What You Must Do to Address OSHA’s Annual Top 10 List of Most Frequent Violations

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Every year, OSHA publishes their Top 10 Most Frequently Cited Violations List, which showcases the most common issues OSHA inspectors find during their inspections. The latest report, which was reviewed during the National Safety Council’s 2022 Safety Congress & Expo in San Diego, CA covers the fiscal year of 2022 (October 1, 2021 – September 30, 2022). Generally, OSHA does not post this list until after the first week in April of each year, so as to allow the prior fiscal year’s inspection data to finalize past the close of the fiscal year (September 30th of each year). So, keep an eye out for the finalized 2022 list in early 2023.

The ultimate goal for OSHA is to educate in order to eliminate accidents resulting in injuries or even deaths, which are preventable if the right measures are put in place and proper procedures are followed.

Here’s where OSHA found the most violations during the fiscal year 2022: 

  1. Fall Protection - General (29 CFR 1926.501) with 5,260 total violations

According to OSHA: “Falls are among the most common causes of serious work-related injuries and deaths. Employers must set up the workplace to prevent employees from falling off of overhead platforms, elevated workstations or into holes in the floor and walls.”

Informative link:  https://www.osha.gov/fall-protection

  1. Hazard Communication Standard (29 CFR 1910.1200) with 2,424 total violations

 According to OSHA: “In order to ensure chemical safety in the workplace, information about the identities and hazards of the chemicals must be available and understandable to workers. OSHA's Hazard Communication Standard (HCS) requires the development and dissemination of such information:

·        Chemical manufacturers and importers are required to evaluate the hazards of the chemicals they produce or import, and prepare labels and safety data sheets to convey the hazard information to their downstream customers;

·        All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers and train them to handle the chemicals appropriately.”

Informative link: https://www.osha.gov/hazcom

  1. Respiratory Protection (29 CFR 1910.134) with 2,185 total violations

According to OSHA: “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 shall be used [by employees] pursuant to this section.”

Informative link: https://www.osha.gov/respiratory-protection

  1. Ladders (29 CFR 1926.1053) with 2,143 total violations

Falls from ladders are a leading cause of death and injury in the workplace.  Workers must be protected from falling when they use fixed or portable ladders, as well as mobile ladder stands and platforms.  

Informative link: https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.1053

  1. Scaffolding (29 CFR 1926.451) with 2,058 violations

A scaffold is an elevated, temporary work platform. Different types of scaffolds come with different hazards and protective measures, and it is important to know what kind of scaffold you are using and how to safely use it in order to avoid any potential accidents related to scaffolds in work environments.

Informative link: https://www.osha.gov/scaffolding 

  1. Lockout/Tagout (Control of Hazardous Energy) (29 CFR 1910.147) with 1,977 total     violations

When a machine is opened for maintenance or repair, workers may be exposed to hazards that are normally enclosed and contained.  It is important to protect workers by locking and tagging all energy sources out of service prior to beginning a task in order to protect workers from exposure to potentially hazardous issues.  According to OSHA: “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.”

Informative link: https://www.osha.gov/control-hazardous-energy 

  1. Powered Industrial Trucks (29 CFR 1910.178) with 1,749 total violations

All powered industrial trucks carry risks of collisions, tip overs, falling loads, and fire/explosion hazards. According to OSHA: “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.”

Informative link:  https://www.osha.gov/powered-industrial-trucks

  1. Fall Protection – Training Requirements (29 CFR 1926.503) with 1,556 total     violations

Training and refresher training are often the most overlooked issues in safety programs. According to OSHA: “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.”

Informative link: https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.503 

  1. Eye and Face Protection (29 CFR 1926.102) with 1,401 total violations

According to OSHA: “Thousands of people are blinded each year from work-related eye injuries that could have been prevented with the proper selection and use of eye and face protection. OSHA requires employers to ensure the safety of all employees in the work environment. Eye and face protection must be provided whenever necessary to protect against chemical, environmental, radiological, or mechanical irritants and hazards.”

