I. Purpose. This Instruction establishes a LEP for High Hazard
Industries in general industry.
II. Scope. This Instruction applies to all Regional Offices & Outreach
III. References. MOSH Instruction 11-08 (SST-11)
IV. Expiration. This Instruction expires on September 30, 2012.
V. Action Information.
- Responsible Office: Office of the Assistant Commissioner
- Action Office: All Regional Offices & Outreach
- Information Office: Office of the Assistant Commissioner
VI. Action. 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-11 Secondary List (see MOSH Instruction 11-08).
These inspections will be scheduled in accordance with MOSH's FOM Chapter 2.
VII. Background. 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 2008 as well as MOSH fatal reports from 2004 to 2009.
VIII. Procedures. This LEP will be conducted throughout the State.
- 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.
- List of Identified High Hazard Industries by NAICS Codes:
Food Manufacturing 311000
Soft Drink & Ice Manufacturing 312111
Apparel Manufacturing 315000
Wood Product Manufacturing 321000
Paper Manufacturing 322000
Other Plastics Product Manufacturing 326190
Non-metallic Mineral Product Manufacturing 327300
Fabricated Metal Manufacturing 332000
Machinery Manufacturing 333000
Motor Vehicle & Motor Vehicle Parts & Supplies Wholesalers 423100
Lumber & Other Construction Materials Wholesalers 423300
Grocery & Related Product Wholesalers 424400
Beer, Wine, & Distilled Alcoholic Beverage Wholesalers 424800
Building Material & Supplies Dealers 444100
Air Transportation 481000
Transit and Ground Passenger Transportation 485000
Couriers & Messengers 492000
Waste Management and Remediation Services 562000
- 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 within the high hazard list without regard to scheduling order.
- This list will also serve as a state specific High Hazard list for Consultation coding and
targeting efforts for VPP, CCP, SHARP, Alliances, and Training and Education activities.
IX. Recording in IMIS. The IMIS identifier code to be used in item 25c on the OSHA-1 will be
cc: J. Ronald DeJuliis, Commissioner, Division of Labor and Industry
Craig D. Lowry, Deputy Commissioner, Division of Labor and Industry
Jonathan Krasnoff, Assistant Attorney General
Office of Administrative Hearings
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