Excellent!  Thank you Steve, and I’ll pop this out to the discussion list ASAP so our folks can get the information.

David,

As I said before I left on Tuesday, I forgot to stress to the group that if their company or group gets inspected under a NEP-Amp inspection, besides machine guarding, the compliance officer will also evaluate the company’s lockout program and whether their maintenance staff performs electrical troubleshooting/voltage testing and any other live electrical work covered under Electrical Safety Related Work Practices standards (ESRWP) 29 CFR 1910.331-335.  Compliance with ESRWP is one of the commonly overlooked and missed issues on most of the NEP-amp inspections.

On the public website (osha.gov) under the Enforcement tab, there is a Quick link on the right side to Directives, and they can search CPL 03-00-003 for the NEP-amp directive.  There is a power point presentation attached that has 43 slides that explains the emphasis program.  Under the Inspection Procedures (IX.C), it explains what a compliance officer will evaluate beside just the presence of a guard, such as set-up, threading, clearing jams, cleaning, scheduled/unscheduled maintenance, and locking out.

Steve Brunette

Compliance Officer

Safety Specialist

US DOL/OSHA

Cincinnati Area Ofice

36 Triangle Park Dr.

Cincinnati, OH. 45246

513-841-4196