U.S. Electronics Industry May See Increased Workplace Inspections as Part of COVID-19 National Emphasis Program

Key Summary

• OSHA launched a COVID-19 National Emphasis Program targeting industries with elevated exposure risks, including electronics manufacturing.
• Electronics sectors NAICS 334xxx and 335xxx fall on OSHA’s secondary inspection list under the COVID-19 NEP.
• OSHA inspections will prioritize facilities where tasks involve frequent close-contact exposure among workers.
• The COVID-19 NEP includes safeguards to prevent retaliation against workers reporting safety concerns.
• NEP inspections began March 26, 2021 and may continue for up to twelve months.


The U.S. Occupational Safety and Health Administration (OSHA) announced a new COVID-19 National Emphasis Program (NEP) to significantly reduce or eliminate worker exposures to SARS-CoV-2 by targeting industries and worksites where employees may have a high frequency of close contact exposures.

The NEP sets goals for inspections of workplaces in selected industries and it includes an added focus to ensure workers are protected from any whistleblower retaliation. Industry code (NAICS) and elevated illness rates as indicated by required reporting will be used to determine site selection for programmed inspections. Inspections began March 26, 2021 and the NEP is effective for no more than 12 months unless canceled or extended.

The primary target industries include those where OSHA data shows the highest number of workers expected to perform tasks associated with exposures to SARS-CoV-2, such as healthcare industries, meat slaughtering and processing, supermarkets and grocery stores, and restaurants. OSHA anticipates that most of the inspections will continue to occur in general industry, particularly in healthcare, based on current OSHA enforcement data that show higher COVID-19-related complaints, referrals and severe incident reports at healthcare worksites.

The secondary target industries, a list that supplements the primary list, includes NAICS codes for essential critical infrastructure workers, apart from healthcare. NAICS 334xxx, computer and electronic product manufacturing, and NAICS 335xxx, electrical equipment, appliance, and component manufacturing, are both listed on the secondary list. These secondary target industries, and approximately three dozen others, maintain critical business operations or would otherwise help to maintain a healthy work environment, and are likely to be at increased risk of exposure.

For information on the NEP and the inspections, read more here.  For timelines, see here.

The NEP is a separate effort from OSHA’s  Emergency Temporary Standard (ETS), which is expected to be released soon in accordance with an executive order from U.S. President Biden. IPC will continue to keep you posted on these agency actions. 

 

Q:
What does OSHA’s COVID-19 National Emphasis Program mean for electronics manufacturers?
A:

The NEP places NAICS 334xxx and 335xxx on the secondary target list, meaning electronics facilities may see increased inspections based on exposure risks.
 

Q:
Why are electronics facilities included in the secondary list of OSHA’s COVID-19 NEP?
A:

OSHA identifies these sectors as essential operations that may face higher exposure risks and therefore warrant additional monitoring.
 

Q:
How does OSHA determine which electronics worksites may be inspected under the COVID-19 NEP?
A:

Inspections are based on industry codes, illness reporting data, and workplace tasks that may involve close contact exposures.
 

Q:
How is OSHA’s COVID-19 NEP different from the Emergency Temporary Standard expected from the agency?
A:

The NEP focuses on targeted inspections, while the ETS will set mandatory workplace safety requirements once released.
 

Q:
What protections does OSHA’s COVID-19 NEP provide for workers in electronics manufacturing?
A:

The NEP includes added attention to preventing whistleblower retaliation and ensuring workers can report concerns safely.