Division of Labor and Industry


MOSH Instruction 08-09 - Maryland Occupational Safety and Health (MOSH)

Subject: Local Emphasis Program (LEP) Maryland High Hazard Industries
Effective Date: October 1, 2008
Issuance Date: August 25, 2008
Cancellation: None
Expiration Date: One year from the effective date, unless replaced earlier by a new Instruction.
Purpose: This Instruction establishes an LEP for High Hazard Industries in general industry.
Scope: MOSH-wide
Reference: MOSH Instruction 08-8 (SST-08)
Contact: Chief of MOSH Compliance Services
312 Marshall Avenue, Room 602
Laurel, Maryland 20707
(410) 880-4886 x312
By and Under the Authority of: Roger Campbell, Assistant Commissioner


General Industry injuries and illnesses are tracked by several different methods. By analyzing the results of injury and illness data, employment data, and fatalities over a three year period to determine ascending or descending trends results in a list of High Hazard Industries that indicates where MOSH needs to focus its resources. This data is based on Bureau of Labor and Statistics databases from 2004 to 2006 as well as MOSH fatal reports from 2004 to 2006.


MOSH compliance personnel shall ensure that the procedures contained in this Instruction are followed when conducting this LEP. The Chief of Compliance, or designee, will randomize establishments of the same NAICS/SIC identified through the High Hazard Industries listed in Section VIII.B and assign in cycles concurrently with SST-08 Secondary List (see MOSH Instruction 08-8). These inspections will be scheduled in accordance with MOSH's FOM Chapter 2.

Action Information.

a) Responsible Office: Office of the Assistant Commissioner
b) Action Office: All Regional Offices
c) Information Office: Office of the Assistant Commissioner


This LEP will be conducted throughout the State.

A. The Chief of Compliance, or designee, will create a randomized establishment inspection list by extracting the industries listed in Paragraph B of this section from an establishment database of Maryland employers with 11 or more employees.

B. List of Identified High Hazard Industries by NAICS Codes:

Animal Slaughtering & Processing 311610
Bread & Bakery Product Manufacturing 311810
All Other Food Manufacturing 311990
Soft Drink and Ice Manufacturing 312110
Textile Mills 313000
Apparel Manufacturing 315000
Wood Product Manufacturing 321000
Paper Manufacturing 322000
Other Plastics Products Manufacturing 326190
Non-Metallic Mineral Product Manufacturing 327000
Fabricated Metal Product Manufacturing 332000
Semiconductor and Other Electronic Component Manufacturing 334400
Furniture and Related Product Manufacturing 337000
Lumber and Other Construction 423300
Grocery and Related Product Merchant Wholesalers 424400
Beer, Wine, and Distilled Alcoholic Beverage Merchant Wholesalers 424800
Building Material and Supplies Dealers 444100
Air Transportation 481000
Couriers and Messengers 492000
Waste Management and Remediation Services 562000

C. Any unprogrammed inspection or investigation such as a complaint, referral, fatality, etc., will be expanded to a comprehensive safety or health inspection for any establishment that is already included in a current inspection cycle.

D. A large number of High Hazard Industries are reported via referrals and complaints, both of a formal and a non-formal nature. Formal complaints of High Hazard Industries sites will continue to be scheduled before programmed inspections. Non-formal complaints and referrals which would normally be handled by letters will be handled in accordance with paragraph VIII.C. above. Inspection history and the scope of the inspection will be handled in the same manner.

1X. Recording in IMIS. The IMIS identifier code to be used in item 25c on the OSHA-1 will be "HIGHHAZD".


cc: J. Ronald DeJuliis, Commissioner, Division of Labor and Industry
Craig D. Lowry, Deputy Commissioner, Division of Labor and Industry
Jonathan R. Krasnoff, Deputy Counsel, Department of Labor, Licensing and Regulation
Office of Administrative Hearings

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