OSHA Renews Enforcement Directive Targeting Metal Fabricators

Steel fabrication is a craft built on the hard work and precision of its workers, but even the most skilled hands know the inherent risks of the job: with incredibly powerful tools come equally dangerous situations. It’s due to these dangers that OSHA renewed its directive aimed squarely at metal fabrication.

The renewed Regional Emphasis Program (REP) was signed on July 25th 2024, lasts until 2027, and it affects metalworking and fabricating worksites in five states: Arkansas, Louisiana, Oklahoma, Texas and New Mexico. (Note: Only NM worksites under OSHA jurisdiction are affected, NMED worksites are exempt.)

REPs look complicated at first glance, but if you know how to break it down, they’re fairly straightforward. Luckily there are consultancies that have been working to guide fabricators through OSHA inspections and directives.

Scope and Purpose of the REP

An REP is OSHA’s way of zeroing in on elevated risks. They typically look at a specific hazard or industry within a single region that has proven particularly dangerous.

REPs don’t enact any new codes or guidelines, it’s more a framework OSHA themselves use to systematically identify and correct unsafe practices. You should see the announcement as a warning to fabricators to get their affairs in order. By creating this program OSHA is sending a clear message: safety in the steel fabrication industry isn’t optional, it’s the law.

OSHA has broken the country down into 10 “regions,” each headed by a single OSHA office. This particular REP comes from Region VI, which is centered by OSHA’s office in Dallas, TX , and governs the surrounding states.

The choice to focus on steel fabrication was a very intentional choice. It has been consistently identified as one where workers are more likely to encounter serious injuries or illnesses on the job. Injury/illness rate is 37% higher than private industry, and over the past five years manufacturers have seen 70% higher penalties.

The bottom line is: If you’re a steel fabricator in Arkansas, Louisiana, Oklahoma, Texas and New Mexico , your chances for inspection are substantially higher, and you need to be prepared for that.

Who’s exempt?

OSHA famously doesn’t have enough inspectors to go around, so not 100% of manufacturers will receive a visit. They make a big list of companies to choose from, but that list gets a few exceptions. As previously mentioned, any New Mexico worksites under NMED jurisdiction aren’t going to be affected by this directive because they don’t answer directly to OSHA to begin with.

Additionally, OSHA won’t be inspecting any manufacturers who have recently had a “comprehensive” evaluation. The cutoff date for this is October 1, 2022, so manufacturers that have had a comprehensive inspection between then and now are excluded from the list. If your most recent comprehensive inspection was earlier than October 2022, you’re still at risk of a visit.

What is a “Comprehensive” Inspection?

Under this renewed REP every inspection will be comprehensive. In OSHA terms, that word means something very specific: it will cover all aspects of your operation. Every facet of your health and safety program will be examined, including things that aren’t obvious.

For instance, you might be expecting them to do a walkthrough of your shop floor. They will do this, but that’s just the beginning. The comprehensive inspection looks past the superficial and scrutinizes your procedures, protocols and records. Beyond the physical tour inspectors will need to see your written safety programs, employee training records, procedures, health test results and OSHA 300 incident logs. They’ll even conduct private, confidential interviews with your employees to evaluate their understanding of safety and the company’s attitude towards safety.

Because these comprehensive inspections are so extensive, they often result in multiple citations. It’s not unusual to see fines ranging from $35,000-to-$95,000, but in certain cases can exceed $100,000 or more, which illustrates just how seriously you need to take this. It’s crucial to be fully prepared.

How to Prepare: A Crash Course

I’ve been helping small steel fabricators for more than 25 years, and the first thing I do to get them up to speed is perform a mock inspection.

You would be surprised how much you can help yourself by just playing the role of an OSHA inspector. In the directive they specifically called out nine points, which are briefly outlined below. The list isn’t exhaustive but it’s a starting point:

• Machine Guarding Protocols: Ensure all machinery has appropriate guards installed to prevent accidental contact.
• Lockout/Tagout Procedures: Make sure you have LOTO procedures for each piece of equipment with a disconnect and/or multiple energy source, that they’re up-to-date, and that your employees are well trained on these protocols. Also make sure that you have a record of your “annual LOTO inspection” (many companies miss this crucial requirement).
• Electrical Installations: Ensure all wiring is properly insulated, circuits are not overloaded, and all electrical panels are accessible, not blocked and labeled correctly.
• Chemical Handling & Storage: All chemicals should be inventoried and up to date, properly labeled, and stored safely. Safety Data Sheets (SDS) should be accessible to all employees.
• Noise Control Measures: Employees exposed to an eight hour time-weighted average of 85 decibels or greater should have hearing protection provided for them. Alternatively, use engineering or administrative controls to reduce noise exposure.
• Flammable Liquid Storage: These materials should be kept in approved containers, stored in designated areas away from ignition sources. Put proper signage in place to indicate the presence of flammable substances.
• Airborne Contaminants: Local exhaust ventilation or air filtration systems help minimize exposure. Never forget that welding fumes pose a serious health hazard, especially if welding “exotic” metals like stainless steel.
• Ventilation Systems: Check that ventilation is properly maintained and sufficient to handle the levels of contaminants generated by your operations.
• Respiratory Protection Programs: If applicable, review respiratory protection programs. Ensure respirators are available properly fitted to your employees and that you schedule annual medical evaluations.

Safety as a Default: Building Culture That Lasts

As you ramp up your efforts in response to the renewed OSHA directive, you might want to consider making these preparations a permanent installation in your business, rather than a one-time scramble to avoid penalties. The benefits of this shift go far beyond compliance — they can actually transform your entire business.

Benefits

Prioritizing safety saves lives. Those machine guards will prevent amputation. Managing noise prevents hearing loss. Every precaution you take, and every procedure you put in place, protects your workers from long-term harm or death.

Beyond that, a strong safety culture can also lead to other benefits for your business. Reducing the number of accidents means fewer interruptions, lower insurance premiums, and less risk of legal issues. Businesses focused on safety attract customers, vendors, workers and partners. Better yet, it’s a proven fact that improving safety performance also improves quality performance.

How to Make it Happen

You can create this lasting culture by empowering your employees to take an active role in safety. When workers feel they have a voice in the process, they’re more likely to follow procedures and speak up when there are problems.

By embedding safety into the core of your operations, you’re not just preparing for the next OSHA mandate — you’re preparing your business for every possible change that comes down the pipeline. This proactive approach guarantees that when the next regulatory shift happens or a surprise inspection occurs, you’re not just compliant — you’re ahead of the curve, protecting your people and your business at all times.

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