In a continuation of the Obama Administration's amped up regulatory enforcement agenda, OSHA recently announced its intention to target auto suppliers. In its Regional Emphasis Program For Safety Hazards in the Auto Parts Supplier Industry, OSHA identified hazards that it believes are particularly prevalent in the industry. According to OSHA, workers in the auto supplier industry are particularly exposed to "caught-in, crushing, struck-by and electrical hazards due to the machinery utilized in making these parts," resulting in serious injuries, including amputations and deaths. As a result, OSHA is instituting an outreach and enforcement program covering all auto suppliers in the Southeast.
After sending out an "outreach" letter to "stakeholders" (employers, employees, unions, and trade associations) identifying the hazards and offers assistance, OSHA will inspect all auto supplier establishments in the region with ten or more employees. OSHA also promises that the inspections will be "comprehensive." The program will be evaluated by October 30th of each year and its effectiveness will be measured by such factors as the hazards identified and number of citations issued.
This means that unless it has been the subject of a comprehensive inspection within the last two years, every auto supplier in the Southeast region should expect that it will be inspected within the next two years. Also, depending upon its success, auto suppliers in the other geographic regions should be ready for an expansion of the program.
Finally, the information gathered by OSHA through this program, in conjunction with OSHA's proposed rule to require manufacturers to submit quarterly injury and illness reports so that OSHA can post it on the Internet, may be helpful to unions in their struggling organization efforts in this region.
Especially in light of OSHA's promise that it will pay a visit to all suppliers in the region, auto suppliers should consider taking precautionary steps now including:
- Reviewing, auditing and ensuring compliance with the NAICS code with an emphasis on lock out/tag-out, machine guarding, and Subpart-S-Electrical;
- Preparing an effective safety program in writing;
- Reviewing and maintaining up-to-date injury and illness records in proper form, ready to be produced to OSHA, while designating information as confidential where appropriate;
- Presenting updated health and safety training for managers and employees;
- Conducting periodic internal audits and potentially third party audits;
- Designating a point person to handle and coordinate the OSHA inspection; and
- Developing checklist and protocol to be used during inspection.
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