OSHA's Top 10: An Analysis of the Most Cited Workplace Violations in 2019

OSHA’s Top 10: An Analysis
of the Most Cited Workplace
Violations in 2019
Mark Liffers, Practice Director – EHS Consulting
Triumvirate Environmental

Meet Your Moderator
2
Nita Vaidya

3
During this Webinar
✓ All lines will be muted.
✓ Communicate via the questions tab in your webinar panel.
✓ Unanswered questions will be responded to personally after the
webinar.
✓ Webinar recording and slides will be emailed to you tomorrow.

Mark Liffers
Practice Director – EHS Consulting
Triumvirate Environmental
4
Meet Your Presenter

What Can You Expect?
5
Overview of Current OSHA
“Top 10”
Insight on Most Common
Violations
Recommendations for
Avoiding Citations

Poll Question
How prepared are you for
your next OSHA
inspection?
6

Agenda
7
OSHA Update
OSHA’s Top 10
Strategies for Improving Your OSHA Programs
Summary
Q&A

OSHA Updates of Interest
• LOTO Update (Request for information)
▪ Safe use of control circuit type devices to control hazardous energy.
▪ Controlling hazardous energy from the use of robotics technology
• Harmonize Hazard Communication Standard (HCS) with latest edition of
the Globally Harmonized System of Classification and Labeling of
Chemicals (GHS).
▪ HCS is currently based on Revision 3 of the GHS, United Nations at Revision 7
8

OSHA Penalties
9
Type of Violation Penalty
Serious Other-Than-Serious
Posting Requirements
$13,260 per violation
Failure to Abate $13,260 per day beyond
the abatement date
Willful or Repeated $132,598 per violation
On Jan. 23, 2019, OSHA fines increased for the fourth straight year.
OSHA penalties went up by about 2% overall in order to
compensate for inflation.
States that operate their own Occupational Safety and Health Plans
are required to adopt maximum penalty levels that are at least as
effective as Federal OSHA's. https://ww.osha.gov/penalties/

OSHA Enforcement
• OSHA conducted 32,023 inspections in 2018
• (32,408 total inspections in 2017)
• 18,067 (about 56 percent) unprogrammed
inspections, includes employee complaints,
injuries/fatalities, and referrals.
• OSHA continues to devote considerable resources
responding to referrals and complaints
• OSHA issued 58,702 total violations in 2017 (last year
reported)
https://www.osha.gov/dep/2017_enforcement_summary.html
10

OSHA Budget
11
Federal OSHA has 10 regional offices and
85 local area offices.
OSHA budget
FY 2017: $552,787,000
FY 2018: $552,787,000
FY 2019: $557,787,000

OSHA Inspections
12
OSHA inspections
FY 2018 total federal inspections: 32,020
FY 2018 total State Plan inspections: 40,993

Workplace Fatalities
13
5,147 workers died on the job in 2017
3.5 per 100,000 full-time equivalent workers —
on average, more than 99 a week or more than
14 deaths every day.

“OSHA Fatal Four”
14
•Falls – 39.2%
•Struck by Object - 8.2%
•Electrocutions – 7.3%
•Caught-in/between* – 5.1%
*This category includes construction workers
killed when caught-in or compressed by
equipment or objects, and struck, caught, or
crushed in collapsing structure, equipment, or
material

Agenda
15
Regulatory Update
OSHA’s Top 10
Summary
Q&A

OSHA’s Top 10 for 2019
1. Fall Protection: General Requirements
2. Hazard Communication
3. Scaffolding
4. Lockout/Tagout
5. Respiratory Protection
6. Ladders
7. Powered Industrial Trucks
8. Fall Protection – Training Requirements
9. Machine Guarding
10. Personal Protective Equipment
16

Fall Protection – General
Requirements
(1926.501)
6,010 violations
17

Requirements
OSHA requires that fall protection be
provided at elevations of four feet in
general industry workplaces, six feet
in the construction industry.
18

Requirements
• 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
positioning and travel restraint systems
assisted-rescue and self-rescue
systems, subsystems and components
19

3. Scaffolding
4. Lockout/Tagout
6. Ladders
9. Machine Guarding
20

Hazard
Communication
21
(1910.1200)
3,671 violations

Hazard
Communication
22
Required 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
23
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 or warning, safety
data sheets, and employee
information and training will be met.