Informative link: https://www.osha.gov/eye-face-protection 

  1. Machinery and Machine Guarding (29 CFR 1910.212) with 1,370 total violations

One of the leading causes of accidents involving amputations is in adequately guarded machinery. According to OSHA: “Moving machine parts have the potential to cause severe workplace injuries, such as crushed fingers or hands, amputations, burns, or blindness. Safeguards are essential for protecting workers from these preventable injuries. Any machine part, function, or process that may cause injury must be safeguarded. When the operation of a machine or accidental contact injure the operator or others in the vicinity, the hazards must be eliminated or controlled.”

Informative link: https://www.osha.gov/machine-guarding

You can find the list, along with links to the specific regulations and other relevant guidance documents for preventing incidents and staying in compliance on OSHA’s website: www.OSHA.gov 

Not only does this list keep us informed of ongoing trends in the world of environmental, health and safety, but it can also act as a guide for a starting point for OSHA compliance.   

As you get caught up in the day-to-day of your job, it’s easy to miss or overlook certain environmental, health and safety issues, especially those that have become “Invisible Environmental Gorillas” due to familiarity blindness. Simply put, things you see every day are often overlooked and become “just the way things are.” But a fresh set of eyes or a renewed emphasis, such as that which comes with this annual OSHA list, can help you spot them. 

The OSHA top 10 list reminds us of common potential workplace hazards that we should double-check to keep our workers and ourselves safe. As we all know, there are many, many OSHA regulations, and they can be complicated. And it’s hard to keep up with the constant tweaks and changes that impact your specific industry.

That’s one reason this Top 10 Most Frequently Cited Violations List can be so useful. It helps you focus on the most common issues you should be aware of at your facility. 

In fact, I recommend using the publication of OSHA’s latest top 10 list as an opportunity to do a thorough check of your facility to see if any of the identified 10 issues are found there.

You should check not only your buildings and equipment but also processes and procedures and employee safety measures. It might be that safety training has to be reinforced, for example, or a manufacturing process must be altered. Get your team involved. Show them the list and have them go over their workstations, safety routines, and more.

Make the necessary fixes. Then make sure all your employees- and management - understand how to stay in compliance.

As the agency puts it: “OSHA publishes this list to alert employers about these commonly cited standards, so they can take steps to find and fix recognized hazards addressed in these and other standards before OSHA shows up. Far too many preventable injuries and illnesses occur in the workplace.”

It’s easy enough to just go down the list… and by taking that time now, you can avoid expensive, dangerous, maybe even deadly, consequences down the road. You should know that many of these issues are easy and inexpensive to address. Also, this OSHA list is usually very similar year-to-year, with some of the hazards switching ranking spots, but most of the same issues remain in the top 10.

That means addressing these issues now will pay off in dividends for years into the future.

Also, keep in mind that regulators at the federal, state, and local levels all use the OSHA list as a guide when inspecting facilities. They have limited time, so these are the issues they look for first. And if they find violations of the most common issues, that’s usually cause for them to conduct a more thorough investigation.

After all, if your facility has these common issues, they feel it’s likely there are other issues under the surface to be found.

But pass this test… and they are less likely to continue to dig deeper for other issues during inspections.

I always tell people that regulators can be your friend. They really don’t want to be out there issuing fines and penalties. They have a focus on education and helping companies to be proactive in preventing enforcement actions - but most importantly eliminating accidents and other incidents.

That’s why OSHA puts out their annual top 10 list - and why they’re happy to answer questions or guide you in how to comply with regulations. Not to mention why they publish thousands of guidance documents and videos each year to help companies stay in compliance.

I’m happy to discuss OSHA’s Top 10 Most Frequently Cited Violations List with you, especially if you’re dealing with any potential compliance issues or have specific safety concerns. Just call me, Mark Roman, at 609-208-1885 or reach out via e-mail to markroman@envisionenvironmental.com

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