Last week, we published a blog that covered the latter half of OSHA's top ten most cited violations. This week, we look at the top 5 violations from the 2016 reporting year. OSHA issues violations and penalties not only to protect workers but to deter others from, unknowingly or not, allowing an unsafe working environment. As 2017 begins, it's a great time to evaluate any vulnerabilities in your workplace and conduct walkthroughs to ensure your work site does not have any violation worthy scenarios.
Total citations in 2016: 3,414 (increase of 412 from 2015)
At number five on the list of most violations, lockout tagout (LOTO) procedures are in place to protect workers servicing machines or equipment. Failure to properly lockdown a piece of equipment or execute a machine-specific LOTO procedure leaves those working on the machine dangerously exposed to the machine's energy. Energy should be kept isolated until all workers have completed their tasks and are safely away from the machine.
OSHA requires that there are written LOTO procedures in place for any machine that has two or more energy sources. Employers are also required to protect employees by:
- Creating and implementing an energy control program
- Using lockout devices, or tagout devices that meet the equivalent of employee lockout protection
- Ensure new equipment can be locked out
- Create a tagout program if a machine cannot be locked out (OSHA 2002)
4. Respiratory Protection
Total citations in 2016: 3,585 (increase of 280 from 2015)
Standard Number: 1910.134
Approximately 5 million workers are protected by respirators in the United States (OSHA Respiratory). Respiratory protection standards are in place to protect from harmful dust, insufficient breathable air, smokes, mists, gasses, vapors, and more. These hazards can cause long-lasting health consequences like cancer, diseases, or even death. Failure to comply with OSHA respiratory standard will not only lead to a costly violation, but could also result in harmful health effects for yourself or other workers.
OSHA standards mandate the following:
- Engineering controls limit the hazard
- Provide a respirator appropriate to the situation, either one that filters air or has its own source of breathable air
- Make sure the provided respirator is being used
- Enact a protection program that complies with respiratory standard (OSHA Respiratory eTool)
For more on respiratory protection and choosing a respirator for different environments, read our respiratory protection blog.
Total citations in 2016: 3,906 (decrease of 389 since 2015)
Standard Number: 1926.451
Approximately 65% of the construction industry works on scaffolds daily (OSHA Scaffolding). OSHA's Scaffolds standard is designed to make work safer for these 2.3 million workers. Similar to fall protection, scaffold protection is needed to protect workers from falling from a height, like a suspended or supported scaffold. Other hazards include electric shock, scaffold collapse, and falling objects.
After a scaffold is set up, it's up to trained workers to recognize and minimize hazards that arise. Each worker that will be around scaffolding should be trained on:
- Nature of any electrical hazards, fall hazards, and falling object hazards
- How to deal with electrical hazards that are identified
- How to set up, maintain, and dismantle fall protection and falling object protection systems
- Proper use of scaffold and handling material on scaffold
- Maximum load the scaffold can support (OSHA 1996)
2. Hazard Communication
Total citations in 2016: 5,677 (increase of 485 from 2015)
Standard Number: 1910.1200
Hazard Communication, commonly referred to as the "Right to Know", is a standard to educate employees about the chemicals and substances they are handling. Each and every person has the right to know what chemicals that are around them and the dangers of said chemicals. Companies failing to communicate hazards using OSHA guidelines results in the second place ranking.
A comprehensive hazard communication program should effectively communicate information to employees through container labeling, safety data sheets, and employee training. The six main categories of the Hazard Communication Standard are:
- Hazard classification
- A written hazard communication program
- Labels and other forms of warning
- Safety data sheets
- Employee information and training
- Trade secrets (OSHA 2016)
1. Fall Protection
Total citations in 2016: 6,929 (increase of 208 from 2015)
Standard Number: 1926.501
For the 6th straight year, fall protection leads the violation rankings in the top spot. Falls are the leading cause of deaths in construction, making up a third of all deaths within this industry (OSHA 2015). It's almost never just one thing that causes an incident, but a wide range of contributing factors leading to a violation or injury.
Fall protection guidelines vary depending on activity, but there are 3 main types of protection requirements:
- Safety Net
- Personal Fall Arrest System (PFAS).
You can learn more on this subject by reading OSHA's "Fall Protection in Construction" informational booklet. OSHA also recently released a Final Rule to update Fall Protection Standards. The rule allows employers to have more flexibility in deciding which fall protection system they use, with guardrails as the primary protection method.
Going into a new year is a perfect time to go above and beyond OSHA standards to ensure complete protection of your workers in the workplace. Review your accident records, consult your fellow workers, and perform a job hazard analysis on the jobs resulting in the most injuries, jobs with the potential for severe or fatal injury, or jobs complex enough to require a high level of awareness. Be aware of your site's vulnerabilities and be proactive to get them fixed. If you missed it, check out part one of OSHA's most cited violations of 2016, and don't forget to subscribe to our blog for more safety information and discussions.
OSHA (2015) Fall Protection in Construction. Retrieved from: https://www.osha.gov/Publications/OSHA3146.pdf
OSHA (2016) Hazard Communication. Retrieved from: https://www.osha.gov/Publications/OSHA3844.pdf
OSHA (2002) Lockout Tagout Fact Sheet. Retrieved from: https://www.osha.gov/OshDoc/data_General_Facts/factsheet-lockout-tagout.pdf
OSHA. Respiratory Protection. Retrieved from: https://www.osha.gov/SLTC/respiratoryprotection/index.html
OSHA. Respiratory Protection eTool. Retrieved from: https://www.osha.gov/SLTC/etools/respiratory/index.html
OSHA (1996) Safety and Health Regulations for Construction - Scaffolds. Retrieved from: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10755
OSHA. Scaffolding eTool. Retrieved from: https://www.osha.gov/SLTC/etools/scaffolding/index.html