OSHA's Top 10: An Analysis of the Most Cited Workplace Violations in 2017

OSHA’s Top 10
An Analysis of the Most Cited
Workplace Violations in 2017

Meet Your Moderator:
James Ciccone

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Webinar Overview

Meet Your Presenter
Mark Liffers
Practice Director – EHS
Consulting
mliffers@triumvirate.com

What Can You Expect?
Overview of Current
“Top 10”
Insight on Most
Common Violations
Recommendations for
Avoiding Citations

Poll Question
How prepared are
you for your next
OSHA inspection?

Agenda
OSHA Update
OSHA’s Top 10
Strategies for Improving Your OSHA programs
Summary/Q&A

• May 11, 2016 Final Rule
• Establishments with 20-249 employees in certain high-risk industries
must submit information from their 2016 Form 300A by July 1, 2017*,
and their 2017 Form 300A by July 1, 2018.
• Beginning in 2019 and every year thereafter, the information must be
submitted by March 2.
• *OSHA published a notice of proposed rulemaking on June 27, 2017 to
extend the date by which employers are required to submit the
information from July 1, 2017 to December 1, 2017.
Electronic Reporting Delayed

• President Trump signed the Volks Rule Congressional Review Act
authorization directing that this regulation issued in 2016 be expunged on
April 3, 2017.
• Finalized Dec 19, 2016 the “Volks Rule” was issued to allow OSHA to cite
employers for failure to record an injury or illness for up to six months
following the five-year record retention period that would have applied to
such a record had it been made in the first place
• The language of the OSH Act provides that OSHA cannot cite an employer
“after the expiration of six months following the occurrence of any
violation”.
• OSHA is again prohibited from issuing citations for injury or illness record-
keeping violations outside the OSH Act’s six-month statute of limitations.
Volks Rule Repealed

Moved to ‘long-term’ actions:
• Updates to a host of chemical exposure
permissible exposure limits
• Hearing protection for construction
workers
• Vehicle backing hazards in general
industry and construction
OSHA Rulemaking

Indefinitely delayed:
• Reforms to the process safety management
standard developed in response to the 2013
fertilizer plant explosion in West, Texas
• A new regulation addressing emergency
response and preparedness
• A new standard to address infectious diseases
in health care
OSHA Rulemaking

Rulemaking that remains active:
• A new standard addressing
communications tower safety
• An update to the powered industrial
truck standard
• An amendment to the regulation for
mechanical power presses
OSHA Rulemaking

Type of Violation Penalty
Serious
Other-Than-Serious
Posting Requirements
$12,675 per violation
Failure to Abate $12,675 per day beyond the
abatement date
Willful or Repeated $126,749 per violation
https://www.osha.gov/penalties/
OSHA Penalties

OSHA Enforcement
OSHA conducted 31,948 total inspections in 2016
19,217 inspections were unprogrammed
OSHA issued 58,702 total violations
https://www.osha.gov/dep/2016_enforcement_summary.html

OSHA’s Top 10 for 2017
1. Fall Protection – General Requirements
2. Hazard Communication
3. Scaffolding
4. Respiratory Protection
5. Lockout/Tagout
6. Ladders
7. Powered Industrial Trucks
8. Machine Guarding
9. Fall Protection – Training Requirements
10. Electrical – Wiring Methods

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, six feet
in the construction industry.
Fall Protection –
General Requirements

Fall Protection
• ANSI Z359 fall protection 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

Hazard
Communication
(1910.1200)
4,176 violations

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 and
training.
Hazard
Communication

Hazard Communication
Plan Content
Employers shall develop, implement, and
maintain at each workplace, a written hazard
communication program which at least
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.

• A list 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); and,
• 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.
Plan Content

• 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.
Plan Content

Scaffolding
(1926.451)
3,288 violations

Suspended Scaffolds
Scaffolding

Supported Scaffolds
Scaffolding

Respiratory
Protection
(1910.134)
3,097 violations

Respiratory
Protection Plan
• A respirator shall be provided to each employee when such
equipment is necessary to protect the health of such employee.
• The employer shall provide the respirators which are applicable
and 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.

Lockout/Tagout
(1910.147)
2,877 violations

• This standard 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.
Lockout/Tagout

• 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.
• 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:
Lockout/Tagout

• 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.
Lockout/Tagout

Ladders
(1926.1053)
2,241 violations

Falls from portable ladders (step,
straight, combination and
extension) are one of the leading
causes of occupational fatalities
and injuries
Ladders

29 CFR 1910.23
• In late 2016, OSHA published an update to
its walking-working surface rules for
general industry.
• As part of the update, OSHA combined its
previously separate regulations for
portable wood ladders, portable metal
ladders and fixed ladders under one
comprehensive ladder standard.
Ladders

(1910.178)
2,162 violations
Powered Industrial
Trucks

Powered Industrial
Trucks
(OSHA) defines a powered
industrial truck as a mobile,
power-propelled truck used
to carry, push, pull, lift,
stack or tier materials.

• Training program based on the general principles of safe truck operation, the
types of vehicle(s) being used and the hazards they create
• Trained operators must know how to do the job properly and safely, as
demonstrated by workplace evaluations.
• Formal (classroom, lecture) training
• Practical (demonstration and practical exercises) training
• Employers must also certify that each operator has received the training and
evaluate each operator’s performance at least once every three years.
Powered Industrial Trucks

Machine Guarding
(1910.212)
1,933 violations

Machine Guarding
Amputations are among the most
severe and disabling
workplace injuries that often
result in permanent disability.
They are widespread and involve
various activities and equipment.

Machine Guarding
ANSI B11 series of American
National Standards and Technical
Reports consists of nearly three
dozen different documents that deal
with machine / machinery / machine
tool safety, and they specify
requirements for both the
manufacturers (suppliers) and users
of the machines.

Fall Protection – Training
Requirements
(1926.503)
1,523 violations

Fall Protection – Training
Requirements
• Performance-based, use methods that are most effective.
• Classroom, audio-visual, demonstrations, field training, web-based,
computer-based or other forms of training
• Training must be performed by a qualified person and if web, video or
computer-based methods are used, a qualified person must be available to
answer questions.

Electrical – Wiring
Methods
(1910.305)
1,405 violations

NFPA 70:
National Electrical Code (NEC)
Electrical – Wiring
Methods

Improving OSHA Programs
Safety 101 - Simple?
• Management sets safety policies and procedures.
• After employees are hired, they're trained on safe
work practices.
• Supervisors watch workers or have them watch
each other to prevent unsafe actions.
• Inspections find safety problems which are then
corrected.

Summary
OSHA Rulemaking
Top 10 is Consistent
Have a Clear Strategy!

Thank You For
Attending!
Request a Free Program Review:
http://info.triumvirate.com/free-
osha-program-review
Call Us!
1-888-834-9697
www.triumvirate.com
Contact Mark Liffers:
mliffers@triumvirate.com

OSHA's Top 10: An Analysis of the Most Cited Workplace Violations in 2017

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