OSHA Top Ten Violations: Are You on the List?

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Every year OSHA puts out their top ten list of violations that they have issued. For 2018, the list includes:

  1. Fall Protection – General Requirements (1926.501): 7,270 violations
  2. Hazard Communication (1910.1200): 4,552
  3. Scaffolding (1926.451): 3,336
  4. Respiratory Protection (1910.134): 3,118
  5. Lockout/Tagout (1910.147): 2,944
  6. Ladders (1926.1053): 2,812
  7. Powered Industrial Trucks (1910.178): 2,294
  8. Fall Protection – Training Requirements (1926.503): 1,982
  9. Machine Guarding (1910.212): 1,972
  10. Eye and Face Protection (1926.102): 1,536

It is important to note that this list always includes both OSHA 29 CFR 1926 Construction and OSHA 29 CFR 1910 General Industry standards. Also, the top five is the same as in 2017. But what can we learn from the list and how can it help employers improve their work sites?

As the National Safety Council President and CEO Deborah A.P. Hersman astutely points out, “Knowing how workers are hurt can go a long way toward keeping them safe.”

Patrick Kapust, deputy director of OSHA’s Directorate of Enforcement Programs agrees with this sentiment and echoed it during the 2018 National Safety Council Congress & Expo where he presented this preliminary data for OSHA’s Top 10 most-cited violations for the fiscal year 2018, which ended Sept. 30. “The Top 10 represents the most frequently cited standards, and they are a good place to start for the employer in identifying hazards in their own workplace.”

Now is a good time to check your job sites to see if training is up to date, signs are clearly marked and if personal protective equipment (PPE) should be upgraded and replaced. It might also be time to reevaluate how you approach thinking about safety culture. These are just a few things you can do to help ensure safe working conditions.

1. Fall Protection 1926.501

Fall Protection continues to be the number one most cited violation. The fall protection standard is designed to prevent falls, and according to statistics, these types of accidents account for almost 40 percent of all deaths in the construction industry. The sections of the fall protection standard that are most often cited for violations include residential construction, unprotected sides or edges, roofing work and floor holes including skylights.

OSHA has set requirements for employers to provide fall protection for their workers who are working on unstable surfaces or at work sites that have unprotected sides and edges. Employers can provide fall prevention training by a competent person or they may prefer that their workers complete construction training courses that cover fall hazards and prevention at different training centers. (Check out our blog breaking down competent person vs. authorized person.)

To prevent fall injuries and fatalities, employers are required to supply their workers with personal protective equipment which may include fall arrest systems, guardrails or safety net systems when they are working at height. In addition to just providing proper fall protection, employers are also responsible for ensuring that all employees are trained on how to properly use fall protection and know when to use it.

2. Hazard Communication 1910.1200

The Hazard Communication standard addresses chemical hazards produced or used in the workplace. OSHA’s standard for hazard communication is in line with the international standard but this is still a very often cited OSHA violation. The sections of the Hazard Communication standard that are most often cited for violations by OSHA include implementation of the HazCom program, training on hazardous materials and requirements to develop and maintain Safety Data Sheets (SDS).

3. Scaffolding 1926.451

The OSHA Scaffolding standard covers safety requirements for scaffolding, which should be designed by a qualified person and constructed in accordance with that design. The sections of the scaffolding standard that are most often cited for OSHA violations include fall protection involving guardrail systems, use of cross-braces for access and planking/decking.

Employers are required to protect all workers that use scaffolding from falls and falling objects. In addition, all scaffolds should be inspected by a competent person before use by the workers. The workers affected the most by scaffolding hazards include those in charge of framing, roofing, siding as well as masonry.

4. Respiratory Protection 1910.134

OSHA’s Respiratory Protection standard directs employers about how to establish and maintain a respiratory protection program (read: Tips on How to Write Your Respiratory Protection Story) in the workplace. All aspects of respiratory protection are covered in this standard including procedures, administration, selection, training, fit testing, evaluation, use, cleaning, maintenance and repair.

The sections of the Respiratory Protection standard that are most often cited for violations by OSHA include medical evaluations, respiratory protection requirements, fit testing, failure to establish a necessary respiratory protection program and identifying respiratory hazards in the workplace. Employers should check to see if their respiratory protection program complies with the requirements and make changes as necessary.

5. Lockout/Tagout 1910.147

Lockout/Tagout (LOTO) affects workers that service, repair and maintain equipment or machines. Hazards exist if the equipment being handled can suddenly become energized or started during work.

For companies that require LOTO procedures, these are the sections of the LOTO standard that OSHA has cited most often for violations: general procedures, energy control program, periodic inspections, and training.

To round out the Top 10 list, standards with the most cited OSHA violations in 2018 were:

6. Ladders 1926.1053
7. Powered Industrial Trucks 1910.178
8. Fall Protection – Training Requirements 1926.503
9. Machine Guarding 1910.212
10. Eye and Face Protection 1926.102

What is interesting about the rest of this list is that this is the first time that eye and face protection violations appear in the top ten. This underscores the importance of assessing your job site and asking yourself if you have the right PPE, safety equipment and signage at your worksite. Is everyone up to date with training to help prevent and protect one another? Have you considered ways to change workers’ approach to thinking about safety? Do you know the difference between fast and slow thinking? We can help. Contact us today and check back for more on this topic.