OSHA's 2025 update to the “National Emphasis Program on Amputations in Manufacturing Industries” marks a major shift in how the agency enforces machine safety regulations. The directive, which took effect on June 27, 2025, and will remain in place for five years, introduces more targeted inspection criteria and focuses on higher-risk workplaces.
So, why is this renewed focus causing such a shake-up in the way manufacturers approach machine guarding? And more importantly, what steps should they be taking now to stay ahead of potential violations and protect their workforce from life-altering injuries?
Key Takeaways
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The updated National Emphasis Program reflects a more aggressive, data-driven approach to reducing machine-related amputations in manufacturing.
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Machinery accounts for 58% of reported amputations, but studies suggest actual incidents may be more than twice as high due to underreporting.
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The impact of an amputation goes far beyond the initial injury, often resulting in lost wages, permanent disability, and a lasting decline in quality of life for the affected worker.
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State OSHA programs must adopt the NEP or an equivalent version within six months, ensuring nationwide impact even in non-federal states.
Amputations in Manufacturing Settings
Amputation hazards continue to be one of the most devastating and preventable workplace injuries in manufacturing, with machinery involved in approximately 58% of work-related amputations according to Bureau of Labor Statistics (BLS) data. But the actual scale of the problem is likely much greater. In states like Michigan, research indicates that fewer than half of workplace amputations are reported, suggesting that the actual numbers could be 2.5 times higher than the official data reflects.
Amputations involving machinery in manufacturing typically happen when a worker's body part comes into contact with unguarded or inadequately guarded moving parts.
These incidents tend to follow well-known patterns tied to specific machine hazards and unsafe practices. Here are the most common ways these injuries happen:
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Point of Operation Contact: Workers can be injured when they reach into the point of operation to clear a jam, reposition material, or make adjustments while the machine is still running.
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In-Running Nip Points: These are areas where two rotating parts move toward each other, creating a pulling force that can trap clothing, gloves, or body parts.
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Rotating Parts and Entanglement: Exposed components like shafts, spindles, or couplings pose a serious risk when loose clothing, jewelry, or hair becomes entangled, pulling the worker into the machine.
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Unexpected Machine Startup: Often due to a lack of proper lockout tagout (LOTO) procedures, this can catch workers off guard during cleaning, maintenance, or adjustments.
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Manual Bypassing of Machine Guards: Some workers intentionally remove or disable safety guards to speed up production or make tasks easier
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Poorly Maintained or Improvised Equipment: Equipment with broken or missing guards, makeshift modifications, or outdated safety features increases the risk of severe injury.
The Occupational Safety and Health Administration’s update to the National Emphasis Program reflects a clear intent to reverse this trend. By tightening inspection criteria and expanding enforcement across high-risk industries, the agency is sending a message: manufacturers must do more.
Key Regulatory Changes
To achieve a trend reversal on work-related amputations, OSHA has introduced several key changes that manufacturing leaders need to understand:
Expanded Industry Targeting
The 2025 NEP has significantly expanded its scope to include 91 six-digit NAICS (North American Industry Classification System) codes, adding numerous industries not previously covered in the 2019 version. New additions include:
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Automobile manufacturing
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Oilseed processing
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Beet and cane sugar manufacturing
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Frozen specialty food manufacturing
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Fruit and vegetable canning
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Iron and steel foundries
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Farm machinery manufacturing
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Upholstered furniture manufacturing
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This expansion reflects OSHA's analysis of data from 2019-2023, which identified high-risk sectors based on three criteria:
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High inspection numbers related to lockout/tagout and machine guarding violations
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Industries with 50 or more amputations per year
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Industries with 25 or more employer-reported amputations per year
Refined Inspection Criteria
The updated NEP introduces several important changes to inspection protocols:
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Establishments that underwent an NEP inspection within the previous 24 months with no reported amputations may now be removed from programmed inspection lists.
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Unprogrammed inspections can only be expanded to an Amputations NEP inspection if the establishment's NAICS code is listed in the updated Appendix B.
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Establishments with 10 or fewer employees whose primary NAICS code appears on the “Low-Hazard Industry Table” are exempt from inspections under this NEP.
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VPP (Voluntary Protection Program) sites are removed from programmed inspection lists during their approved participation.
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Outreach Requirements
OSHA requires a 90-day outreach period before enforcement actions begin, focusing particularly on industries that were not previously targeted by the 2019 Amputations NEP. This gives manufacturers time to address potential hazards before inspections commence around September 25, 2025.
What State Plans Must Do?
Since OSHA’s 2025 Amputation NEP update is a federal program change, State Plan states are required to adopt an identical or “at least as effective” version of the directive. Here’s what the State Plan states must do:
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Declare Intent Within 60 Days: Notify OSHA by August 26, 2025, whether the state will adopt the federal NEP as-is or implement a state-specific equivalent.
