Is Something at Your Facility on the List?
I have a lot of respect for regulators at all levels, local, state, and federal. It sometimes surprises people that they are very often willing to work with facilities to improve their environmental, health and safety practices and address exposures.
Regulators don’t issue fines and other penalties for fun. They’d rather not do it. So they’re willing to answer questions and educate companies on best practices, how to comply with regulations, and more.
OSHA is probably the best in this regard. They have a very diverse – numerous – group of rules and regulations. OSHA regulations can get complicated and you don’t have time to keep up with everything.
OSHA recognizes this – that’s why they publish thousands of guidance documents and videos to help you manage compliance with their rules and regulations.
Of all the material that OSHA releases, my favorite, and the first one you should take a close look at before anything else, is its annual Top 10 Most Frequently Cited Standards List, which comes out every year around October/November.
Their goal is to prevent accidents, and the resulting injuries and illnesses, that should be totally preventable if the right measures are put in place and proper procedures followed.
It’s a handy guide for examining your facility to see where you might fall short in key areas with regards to the most commonly observed violations of workplace safety. Also included in that report are recommendations for dealing with them and getting into compliance.
As Patrick Kapust, deputy director of OSHA’s Directorate of Enforcement Programs, said at an industry event when presenting the list:
“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."
Oddly enough, these are issues that are relatively easy and inexpensive to address. Below is the list from 2018, with the applicable regulation and number of violations issued, as well as a quick summary of what it entails.
Keep an eye out for the updated list for 2019 a few months from now.
Many issues carry over from year to year. In fact, the top five have remained unchanged for the last four years.
1. Fall Protection, Construction – 29 CFR 1926.501 (7,270 violations)
“The employer shall determine if the walking/working surfaces on which its employees are to work have the strength and structural integrity to support employees safely.”
2. Hazard Communication Standard, General Industry – 29 CFR 1910.1200 (4,552 violations)
“This section requires chemical manufacturers or importers to classify the hazards of chemicals which they produce or import, and all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets, and information and training.”
3. Scaffolding, General Requirements, Construction – 29 CFR 1926.451 (3,336 violations)
“Each scaffold and scaffold component shall be capable of supporting, without failure, its own weight and at least 4 times the maximum intended load applied or transmitted to it.”
4. Respiratory Protection, General Industry – 29 CFR 1910.134 (3,118 violations)
“In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smoke, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators [by employees] shall be used pursuant to this section.”
5. Control of Hazardous Energy (Lockout/Tagout), General Industry – 29 CFR 1910.147 (2,944 violations)
“This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy, could harm employees. This standard establishes minimum performance requirements for the control of such hazardous energy.”
6. Ladders, Construction – 29 CFR 1926.1053 (2,812 violations)
There are different standards for fixed ladders, as well as self-supporting and non-self-supporting portable ladders, regarding the amount of weight, how far apart rungs can be, and more.
7. Powered Industrial Trucks, General Industry – 29 CFR 1910.178 (2,294 violations)
“This section contains safety requirements relating to fire protection, design, maintenance, and use of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines. This section does not apply to compressed air or nonflammable compressed gas-operated industrial trucks, nor to farm vehicles, nor to vehicles intended primarily for earth moving or over-the-road hauling.”
8. Fall Protection, Training Requirements – 29 CFR 1926.503 (1,982 violations)
“The employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards.”
9. Machinery and Machine-Guarding, General Requirements – 29 CFR 1910.212 (1,972 violations)
“One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are: barrier guards, two-hand tripping devices, electronic safety devices, etc.”
10. Eye and Face Protection – 29 CFR 1926.102 (1,536 violations)
“The employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.”
Something to keep in mind is that OSHA inspectors are busy, with limited time, and they often focus on the items on this list when inspecting your facility. So by simply taking care of these 10 issues, which is a must with your own busy schedule, you’ll often find that your inspections will go a bit easier.
On the flipside, if they find many of these workplace safety guidelines not being followed, they’ll “roll up their sleeves” and examine your whole facility with a fine-tooth comb.
So it pays to do a thorough once over of your facility armed with this list now. Get your team on-board to find problem areas in workstations, work practices, or areas of your facility.
Then make changes. But your work doesn’t stop there. You should also make sure your entire team understands these common violations and how to stay in compliance. This might require some additional training to further educate your facility.
This process takes a while on the first go-around. But it gets easier and easier each time you do it. You might even be covering many of these bases already.
Lastly, this isn’t a one and done situation. Keep this list handy and make it routine to go over it at least once a month to see if any issues have crept back in. And be sure to also post it in a prominent place at your facility. You should also make it part of your on-boarding process for new hires.
To make sure what’s on OSHA’s radar is always top of mind for you and your team, download this free OSHA’s Top 10 Most Frequently Cited Standards at a Glance Checklist.