June 9, 2022Client Alert

OSHA Announces Targeted Inspection Program for Wisconsin’s Food Manufacturing Industry

This week, OSHA announced that it is conducting an emphasis program targeting Wisconsin’s food manufacturing industry.  This program will include outreach, training opportunities and inspections of food manufacturing companies.  According to OSHA, the food manufacturing industry in Wisconsin has experienced significantly higher incidents of injury and illness cases in every category as compared to manufacturing overall.  Specifically, according to OSHA, Wisconsin Food manufacturers experienced 78 amputations, 17 bone fractures and 3 deaths associated with guarding or energy control between 2016 and 2020. 

What Does This Mean for the Industry?

OSHA is targeting food manufacturing businesses in the following categories of the North American Industry Code System (NAICS):  NAICS 3114xx, Fruit and Vegetable Preserving and Specialty Food Manufacturing; NAICS 3115xx, Dairy Product Manufacturing; and NAICS 3116xx, Animal Slaughtering and Processing.

Each Wisconsin Area Office (Eau Claire, Madison, Milwaukee and Appleton) will generate targeted inspection lists for random inspection in these industry groups.  Under the emphasis program, each area office is allowed to add to its list, known food manufacturers in their area.  Therefore, it is likely that companies which have been previously cited in recent years will be added to the list by the area OSHA office.  Once the list is complete, the area office is required to generate a randomly selected order for inspection.  So, any company on the list has an equal chance of being inspected.  Depending upon available resources, the area office may or may not reach each company on the list.

In addition to the randomly generated inspections, any other inspection of a food manufacturer which is triggered by an independent event (e.g. complaint, referral, etc.), even though unrelated to amputation hazards, could result in an inspection for violations of machine guarding and lockout/tagout standards. 

Note: One of the most frequent reasons for an OSHA inspection is a hospitalization or amputation, which must be reported to OSHA within 24 hours.  It is very important that when reporting such incidents, an employer makes clear when the incident does not involve a machine guarding or lockout/tagout situation.  For example, if an employee pinched a finger between two objects, causing a fingertip amputation, it is very important that the report to OSHA makes clear the matter did not involve a machine.  Under the emphasis program, if OSHA believes an incident involves a machine, it is almost certain that an inspection will follow.  That inspection will look at all machines. 

What is OSHA looking for?

A specific area of focus, listed in the emphasis program, is sanitation.  Since sanitation often occurs on the 2nd or 3rd shift, it is likely OSHA will conduct an initial inspection during the first visit.  OSHA may then schedule a follow-up visit to inspect lockout procedures during sanitation.  OSHA will also focus on physical barrier guards, light curtains, and robotics in order to verify proper guarding on all machines.  OSHA will perform an in-depth inspection to verify machine-specific lockout procedures are documented, audited yearly, and that the procedures are applied properly, especially during sanitation.  OSHA will look for open areas on machines, where pipes and covers over augers, blades and other moving parts are removed to allow water and material to drain during sanitation when the mixers or other equipment needs to keep running.  This is often a source of injury, as employees put their hands in the zone of danger while clearing loose or jammed material.   

What Should Food Manufacturing Employers do Now?

OSHA is conducting outreach programs over the next few weeks.  The sessions will be held at the following times:

If you wish to attend via audio only:

Dial: 202-693-6338

Call ID: 5552004454 

We recommend food manufacturers attend one of these sessions to learn more. 

OSHA is also urging employers to use its free consultation services for advice on complying with OSHA standards by visiting  This program is only available to establishments with less than 250 employees.

It is important that companies in the food manufacturing industry develop a plan for managing an OSHA inspection under the Wisconsin Food Industry Emphasis Program.  For further information please contact Charles B. Palmer at or 262-956-6518 or Denise Greathouse at 262-956-6534   

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