1/6/2020

At the end of every year, the Occupational Safety and Health Administration (OSHA) announces the top ten categories for which organizations have received citations for violating certain safety and health regulations.  Over the years, one can see that, outside of a few changes, the top ten violations have remained quite consistent. Aside from lockout/tagout and respiratory protection switching positions (numbers 4 and 5, respectively), the list remains the same. Below is a brief description of the 2019 regulations which had the most violations.

1. Fall Protection General Requirements- (1926.501), 6,010 violations

This is the ninth year in a row this Construction standard has had the most OSHA violations. The specific non-compliance stemmed from unprotected sides or edges, fall protection for sloped roofs and workers not being protected from falling through a roof via structures like skylights are some primary places where employers are missing the mark.

2. Hazard Communication – (1910.1200), 3,671 violations

Problems that come up the most: No HAZCOM program, no worker training on HAZCOM and lack of safety data sheets (SDSs). Employers most cited: masonry contractors, painting and wall covering contractors, machine shops and general contractors.

3. Scaffolding- (1926.451), 2,813 violations

Where companies are going wrong: Using cross-braces as scaffold access, not fully planking, scaffolds not on firm foundations and no guardrails. Employers most cited: masonry contractors, roofing contractors and commercial builders.

4. Lockout/tagout- (1910.147), 2,606 violations

Companies cited do not have LOTO rules for specific machines, employees aren’t trained, there’s no periodic evaluation of the program and LOTO devices aren’t affixed. Among industries most cited: product manufacturing and sawmills.

5. Respiratory protection- (1910.134), 2,450 violations

Companies aren’t providing employees with a medical evaluation before they use respirators, they don’t have a respiratory protection program and employees don’t receive a fit test. Most cited: Auto maintenance, masonry contractors, cut stone contractors and painting and wall covering contractors.

6. Ladders, construction (29 CFR 1926.1053)

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.

7. Powered industrial trucks, general industry (29 CFR 1910.178)

Determining the best way to protect workers from injury largely depends on the type of truck operated and the worksite where it is being used. Employers must ensure that each operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in 29 CFR 1910.178(l)(1).

8. Fall Protection–Training Requirements (29 CFR 1926.503)

OSHA requires employers to:

• Provide working conditions that are free of known dangers.
• Keep floors in work areas in a clean and, so far as possible, a dry condition.
• Select and provide required personal protective equipment at no cost to workers.
• Train workers about job hazards in a language that they can understand.

9. Machinery and Machine Guarding, general requirements (29 CFR 1910.212)

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.

10. Eye and Face Protection (29 CFR 1926.102)

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.

The S&H profession embraces a “ZERO Accident” philosophy; a concept that professes all accidents are preventable. And while there may be certain cases where this concept can be debated, it certainly looks like any incident that was a direct result of the S&H infractions listed above, would qualify as being preventable.  

What could possibly be the explanation for the same S&H regulations being out-of-compliance on a regular basis? Could it be cost or time considerations? Or maybe these non-compliances are the result of an organizations’ lack of accountability; that is, management not having a commitment to worker S&H.  Maybe non-qualified individuals are being placed in the wrong positions (i.e. S&H managers, supervisors, etc.) while organizations are not providing the proper resources such as training (as noted for hazard communications, lockout/tagout, powered industrial trucks and fall protection) as well as not instituting appropriate controls, such as machine guarding (item #9) or proper materials for scaffolds and guardrails to prevent falls from heights (items #3 and #4).   

As members of TPMC, we should all feel confident that there is a management commitment to S&H and that a philosophy exists where if anyone sees something wrong, we have a voice to say something without a fear of retaliation. Throughout the years, we have encountered ergonomic issues as well as lacerations, contusions and even vehicular incidents. Fortunately, none have been serious. TPMC has a history of implementing appropriate controls – whether as a result of a corrective action or through proactive employee involvement where an unsafe scenario was identified.

In our S&H orientation for new hires, an important point is brought up. That is, the most valuable resource TPMC has is its employees. While any company can buy the latest equipment and hire persons with impressive qualifications, it is the quality of our employees that makes the difference. TPMC truly values its employees and will always be proactive to ensure our work is performed with a high level of quality while ensuring S&H is never compromised.  

Never feel hesitant to let someone know when you see something that doesn’t look right. You could be protecting the lives of your coworkers.

Here’s to a great 2020!

It is the set of the sails, not the direction of the wind that determines which way we will go

Jim Rohn (American author and entrepreneur)