Protecting Workers from OSHA’s Top Ten Commonly Cited Regulations
Occupational Safety and Health Administration (OSHA) released its official citation data for the fiscal year 2019 and it certainly seems to be ringing some bells from last year’s list:
OSHA believes that the reason the Top 10 Most Cited Violations stayed the same is because “Employers are not aggressively targeting these hazards at their worksites.” (Patrick Kapust: Deputy Director of OSHA’s Directorate of Enforcement Programs). Here are some valuable tips on how to avoid some of the most commonly cited hazards from occurring in your workplace. Following these tips will not only keep your workers safe and improve your safety culture, but will also help avoid the chance of being cited with a hefty fine this New Year.
1. Fall Protection- General Requirements (1926.501)
Be sure to protect employees performing construction related activities that are exposed to falls from height 6 feet (4 feet for general industry tasks) or more with guardrail systems, safety net systems, or personal fall arrest systems. Common areas where OSHA identifies these hazards are, residential construction, unguarded edges on low sloped roofs, and holes and floor openings.
2. Hazard Communication (1910.1200)
If your workplace produces chemicals, imports chemicals, or works with hazardous chemicals within the workplace, a written hazard communication program must be in place. Common areas where OSHA identifies gaps in compliance are, training employees on the specific chemical hazards in the workplace, having Globally Harmonized System (GHS) labelling, and maintaining SDS sheets.
3. Scaffolding (1926.451)
Be sure to provide fall protection for employees on scaffolds higher than 10 feet. When scaffold platforms are 2 feet above or below an access point, they must be equipped with either: portable ladders, hook-on ladders, attachable ladders, stair towers, stairway type ladders, ramps walkways, integral prefabricated scaffold access or direct access from another scaffold, structure, personnel hoist or similar surface must be used. Common areas where OSHA identifies citations are where employees use cross braces as means of access.
4. Lockout/Tagout ( 1910.147)
Be sure to have documented energy control procedures on site. Common areas where OSHA identifies these hazards are missing training, periodic inspections and written program documentation.
5. Respiratory Protection (1910.134)
Be sure to provide air sampling/monitoring to determine if your employees are being exposed to chemicals that would require them to wear respiratory protection. If it is determined that employees need to wear respiratory protection, then they must be seen by a Physician or other licensed health care professional (PLHCP) before they can perform any job duties to determine if they are physically fit to perform work while wearing a respirator. Common citations given by OSHA are for not allowing the employee to go to a PLHCP during their normal work shift, for not providing the employee with proper training on how to wear, clean and maintain their respirator, and training on how to recognize signs of potential exposure.
Only use ladders for their intended purpose and design, do not use them for alternative purposes (i.e., scaffolding). Ladders with physical defects must be tagged out of service and new equipment must be ordered or the defective piece must be sent back to the manufacturer for repairs. In-house repairs may not be substituted for manufacturer repairs. OSHA commonly cites for the following hazards: Portable ladders not extending 3 feet above the upper landing surface. Ladders not secured at its top to a rigid support. Using the top step of the ladder as a step. Ladders can only be used on flat stable surfaces.
7. Powered Industrialized Trucks
Make sure you have a powered industrial truck training program in place. OSHA commonly cites for: missing training records and certifications, not providing both written and practical training, missing documentation for pre inspections.
8. Fall Protection-Training Requirements
Employers must give each employee who has the potential of being exposed to falls a comprehensive training program that will teach employees how to recognize the hazards of falling and how to minimize those hazards. OSHA commonly cites those missing: training given by a qualified competent person, written certifications that each employee has received training with the date and the signature of the specific person who performed the training, not performing retraining when an affected employee requires it.
9. Machine Guarding
When there is exposure to ingoing nip points, rotating parts, flying chips, and sparks then machine guarding needs to be put into place to protect employees. Common citations are due to: fixed machines not being anchored down, blades of fans not being guarded when there’s less than 7 feet between floor and working surface.
10. Personal Protective Equipment
Employers must provide most PPE to employees free of charge. Common citations given by OSHA are: not providing employees with eye glass prescriptions with proper eye protection, no training provided to the employee on how to properly wear, store, clean and maintain the PPE, if PPE is in poor unwearable /unusable conditions.
The violations noted above only reflect the most common OSHA citations. There is a host of general industry regulations that are required by OSHA that companies must also comply with to ensure compliance. CAPACCIO can assist with these top ten violations and go beyond by performing compliance audits or on-site inspections, providing written or site-specific recommendations, or creating training programs based on your specific needs. We can also tailor programs to include on-site assistance at an interval that works for you. Any of these solutions coupled with our EHS Dashboard™ cloud-based software can provide a winning combination for your organization as it helps ensure compliance dates are being met, tracks records and documentation, maintains accident and injury data, and much more.
If you would like to do a “quick check” of the OSHA general industry regulations which may apply to your organization (beyond the top ten noted in this article) and where your organization stands, download our OSHA Compliance Quick Checklist:
At CAPACCIO, we live our mission of "Helping Industry and the Environment Prosper". We align EHS with your overall business objectives to strategically position you for success. Our unique approach combines our extensive EHS experience with innovative tools, such as our EHS Dashboard™, to effectively address your challenges. Our comprehensive solutions have resulted in award-winning EHS and overall business performance for our clients. We are certified WBENC, WBE. To learn more visit us at www.capaccio.com.