Division of Labor and Industry


MOSH Instruction 09-05 - Maryland Occupational Safety and Health (MOSH)

Subject: Local Emphasis Program (LEP) Maryland High Hazard Industries
Effective Date: October 1, 2009
Issuance Date: September 17, 2009
Purpose: This Instruction establishes a Local Emphasis Program for High Hazard Industries in Maryland.
Scope: MOSH-wide
References: MOSH Instruction 09-4 (SST-09)
Cancellation: None
Contact: Chief of MOSH Compliance Services
312 Marshall Avenue, Room 602
Laurel, Maryland 20707
(410) 880-4886 x312
Expiration Date: One year from the effective date, unless replaced earlier by a new Instruction.
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 2007 as well as MOSH fatal reports from 2004 to 2007.


MOSH compliance personnel shall ensure that the procedures contained in this directive 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-09 Secondary List (see MOSH Instruction 09-4). 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

Procedures: 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:

Food Manufacturing 311000
Beverage Manufacturing 312100
Textile Mills 313000
Apparel Manufacturing 315000
Wood Product Manufacturing 321000
Other Plastics Products Manufacturing 326190
Non-Metallic Mineral Product Manufacturing 327000
Fabricated Metal Product Manufacturing 332000
Furniture and Related Product Manufacturing 33700
Lumber and Other Construction Materials Merchant Wholesalers 423300
Merchant Wholesalers Non-durable Goods 424000
Building Material and Supplies Dealers 444100
Air Transportation 481000
Couriers and Messengers 492000

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.

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

Roger Campbell, Assistant Commissioner, MOSH


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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