Division of Labor and Industry


MOSH Instruction 13-5 - National Emphasis Program (NEP) - Primary Metal Industries

Subject: MOSH Instruction 13-5 - Primary Metal Industries
Effective Date: February 5, 2013
Issuance Date: February 5, 2013
Cancellation: None
Expiration Date: Three years from the effective date, unless replaced earlier by a new Instruction.
Purpose: This Instruction adopts the OSHA National Emphasis Program to identify and reduce or eliminate worker exposures to harmful chemical and physical health hazards in facilities in the Primary Metal Industries.
Scope: MOSH-wide.
Reference: OSHA Directive CPL 03-00-013 (PDF document, download Adobe Acrobat for free
Contact: Chief of MOSH Compliance Services
See MOSH Website for Current Information
By and Under the Authority of: Eric M. Uttenreither, Assistant Commissioner


OSHA inspection history has shown that individuals employed in the Primary Metal Industries are exposed to serious safety and health hazards on a daily basis. Previous inspections of primary metal establishments have resulted in citations for overexposures to a wide variety of health hazards including chemical exposures in foundry operations as well as physical stressors such as noise and heat. This Instruction describes policies and procedures for implementing a National Emphasis Program (NEP) to identify and reduce or eliminate worker exposures in facilities under the Primary Metal Industries, Major Group 33 in the Standard Industrial Classification (SIC) Manual. This NEP will also heighten health and safety awareness within the affected industries of the potential for worker exposure to harmful chemical and physical hazards so that employers may voluntarily take steps to correct hazards and comply with current safety and health regulations and practices.


  1. MOSH compliance and consultation personnel shall utilize OSHA Directive CPL 03-00-013 while preparing for and performing on site inspections and visits in primary metal industries.
  2. Supervisors shall ensure that this instruction is reviewed with all compliance officers and consultation staff.
  3. Wherever the OSHA Instruction references job titles, manuals, and offices, the equivalent MOSH job title, manual, or office shall apply.
  4. The Chief of MOSH Compliance Services shall act as coordinator for this NEP.
  5. The inspection list shall be queried from the most current Hoovers Directory utilizing Appendix B contained in the Instruction and randomized for inspection.
  6. Wherever the OSHA Instruction references medical records or privacy, COMAR 09.12.22 Personally Identifiable Employee Medical Information, shall be utilized instead.
  7. This is a three year long MOSH Instruction and at least 3 facilities will be inspected per year.
  8. All NEP coding shall be consistent with this Instruction and entered into IMIS.

cc: J. Ronald DeJuliis, Commissioner, Division of Labor and Industry
Jonathan Krasnoff, Assistant Attorney General
Office of Administrative Hearings

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