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Most Violated OSHA Standards: Analysis and Recommendations for 2017 Part I

OSHA StandardsEvery year, the Occupational Safety and Health Administration (OSHA) releases a list of the ten most frequently cited safety and health violations for the fiscal year (OSHA top 10), determined by inspections of workplaces reviewing OSHA standards. In September 2017, the preliminary list was released.

OSHA's top 10 is actually very consistent year after year, so we wanted to provide you with an analysis of the regulations and insight into the top 10 violations of OSHA standards. Read on for an analysis of the top five violations, and stay tuned for next week's blog to see the remaining five, as well as recommendations for avoiding OSHA citations and maintaining compliance!

1. Fall Protection: General Requirements (1926.501) - 6,072 Violations

OSHA requires that fall protection be provided at elevations of four feet in general industry workplaces, and six feet in the construction industry. Where we look for guidance in fall protection is the ANSI Z359 series of standards:

  • ANSI Z359.1 Safety requirements for personal fall arrest systems, subsystems, and components
  • ANSI Z359.2 Minimum requirements for a comprehensive managed fall protection program
  • ANSI Z359.3 Safety requirements for positioning and travel restraint systems
  • ANSI Z359.4 Safety requirements for assisted-rescue and self-rescue systems, subsystems, and components

2. Hazard Communication (1910.1200) - 4,176 Violations

Hazard communication 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 training.

To maintain compliance with hazard communication, employers must develop, implement, and maintain at each workplace, a written hazard communication program which describes how the criteria of this section for labels and other forms of warning, safety data sheets, and employee information and training will be met. Within this program, employers must:

  • Maintain lists of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas).
  • Explain the methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas.
The employer shall make the written hazard communication program available, upon request, to employees, their designated representatives, the Assistant Secretary, and the Director. Where employees must travel between workplaces during a work shift, i.e., their work is carried out at more than one geographical location, the written hazard communication program may be kept at the primary workplace facility.

3. Scaffolding (1926.451) - 3,288 Violations

Typically, scaffolding violations take place at construction sites. Under the OSHA rules for scaffolding, the following are included:

  • Staging
  • Suspended scaffolds (window washers)
  • Supported scaffolds - need to be designed by a qualified, competent person and then inspected, usually a professional engineer
  • Scissor lifts
  • Aerial lifts
Fatalities in these lifts are typically caused by: 
  • A person being ejected when in the bucket and elevated but not clipped in, and the vehicle is struck by another vehicle;
  • Uneven terrain and the lift tips over; or
  • Operation and high winds.

4. Respiratory Protection (1910.134) - 3,097 Violations

If an employer is providing respirators for employees:

  • The equipment must not be harmful to the worker.
  • These respirators need to be suitable for the purpose intended.
  • The employer shall be responsible for the establishment and maintenance of a respiratory protection program:
    • The program shall cover each employee required by this section to use a respirator.
    • A respiratory protection program coordinator must be assigned.
    • There must be a system to maintain respirators.
    • The employer must qualify and fit test employees.

5. Lockout/Tagout (1910.147) - 2,877 Violations

Lockout/Tagout is the standard that covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up 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.

Procedures shall be developed, documented, and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section. In addition, the procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, the following:

  • A specific statement of the intended use of the procedure;
  • Specific procedural steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy;
  • Specific procedural steps for the placement, removal, and transfer of lockout devices or tagout devices and the responsibility for them; and
  • Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.

Click here to see Part II, an analysis and recommendations for the other five top OSHA violations of 2017 (ladders, powered industrial trucks, machine guarding, fall protection - training requirements, and electrical - wiring methods).