Running a US Machine Shop From the UK? Preparing for an OSHA Amputations NEP Inspection

If your group owns or manages a US machine shop, it falls within OSHA's National Emphasis Program on Amputations in Manufacturing Industries, directive CPL 03-00-027, signed on 29 May 2025 and effective from 27 June 2025: NAICS 332710, Machine Shops, is listed in its Appendix B. An inspection under the programme examines every location and practice involving the operation, servicing, maintenance, hazardous energy control and machine guarding of equipment that can amputate. At the opening conference, the compliance officer should collect the site's injury records for the current and previous three calendar years and ask for its lockout/tagout programme and training records.

Why US machine shops are in scope

OSHA built the list from three data sources described in Appendix A: inspection data for 2019 to 2023 on five standards linked to amputations (1910.147, 1910.212, 1910.213, 1910.217 and 1910.219), Bureau of Labor Statistics amputation counts for 2019 to 2022, and employer-reported amputations for 2019 to 2023. The result is 91 six-digit NAICS codes. Besides 332710, codes relevant to precision engineering include 332721 (precision turned products), 332722 (bolts, nuts, screws, rivets and washers), 333514 (special dies, tools, jigs and fixtures), 333515 (cutting tools and machine tool accessories) and 333517 (machine tool manufacturing).

Selection is not a sign of suspicion. Each Area Office works from a master list of establishments in the covered codes, either inspecting the whole list or taking establishments in random number order. It may add sites in covered codes where machinery-related amputations or fatalities occurred in the five years before the effective date, after which the list is re-randomised.

Situations where the site should not be inspected under the NEP

• 10 or fewer employees and a primary NAICS code on the Low-Hazard Industry Table of the Appropriations Act directive. The base does not reproduce that table; check the current directive rather than assume.
• The site's code is not in Appendix B.
• The CSHO finds no machinery, equipment or process presenting amputation hazards.
• The site participates in OSHA's Voluntary Protection Programs (VPP).
• An NEP inspection was initiated in the previous 24 months and no amputations were reported in that period: the site may be deleted from the programmed list, at OSHA's discretion.

Documents to have ready for the opening conference

The CSHO should verify the NAICS code and headcount, and ask whether any machinery, equipment or process that could cause amputations is present. Make sure local management can produce, without waiting for head office:

1. OSHA 300 logs, 300A summaries and 301 incident reports for the current and previous three calendar years.
2. The energy control programme and procedures (lockout/tagout).
3. Training records.
4. Other documents within the scope, for instance mechanical power press inspection and maintenance certification records under 1910.217(e).

If records are held centrally in the UK, agree beforehand who in the US can retrieve them. The directive allows the CSHO to expand the scope where injuries recorded on both the 300 and 301 forms, an employee statement or a plain-view observation suggest problems elsewhere on site.

What happens on the shop floor

On the walkaround, the CSHO focuses on nip points, pinch points, shear points, cutting hazards and other points of operation, and evaluates exposure during setup, normal operation, clearing jams, adjustments on running machines, cleaning, oiling and greasing, scheduled and unscheduled maintenance, and hazardous energy control. Employees are interviewed and more than one shift may be assessed. OSHA expects its inspectors on these visits to be trained in machine guarding and lockout/tagout.

A common question from UK colleagues is whether a lathe really needs a guard under US rules. OSHA's letter of 15 October 1990 says 1910.212(a)(1) does apply to drill presses and lathes. You can test similar questions in the OSHA machine guarding knowledge base, which answers with the letter or paragraph concerned.

Training: what operators should be able to explain

Interviews make training visible. For mechanical power presses, 1910.217(f)(2) requires operators to be trained and instructed in the safe method of work before they start, with adequate supervision to make sure correct procedures are followed. OSHA's eTool lists what thorough machine training should cover: the hazards of each machine; the safeguards and what they protect against; how to use them and why; how, when and by whom they may be removed; when lockout/tagout is required; and what to do if a safeguard is damaged, missing or inadequate. It should be given to new operators and maintenance or setup staff, whenever safeguards are added or altered, and when someone moves to a new machine.

OSHA publication 3170 adds that only trained employees should operate machinery and that supervision should reinforce safe practices. If your group runs a common training matrix across UK and US sites, check that the US version records these topics per machine, because that is the evidence a CSHO will look for alongside the training records requested at the opening conference.

If the inspector decides not to inspect

The directive tells the CSHO not to proceed where the code is not listed, where no amputation hazard exists, or where the small-employer low-hazard exemption applies. In that case the CSHO must document the reasons, leave the establishment and record the visit as "No Inspection". It is worth asking the CSHO which ground was used, so your records are accurate.

A remote-readiness plan for group HSE

1. Confirm each US site's primary NAICS code and headcount, and whether the Low-Hazard Industry Table exemption could apply.
2. Ask each site to send a four-year extract of its 300, 300A and 301 records and flag amputation-related entries.
3. Commission a walk-through covering setup, jam clearing and cleaning tasks, not just production.
4. Check lathes, drill presses, mills and grinders against 1910.212 and 1910.215; power transmission against the 7 ft rule of 1910.219.
5. Review the site's lockout/tagout programme and machine-specific procedures.
6. For presses, check 1910.217(e) records exist and are signed.
7. Name a local person who will accompany the CSHO and can produce records.
8. Brief supervisors that employee interviews are part of the inspection.

Timing and what the base cannot tell you

The directive states that it terminates five years from its effective date, which is 27 June 2025, so it is set to run until June 2030 (2025 + 5) unless replaced. Area and Regional Offices were required to run a 90-day outreach programme focused on industries not targeted in 2019. The base does not hold penalty amounts, State Plan variants or UK rules, so it will not answer those; for guarding and NEP procedure, the machine guarding base cites CPL 03-00-027 and Subpart O directly.