In February 2014, OSHA Region 4 (Atlanta) initiated a Regional Emphasis Program (REP) focusing on hazards related to automotive supply manufacturing operations. As a result of this REP, OSHA will be conducting comprehensive, wall-to-wall inspections of automobile parts suppliers during the next two years. While the inspections will be comprehensive, the particular areas of focus include:

  1. Machine guarding;
  2. Temporary employees and new hire training;
  3. Lockout/tagout and machine-specific procedures;
  4. Electrical hazards (included whether machines are properly grounded); 
  5. Forklift training and operation;
  6. HAZCOM training (particularly the 2013 requirements for the Revised Hazard Communication Standard)

Each of the inspections to date has covered all of these issues through thorough walk-through inspections, document requests, and interviews of hourly employees and management.

In Alabama, both the Mobile and Birmingham offices have begun conducting these inspections. Mobile's OSHA office conducted at least four inspections during the week of March 16, 2014. We have been notified that the Mobile office has 50 companies on its list of employers to inspect. Every automobile supplier in Region 4 is likely to be targeted at some point during the next one to two years.

In addition to conducting internal reviews of all safety practices, procedures, and guarding, automobile suppliers should consider contacting state on-site consultation offices, such as Safe State in Alabama, for free inspections which may postpone scheduled comprehensive inspections once a compliance visit date has been scheduled. Employers contacting one of these offices should seek to schedule an inspection date as soon as possible, as OSHA is likely not to postpone an inspection if an inspection date has not been set. Employers (particularly those with less than 250 employees) may also be eligible for OSHA's Safety & Health Achievement Recognition Program "SHARP", which exempts the employer from an inspection for two years if the employer meets the requirements and successfully completes the program.