Understanding OSHA’s Special Emphasis Programs

Responding is Barrett Pryce, content strategist, Vivid Learning Systems Inc., Pasco, WA.

In order to respond to developing situations in which the health and safety of workers may be compromised, or in which negative trends in safety call for heightened scrutiny of certain industries, OSHA relies on its Special Emphasis Program tool.

For example, a spike in illness, injury, or fatality rates in a specific industry somewhere in the country might lead OSHA to create a Special Emphasis Program to lower risks or mitigate corresponding hazards.

The three types of Special Emphasis Programs are a significant part of OSHA’s enforcement strategy. Between National, Regional and Local Emphasis Programs, 153 total programs are active.

National Emphasis Programs

OSHA has 13 active National Emphasis Programs, covering:

• Combustible Dust
• Federal Agencies
• Hazardous Machinery
• Hexavalent Chromium
• Isocyanates
• Lead
• Nursing and Residential Care Facilities
• Primary Metal Industries
• Process Safety Management
• Shipbreaking
• Silica
• Trenching & Excavation
• Refineries

Regional Emphasis Programs

Currently, OSHA has approximately 140 Regional/Local Emphasis Programs.

For purposes of meaningful enforcement, OSHA has 10 regions covering all U.S. states and territories. Because certain high-risk industries and occupations are concentrated differently in each region, OSHA deploys Regional Emphasis Programs as needed, to target enforcement and address problems in worker safety that aren’t prevalent nationally, but reflect the hazards faced by workers participating in specific regional economic activity.

For example, OSHA’s Region VI includes the states of Arkansas, Louisiana, New Mexico, Oklahoma and Texas. Right now, 11 Regional Emphasis Programs unique to Region VI are active:

• Upstream Oil and Gas Industry
• Construction
• Marine Operations
• Demolition Activities
• Work Zone Safety and Health
• Cranes Used in Construction
• Safety & Health Hazards in the Manufacture of Fabricated Metal Products
• High Noise in Manufacturing Industries
• Fall Hazards in Non-Construction Industries
• Grain Handling Facilities
• Heat Illnesses

You’ll notice that the programs listed above reflect the economic activity of the region, with focus on the oil and gas industry, heat illness, and marine operations.

Local Emphasis Programs

Each of OSHA’s 10 regions may have Local Emphasis Programs targeting issues unique to certain parts of the region. It is relatively common for each region to have some mix of Regional Emphasis Programs and Local Emphasis Programs concurrently active in each of the 10 regions, but there are exceptions.

In general, states that operate a separate, OSHA-approved worker safety and health plan rely more on Local Emphasis Programs, while states under OSHA’s federal plan deploy Regional Emphasis Programs.

For example, OSHA’s region IX, covering the states of Arizona, California, Hawaii, Nevada, and several U.S. territories in the Pacific, has 12 Local Emphasis Programs and zero Regional Emphasis Programs:

• Amputations
• Programmed Construction Inspections
• Warehousing Operations
• Programmed Maritime Inspections
• Inspections of Smelters
• Federal Agencies
• Combustible Dust
• Silica and Portland Cement Exposures
• Programmed Construction Inspections at Military Installations
• Hotels, Casinos and/or Casino Hotels
• Inspections of Longshoring Activity
• Automotive Lifts

To find out if your company is targeted by a Special Emphasis Program, look to match up your SIC code(s) with the corresponding emphasis program directive, starting with your region of operation. If you find a match, the likelihood of inspection increases substantially, and as the likelihood of inspection increases, the risk of enforcement penalty rises with it.

Editor's note: This article represents the independent views of the author and should not be construed as a National Safety Council endorsement.