Every year OSHA publishes the most cited safety violations given to employers, and from year to year the list of the top ten doesn’t change very much! The most cited violations in 2012 were as follows
1. Fall Protection
2. Hazard Communications
4. Respiratory Protection
6. Machine Guarding
7. Powered Industrial Trucks (Forklifts)
8. Electrical – Wiring Methods
9. Lock Out / Tag Out
10. Electrical General
The reason for OSHA’s concern over these specific hazards is due to the severity of injuries that occur when employees are exposed to them. Falls, as an example is the leading cause of fatality in the construction industry so it’s no surprise that failing to maintain proper fall protection, scaffolding, and ladders are all in the top five! Given the peculiar labor laws in New York, employers need to give extra special attention to any employee working at height to avoid potentially expensive litigation.
Hazardous communications deals with hazardous chemicals found or brought into the workplace, common citations include not having the proper Material Safety Data Sheets properly displayed and improper handling/storage of chemicals.
Lock Out / Tag Out is of course a written program to control hazardous energy while servicing or maintaining machines and equipment in the work place. As part of your company’s safety manual there should be a section on Lock Out / Tag Out and it should be re-visited on a regularly scheduled training basis – especially for new hires during orientation periods. Too many worker injuries result from failing to de-energize machinery prior to cleaning or repairing or thinking that a quick fix won’t require a whole tag out procedure of walking across the plant to the electrical panel or going to the maintenance supervisor for a lock….. it could be laziness, or complacency, but it’s really unacceptable when the risks are so high for injury. Proper training, documentation and resources such as tag and lock kits help avoid serious injuries as well as OSHA penalties.
Machine Guarding – it may come as a surprise that guarding continues to be a hazard in the workplace, but it is for a variety of reasons. What we see typically happening with guarding is that guards are removed for servicing or cleaning of machinery and moving parts, and when the assembly line or machine is put back into service, the guards are left off. Usually in my inspections with client locations, it’s guarding is not removed intentionally or maliciously, so it is critically important to have line managers or department managers regularly inspect machines for all proper guarding. Whether this is daily or weekly this is both an easy solution to avoid employee injuries as well as potential OSHA fines or penalties.
Electrical issues are another situation which can be resolved through a regular inspection process by department or line managers. We recommend that the manager of a department or area of your plant not inspect his or her own area, but inspect another area of the plant and vice-versa. When you work and live in one area of a plant, warehouse, or operation it’s easy to have “complacent eyes” – you don’t see the violations as violations because you’ve grown accustom or complacent to the hazard, so having “fresh eyes” perform the inspection will increase the likelihood that potential hazards are spotted and marked for correction. Common violations include use of extension cords where permanent wiring should be deployed, questionable wiring in wet locations, and questionable wiring connections.
So here you have a quick rundown of the areas that OSHA is most commonly citing employers for violating standards and potentially putting employees at risk of injury. What areas in your company need improvement? Do you have a process to identify potential areas of risk for violations? Have you ever conducted a Mock OSHA inspection?
The OSHA.gov website has a lot of resources and training materials available, as well as the voluntary inspection program for an inspector to come on your premises to conduct an inspection – any violations found under this process will not be levied a fine, but must be corrected or a fine will be levied on a follow up inspection.
by Gordon B. Coyle