newly listed industries

Asterisked codes in Appendix B were not in the 2019 programme. They include food and drink processes such as oilseed processing (311224), sugar (311313, 311314), frozen specialty foods (311412), fruit and vegetable canning (311421), soft drinks and bottled water (312111, 312112); metals such as secondary aluminium smelting and alloying (331314), iron and steel foundries (331511, 331512, 331513), die-casting (331523), springs (332613) and electroplating (332813); and vehicles and vessels such as farm machinery (333111), cars and light trucks (336111, 336112), ships (336611) and boats (336612). OSHA notes that some codes covered in 2019 have been dropped, but the base's copy does not list them.

Codes without an asterisk, such as 332710 Machine Shops, 332721 precision turned products or 333517 machine tool manufacturing, carried over from 2019. A quick way to check an individual code is to ask the OSHA machine guarding knowledge base, which reads Appendix B for you.

How sites are picked from the list

Being in a listed industry does not mean an inspection is imminent. OSHA's Office of Statistical Analysis provides each Area Office with a database of establishments in the covered codes, accessible only to federal OSHA and State Plans. The Area Office then either works through the whole master list, in any efficient order, and may not start a new list until the old one is finished, or takes establishments in the random number order supplied, in cycles, without having to finish the list.

Local evidence can add sites. Area Offices may add manufacturing establishments in targeted codes where machinery-related amputations or fatalities occurred in the five years before the effective date, using OIS incident data, employer-reported amputations or workers' compensation data, provided the site has not had an NEP inspection initiated in the previous 24 months. The master list is then re-randomised before use. For a UK group, the practical point is that an amputation reported at a US site can make that site more likely to be added to the list.

OSHA's stated reason for the programme

The directive's background section says that operating machinery or equipment can be extremely dangerous when it is not properly guarded or maintained, that injuries involving machinery often result in death or permanent disability, and that OSHA's enforcement history shows employees performing servicing and maintenance are often injured when no machine guarding is present or energy control procedures are not followed. That explains why inspections look well beyond production, at setup, jam clearing, cleaning and maintenance.

Outreach, State Plans and the five-year horizon

• Each Regional and Area Office must run a 90-day outreach programme aimed at newly targeted industries before compliance inspections start for them.
• State Plans must file a notice of intent within 60 days of notification and should adopt within six months, with policies at least as effective as the federal ones.
• The directive terminates five years from its effective date: on our arithmetic, June 2030 (27 June 2025 + 5 years), unless superseded earlier.

Action list for group HSE

1. List every US site with its primary NAICS code and headcount.
2. Mark which codes are in Appendix B, and which are newly added (asterisk).
3. For sites with 10 or fewer employees, check the Low-Hazard Industry Table.
4. Record the date and outcome of any previous NEP inspection (relevant to the 24-month rule).
5. Ensure each site can produce OSHA 300, 300A and 301 records for the current and previous three calendar years, its lockout/tagout programme and training records, which a CSHO requests at the opening conference.
6. Review guarding against the five targeting standards, starting with 1910.212 and 1910.217.

Read the full text in CPL 03-00-027. The machine guarding base also holds Subpart O and OSHA interpretation letters, so a follow-up question on what the inspector will check on a particular machine can be answered from the same sources.