If you are a motor vehicle parts manufacturer within Georgia, Alabama and Mississippi, your probability of undergoing a comprehensive on-site Federal OSHA safety inspection within the next two years is virtually certain, according to the recently launched OSHA Region IV “Regional Emphasis Program for Safety in the Auto Parts Industry” (REP).  The program, announced earlier this year, seeks to reduce workplace exposures to safety and health hazards in the motor vehicle parts supply industry, emphasizing the most common causes of injury and the most frequently-cited violations, comprising lock out/tag out; machine guarding; and electrical-related hazards. In light of OSHA’s 2013 revision of the Federal Hazard Communication Standard and attendant employee training requirements, evidence of an employer’s compliance with those requirements will likely also undergo scrutiny. 

OSHA’s inspection activities will commence thirty days following mailing of an outreach and notification letter sent to relevant employers, and all inspections covered by the REP will be completed within two years.  Notices concerning the REP will also be sent to industry “stakeholders” (including unions and trade associations), to raise awareness of the REP and the hazards associated with the automotive parts supply industry.  These notification letters have already begun to be delivered by OSHA to affected employers. 

In light of impending compliance inspections under OSHA Region IV’s REP, employers in Georgia, Alabama and Mississippi should consider taking immediate steps necessary to review, audit, and ensure their OSHA compliance status.