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10 insights into OSHA’s Top 10

Safety experts offer advice on the most cited violations

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It’s a December tradition for Safety+Health to present final numbers for OSHA’s Top 10 most cited violations for the recently concluded fiscal year.

But 2020 has been anything but traditional. At press time, S+H was continuing to coordinate with OSHA on the announcement of the agency’s Top 10 list for FY 2020, which ended Sept. 30.

Although the data isn’t yet available (we’ll keep you posted), the need to eliminate Top 10-related workplace hazards and stay in compliance with OSHA regulations continues. S+H turned to veteran safety consultants JoAnn Dankert and John Newquist, who offer 10 insights to help employers tackle OSHA’s Top 10.

1

Standard (lack of) deviation

Fall Protection – General Requirements (1926.501) has been OSHA’s most frequently cited standard for nine successive years, with the other standards that make up the rest of the list experiencing minimal change as well.

Why is the list so static?

“I think a portion of why we see these over and over again is there’s a lot of parts to many of the standards, which makes it easier for OSHA to cite us if we missed something, and some parts take time to implement,” said Dankert, senior safety consultant at the National Safety Council. “They aren’t necessarily bad, but they do take resources, and for smaller organizations, people might be doing HR and safety, or they’re doing facility maintenance and safety. Maybe they’re the person, the admin, that sits in the lobby and they’re trying to do safety on the side.”

Newquist, a former longtime OSHA employee, agrees that “nuances of the standard” contribute to more frequent citations. For example, the four most cited sections of the Hazard Communication Standard (1910.1200) – the second most cited standard in FY 2019 – require employers to develop or provide a written HazCom program, hazardous chemicals training, copies of mandatory Safety Data Sheets for each chemical and labeling for each chemical, respectively.

“If you have a lot of chemicals, it’s really hard to keep track of those,” Dankert said.

2

Building block

Employers should view the Top 10 list as a good starting point on the path to correcting hazards in their workplaces.

“Minimally,” Dankert said, “an employer should have the responsibility of asking, ‘Do any of these Top 10 affect me?’ Because this is the easiest place if our friends from OSHA should come to visit. Those are the gimmes, kind of. So if we wear respirators, do I have a strong respiratory protection program? Can I take a deep dive into it, make sure I have all the parts and pieces in place?

“‘Or if I use chemicals, like with HazCom, or if we use ladders?’ There’s no doubt that employers could use that listing as a way to just check themselves from an audit perspective.”

3

Trained and true

Many mainstays on the Top 10 list carry associated training requirements. As the pandemic impacts the economic climates of organizations nationwide, Dankert encourages employers to continue to make training a priority.

“When revenue goes down, organizations tend to sometimes pull back on training,” she said. “and so I would encourage people not to pull back on your safety training. With some things, we’re struggling within organizations because maybe we’ve done classroom training, but now because of physical distancing and so forth, we don’t want to put too many people in an area. That might mean we’ve got to have more classroom training sessions. That takes more time. Time is money. So I think just be cautious about deferring training too long or pulling back on your safety and health training.”

This is especially important for training related to hazard recognition and communication. Don’t leave these up to experience or perceived common sense, Dankert and Newquist say.

“Organizations maybe don’t want to get that technical about it, but we need a common understanding and agreement between employee and employer that, ‘Yeah, we don’t want those hazards, and if you see that, Mr. or Ms. Employee, tell us about it,’” Dankert said.

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