Hazard
Communication
24
• A list of the hazardous chemicals
known to be present using a product
identifier that is referenced on the
appropriate safety data sheet (that list
may be complied for the workplace as a
whole or for individual work areas); and
• The methods the employer will use to
inform employees of the hazardous 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

Hazard
Communication
25
• 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 that one
geographical location, the written
hazard communication program may be
kept at the primary workplace facility

3. Scaffolding
4. Lockout/Tagout
6. Ladders
9. Machine Guarding
26

Scaffolding
27
(1926.451)
2,813 violations

Scaffolding
28
Suspended Scaffolds

Scaffolding
29
Supported Scaffolds

3. Scaffolding
4. Lockout/Tagout
6. Ladders
9. Machine Guarding
31

Lockout/Tagout
(1910.147)
2,606 violations
32

Lockout/Tagout
• 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 established
minimum performance
requirements for the control of
such hazardous energy
33

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:
34

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
placement, removal and transfer of
lockout 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
35

3. Scaffolding
4. Lockout/Tagout
6. Ladders
9. Machine Guarding
36

Respiratory
Protection
(1910.134)
2,450 violations
37

Respiratory
Protection
• 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 protector program
• The program shall cover each employee
required by this section to use a
respirator
38

3. Scaffolding
4. Lockout/Tagout
6. Ladders
9. Machine Guarding
39

Ladders
(1926.1053)
2,345 violations
40

Ladders
Falls from portable ladders (step,
straight, combination, and
extension) are one of the leading
causes of occupational fatalities
and injuries
41

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
42

3. Scaffolding
4. Lockout/Tagout
6. Ladders
9. Machine Guarding
43

Powered Industrial
Trucks
(1910.178)
2,093 violations
44

Powered Industrial
Trucks
45
OSHA defines a powered
industrial truck as a mobile,
power-propelled truck used to
carry, push, pull, stack or tier
materials

Powered
Industrial Trucks
46
• Training program based on the general
principles for 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 one every three years

3. Scaffolding
4. Lockout/Tagout
6. Ladders
9. Machine Guarding
47

Fall Protection –
Training Requirements
(1926.503)
1,773 violations
48

Fall Protection –
Training Requirements
49
• Performance-based
• Use methods that are more
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

3. Scaffolding
4. Lockout/Tagout
6. Ladders
9. Machine Guarding
50

Machine
Guarding
(1910.212)
1,743 violations
51

Machine
Guarding
52
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
53
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.

3. Scaffolding
4. Lockout/Tagout
6. Ladders
9. Machine Guarding
54

Personal Protective
Equipment
(1926.102)
1,411 violations
55

PPE
56
1910.132(d)(2)
The employer shall verify that the required
workplace hazard assessment has been
performed through a written certification that
identifies:
• the workplace evaluated;
• the person certifying that the evaluation has
been performed;
• the date(s) of the hazard assessment; and,
• which identifies the document as a certification
of hazard assessment

PPE
• Employers are also required to
train each worker required to use
personal protective equipment to
know:
▪When it is necessary
▪What kind is necessary
▪How to properly put it on, adjust, wear
and take it off
▪The limitations of the equipment
▪Proper care, maintenance, useful life,
and disposal of the equipment
57

59
www.lni.wa.gov/safety-health/

Agenda
60
Regulatory Update
OSHA’s Top 10
Summary
Q&A

Improving OSHA Programs
Safety 101!
• Management sets safety policies and
procedures
• After employees are hired, they’re trained
on safe work practices and behaviors
• Supervisors watch workers or have them
watch each other to prevent unsafe
actions
• Inspections find safety problems which are
then corrected
61

Agenda
62
Regulatory Update
OSHA’s Top 10
Summary
Q&A

Summary
63
Regulatory rulemaking
Top 10 is consistent
Have a clear strategy!

Agenda
64
Regulatory Update
OSHA’s Top 10
Strategies for Improving Your OSHA programs
Summary
Q&A

THANK YOU!
Mark Liffers: mliffers@triumvirate.com

OSHA's Top 10: An Analysis of the Most Cited Workplace Violations in 2019

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