Regional Emphasis Program (REP) for Landscaping and Horticultural Services

U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration
DIRECTIVE NUMBER: BMH-CPL-04-00-003
SUBJECT: Regional Emphasis Program (REP) for Landscaping and Horticultural Services
REGION: Birmingham Region
SIGNATURE DATE: July 30, 2026 EFFECTIVE DATE: October 1, 2026
AB
STRACT
Purpose: The purpose of this instruction is to renew a Regional Emphasis Program
(REP) to reduce workplace fatalities in the Landscaping and Horticultural
Services industry (NAICS 561730), Landscape Architectural Services (NAICS
541320), and Other Scientific and Technical Consulting Services ( NAICS
541690).
Scope: This instruction applies to all Birmingham Region Federal Area Offices.
Ref
erences:
See Section III.
Cancellations: This instruction supersedes OSHA Regional Instruction BHM-CPL-04-00-
003, Regional Emphasis Program (REP) for Landscaping and Horticultural
Services, April 17, 2025.
State Impact: No Impact.
Action Offices: This instruction applies to Baton Rouge, Birmingham, Jackson, Little Rock,
Mobile, and Nashville Federal Area Offices.
Or
iginating Office:
Birmingham Regional Office
Contact: Assistant Regional Administrator for Enforcement Programs
B
y and Under the Authority of
D
ORINDA HUGHES
Regional Administrator

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Executive Summary

The purpose of this instruction is to renew a Regional Emphasis Program to reduce workplace
fatalities in the Landscaping and Horticultural Services industry (NAICS 561730), Landscape
Architectural Services (NAICS 541320), and Other Scientific and Technical Consulting Services
(NAICS 541690)
as part of the OSHA region realignment.

Significant Changes

• Added Baton Rouge and Little Rock Area Offices.
• Updated the OSHA Information System statistical data.
• Updated Bureau of Labor Statistics charts and information.

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Table of Contents

I. Purpose. ............................................................................................................................................... 4
II. Scope. ................................................................................................................................................... 4
III. References. ........................................................................................................................................... 4
IV. Cancellations. ....................................................................................................................................... 4
V. Expiration..........................................................................................................................................................4
VI.
Action Offices. ...................................................................................................................................... 4
VII. Federal Program Change. .................................................................................................................... 4
VIII. Significant Changes. ............................................................................................................................. 4
IX. Background........................................................................................................................................... 5
X. Procedures ........................................................................................................................................... 5
XI. Recording in OIS ................................................................................................................................... 6
XII. Outreach .......................................................................................................................................... 6
XIII. Evaluation ........................................................................................................................................ 7

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I. Purpose.
To reduce the fatal accidents rate for Landscaping and Horticultural Services. This
instruction renews a Regional Emphasis Program (REP) to reduce workplace fatalities in
the Landscaping and Horticultural Services industry (NAICS 561730), Landscape
Architectural Services (NAICS 541320), and Other Scientific and Technical Consulting
Services (NAICS 541690).
II. Scope.
This instruction applies to all Birmingham Region Federal Area Offices.
III. References.
A. OSHA's Industry Profile for Industry Group 078, Landscape and Horticultural
Services

B. OSHA Instruction CPL 02-00-025, Scheduling System for Programmed Inspections,
January 4, 1995.

C. OSHA Instruction CPL 04-00-002, Procedures for Approval of Local Emphasis
Programs (LEPs), November 13, 2018

D. OSHA Instruction CPL 02-00-164, Field Operations Manual (FOM), February 9,
2026, or current update

E. U. S. Department of Labor, Bureau of Labor Statistics: Occupational
Injuries/Illnesses and Fatal Injuries Profiles – Landscaping services

IV. Cancellations.
This instruction supersedes OSHA Regional Instruction BHM-CPL-04-00-003, Regional
Emphasis Program (REP) for Landscaping and Horticultural Services, April 17, 2025.

V. Expiration.
This instruction expires within five years of the effective date, unless extended.
VI. Action Offices.
A. Responsible Office.
Birmingham Regional Office – Enforcement Programs.
B. Action Office.
Baton Rouge, Birmingham, Jackson, Little Rock, Mobile, and Nashville Federal Area
Offices.
VII. Federal Program Change.
None.
VIII. Significant Changes.
Added Baton Rouge, Little Rock Area Offices. Update OSHA Information System statistical
data. Update Bureau of Labor Statistics charts and information.

