OSHA's Local Emphasis Program for Food Manufacturers

OSHA is now conducting inspections in Illinois (and Ohio) as part of a new Local Emphasis Program (LEP) for the Food Manufacturing Industry announced in late 2022. This LEP empowers Illinois OSHA offices to inspect food manufacturing and processing sites with a focus on machine guarding hazards, the employer’s hazardous energy control (LOTO) program, and the sanitation program (hazard communication and Group LOTO). OSHA has the ability under this LEP to conduct inspections for all referral and complaints, formal or non-formal, which contain allegations of potential worker exposure to serious hazards associated with operating food production machinery or performing service, maintenance, and sanitation tasks on food processing and ancillary equipment.
Establishments can be selected for an inspection even if they have an exemplary safety record, have not been the subject of any complaints, and have not recently reported a serious incident. This discussion covered what to expect and how to prepare your company for an OSHA inspection.
Attendees heared directly from FDR Safety’s Steve Hawkins, former Head of Tennessee OSHA, and Aaron Gelb, Head of Conn Maciel’s Midwest OSHA Practice. Together they answered the following questions:
• What is an emphasis program?
• How do programmed inspections differ from accident and complaint-based inspections?
• Which NAICS codes will be targeted?
• What happens during an LEP inspection?
• Which aspects of your operations draw the most scrutiny?
• What hazards are seen most often in food manufacturing?
• How should employers prepare for LEP inspections?
A webinar from Conn Maciel Carey LLP.
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