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Submit Alternative Plans for Federal Review: If choosing a different version, submit it to OSHA and demonstrate that it is at least as effective as the federal directive.
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Implement Within Six Months: Ensure full implementation of the state’s version no later than December 27, 2025.
The Human Cost Behind the Statistics
Behind every data point is a person whose life and livelihood have been permanently altered. Between 2015 and 2022, employers in 29 states reported over 74,000 severe injuries to OSHA. That’s an average of 27 workers per day suffering some of the most serious injuries on the job. Amputations make up a troubling share of these cases and remain among the most physically and emotionally devastating outcomes a worker can experience.
According to the Bureau of Labor Statistics, an amputation injury typically forces a worker to take a median of 31 days away from work to recover, more than three times the recovery period for other injuries, which average just 9 days. For many, the trauma doesn’t end with the wound; these injuries often mean lost income, long-term disability, and a diminished quality of life.
In manufacturing, machine-related amputations are most commonly tied to equipment used in metalworking, woodworking, and specialized material processing. Meanwhile, meat and poultry processing facilities continue to stand out for their disproportionately high rates of severe injuries, including amputations. These environments frequently involve high-speed machinery, tight workspaces, and intense production pressure, all risk factors that compound the danger.
Industry Response and Compliance Challenges
Manufacturing stakeholders and legal experts recommend several proactive measures in response to the updated NEP:
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Conduct comprehensive reviews of machine guarding and lockout tagout procedures
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Ensure all relevant machine guarding is in place and properly maintained
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Update lockout/tagout procedures and provide refresher training
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Consider scheduling mock inspections to identify potential hazards before OSHA visits
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Review whether establishments qualify for any exemptions under the new criteria
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Industry associations such as OneGroup emphasize that OSHA's enhanced emphasis program “reaffirms its commitment to reducing workplace amputations through targeted inspections, data-driven industry focus, and improved incentives for safe operations.”
Law firms specializing in OSHA compliance advise manufacturers to verify their NAICS codes and employee counts to determine if they fall within the scope of the NEP, and to be prepared for potential inspections by having documentation ready and implementing robust safety programs.
Looking Forward: Industry Transformation
The stricter enforcement environment created by the 2025 Amputation NEP is likely to accelerate several trends in manufacturing:
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Technology Adoption: Increased investment in automated systems that eliminate human interaction with hazardous machinery.
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Safety Culture Transformation: Greater emphasis on proactive safety measures rather than reactive compliance.
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Workforce Development: Enhanced training programs focusing on hazard recognition and prevention.
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Industry Consolidation: Smaller manufacturers may struggle with compliance costs, potentially leading to consolidation.
The 2025 NEP represents a significant shift in OSHA's approach to amputation hazards, utilizing more sophisticated data analysis to target high-risk industries and offering incentives (removal from inspection lists) for sustained good performance. This carrot-and-stick approach may prove more effective than previous enforcement strategies.
Balancing Risk, Compliance, and Modernization
OSHA's 2025 Amputation NEP updates signal a significant shift in regulatory focus that will have far-reaching impacts on manufacturing operations. The expanded scope, refined targeting methodology, and enhanced enforcement mechanisms are forcing manufacturers to reconsider their approaches to machine guarding and worker safety.
While compliance may present challenges, particularly for smaller operations with older equipment, the ultimate goal of reducing devastating amputation injuries justifies these measures. The human cost of machine-related amputations remains too high to ignore.
Manufacturers who proactively invest in safety systems and modernized equipment will not only ensure compliance but also benefit from improved productivity, reduced downtime, and enhanced worker morale. The key question for many facilities will be whether to invest in retrofitting older machinery or accelerate plans for equipment modernization, a decision that will shape the industry's transformation in the years ahead.
FAQs on OSHA 2025 Amputation NEP Update
What is OSHA’s National Emphasis Program (NEP) on Amputations?
The NEP is a targeted enforcement initiative focused on reducing amputations in manufacturing by increasing inspections and compliance around machine guarding and related hazards.
Which industries are now covered under the expanded NEP?
The update broadens coverage beyond traditional metalworking to include food processing, plastics, wood products, and other high-risk manufacturing sectors. Check Appendix B of the NEP directive for the full list.
What should manufacturers do to prepare for NEP inspections?
Conduct a machine guarding audit, review lockout/tagout programs, train workers, inspect older equipment for compliance, and ensure injury records (e.g., 300 logs) are up to date and accurate.
What are the penalties for non-compliance with the NEP?
While specific penalties vary, non-compliance with machine guarding or lockout tagout standards can lead to citations with fines up to $161,323 per serious violation. Proactive compliance is urged to avoid costly penalties.
Where can I find resources to comply with the NEP?
OSHA’s Machine Guarding webpage (www.osha.gov/machine-guarding) offers compliance tools, including checklists and training guides. The NEP directive includes appendices on targeting methodologies and NAICS codes.
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