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IX. Background

Landscaping activities include mowing lawns; weed trimming; planting flowers, shrubs
and trees; and trimming hedges and trees. Landscaping businesses will often fertilize
plants and grounds, as well. Employees are exposed to multiple hazards when performing
these activities, such as falls, electrical, struck-by, etc. Employees can be injured or killed
when utilizing landscaping equipment, e.g., mowing with zero-turn lawnmowers on
slopes or trimming trees near overhead power lines.

According to 2024 BLS data, the total incidence rate in Landscaping Services was 3.0,
compared to all Private Industry at 2.3. Additionally, the rate for cases with days away
from work, job transfer, or restriction was 2.0, compared to 1.4 for all Private Industry.

In FY 2024, the Birmingham Region conducted 14 inspections of landscaping operations,
including seven fatality investigations. In addition, the Region investigated three
employer-reported referrals. Of the nine inspections that resulted in violations, 77.78%
included at least one serious violation. Three of the seven fatality investigations were
conducted by the Baton Rouge Area Office.

Expanding this Regional Emphasis Program (REP) to include the Baton Rouge and Little
Rock Area Offices is justified by the presence of similar industry hazards and the need for
consistent enforcement across the Birmingham Region.

X. Procedures

Compliance Safety and Health Officers (CSHO) shall, while traveling during their workday,
be watchful for work activities where employees may be exposed to hazardous conditions
while doing landscape/horticultural type work. The CSHO, seeing such work activity shall
attempt to contact the area office to obtain authorization from the Area Director or
Assistant Area Director to begin an immediate inspection. Approval to start an inspection
will normally be granted to the CSHO provided that this activity does not conflict with
higher priority inspection activity.

If the CSHO does not have readily available means to contact the area office or is
otherwise unable to reach area office personnel who can authorize the
inspection/intervention, the CSHO will initiate either a limited scope inspection that will
focus on the observed hazard with an option to expand to plain view hazards, or an
intervention provided this activity will not interfere with higher priority inspections or
assignments. The CSHO will give highest priority to preventing further employee exposure
to the hazards observed. The CSHO shall notify the area office management of the
inspection/intervention as soon as possible.

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Whenever an inspection is begun under this REP, the CSHO will include in the case file
narrative a description of the circumstances which resulted in discovery of the work
activity that was the basis of the inspection. In cases where authorization was not
obtained, an explanation shall be included as to the circumstances.

XI. Recording in OIS

Current instructions for completing the appropriate OSHA forms shall be applied when
recording inspections under this REP.
A. The Inspection Form, under the Inspection Type Tab for a programmed inspection
conducted under this regional emphasis program shall be marked "Planned" and
"Local Emphasis Program". The CSHO shall record "LANDSCPE" from the LEP drop
down menu for proper coding. CSHO self-referrals are to be recorded as
programmed inspections. Complaints, referrals from sources such as police
departments or fire departments, fatality/catastrophe, and follow-up inspections
shall be appropriately recorded as unprogrammed inspection activity, marked
"Local Emphasis Program" and coded "LANDSCPE".

B. Upon entry, if it is determined the employees are not exposed to hazards and/or
adequate precautions were taken to protect employees, the Inspection Form shall
be coded "No Inspection". The Inspection Form shall also be coded as described
in paragraph XI(A), and a brief statement shall be included with the case file to
explain why an inspection was attempted and the circumstances resulting in a "No
Inspection" occurring. In addition, a Compliance Assistance Activity Form will be
completed to account for the Compliance Assistance time spent on site with the
employer. A copy of the completed Compliance Assistance Activity Form must be
placed in the case file for future reference. Area Directors shall account for all
intervention activities by generating a report that lists the Compliance Assistance
Activity Form related to this Regional Emphasis Program.

XII. Outreach

All REPS must contain an outreach component that must be ongoing throughout the
effective period of the program. These outreach efforts should be coordinated with or
include the consultation program for that area. The method of outreach is at the
discretion of the respective Area Directors and can consist of one or more of the following
components.

1. Broadcast mail-outs, emails, or program information
2. Stakeholder meetings
3. Targeted training sessions
4. Presentations to the affected group(s)

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Before the Baton Rouge and Little Rock Area Offices may initiate enforcement under this
program, each will implement outreach programs supporting the goals of this program.
The outreach efforts should occur at least three months before the initiation of
inspections and continually after.

XIII. Evaluation

An evaluation of the program will be conducted midway through and at the completion
of the effective period that addresses whether the program advances OSHA’s goals and
initiatives and will include quantitative and qualitative measures.