On Safety

On Safety: A closer look at OSHA’s ‘Top 10’ violations – Part I

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As part of the annual National Safety Council Safety Congress & Expo, OSHA presents its Top 10 most cited violations for each fiscal year. The data is interesting but can be confusing, as the information presented often combines general industry with construction. The Top 10 violations in this case tends to be dominated by fall hazards from construction.

This blog post is the first in a series that looks at OSHA data and the top violations, broken down first by major industry (manufacturing, construction and maritime) and followed by data from industries listed in the North American Industry Classification System codes. Before looking at the OSHA Top 10, it might be of interest to see a breakdown of agency data by inspection type, comparing fiscal year 2019 with FY 2020.

Fiscal year 2019 OSHA inspections Fiscal year 2020 OSHA inspections
Total health inspections 5,511 Total health inspections 4,119
Total safety inspections 27,890 Total safety inspections 17,561
Total 33,401 Total 21,680
Unprogrammed inspections
Complaints 7,408 Complaints 2,178
Fatality/catastrophe 929 Fatality/catastrophe 1,502
Referrals 3,147 Referrals 2,178
Planned or targeted
Health 1,245 Health 689
Safety 11,794 Safety 7,051
Total 13,309 Total 7,740
Construction
Health 933 Health 493
Safety 16,567 Safety 10,582
Total 17,500 Total 11,075
Manufacturing
Health 2,098 Health 1,396
Safety 4,948 Safety 2,972
Total 7,046 Total 4,368

Note: The data includes broad categories of OSHA inspections and does not include smaller categories such as program related or federal agencies.

Of interest in this table is the decline in the number of inspections in FY 2020 from FY 2019. In FY 2019, OSHA conducted a total on 33,401 inspections – an increase over its totals from the previous few years. The number of inspections in FY 2020 dropped to 21,680 – a decrease of 35%. However, the percentage of inspections in each category remained approximately the same. For example, in FY 2019, 52% of all inspections were in construction and, in FY 2020, 51% of all inspections were in construction. The decline in FY 2020 is likely because of the COVID-19 pandemic.

Next, we turn to the OSHA Top 10 for manufacturing, construction and maritime for FY 2020. For manufacturing:

Rank OSHA standard No. of violations Standard description
1 1910.1200(e)(1) 353 Written hazard communication program
2 1910.134(e)(1) 312 Respirator medical evaluation
3 Section 5(a)(1) OSH Act 283 General Duty Clause
4 1910.1200(h)(1) 259 Hazard Communication information and training
5 1910.134(f)(2) 257 Respirator fit testing
6 1904.39(a)(2) 212 Reporting a hospitalization within 24 hours
7 1910.134(c)(1) 210 Written respiratory program
8 1910.28(b)(1) 150 Protection from fall hazards – sides and edges
9 1910.303(g)(1) 150 Working space around electrical equipment
10 1910.37(a)(3) 142 Unobstructed exit routes

Note: 1904.39(a)(1), which requires reporting a fatality within eight hours, was cited 124 times.

In FY 2020, OSHA issued a total of 9,744 violations in manufacturing.

For construction:

Rank OSHA standard No. of violations Standard description
1 1926.501(b)(13) 3,028 Residential construction, fall protection, use of guard rails, netting or personal protective equipment
2 1926.102(a)(1) 1,227 Eye and face protection
3 1926.1053(b)(1) 1,034 Portable ladders
4 1926.503(a)(1) 949 Fall protection training
5 1926.501(b)(1) 676 Fall protection, unprotected sides and edges
6 1926.100(a) 673 Head protection
7 1926.451(g)(1) 533 Fall protection – scaffolding
8 1926.453(b)(3) 467 Fall protection – aerial lifts
9 1926.21(b)(2) 388 Employer training of employees on unsafe conditions
10 1926.20(b)(1) 369 Employer maintaining an incident prevention program

Employee protection in excavations (1926.652(a)(1)) was cited 350 times. Not having an incident prevention program (1926.20(b)(1)) was cited 339 times. When looking at both 1926.20(b)(1) and (b)(2), they were cited by OSHA for a combined 708 violations. In FY 2020, OSHA issued a total of 20,377 violations in construction.

The violation data for maritime – including shipyards, ship breaking, marine terminal and longshoring – was pretty weak for FY 2020. OSHA conducted 211 inspections with a total of 383 violations. Of the maritime standards cited, all showed a total violation count of fewer than 10 violations, except for 1910.303(g)(1), which had 14 total violations for inadequate space surrounding electrical equipment.

Part II of this series will include the top violations for FY 2020 in health care, warehousing and meat processing – all of which are focus areas of OSHA’s National Emphasis Program for employee exposure to COVID-19.

This article represents the views of the authors and should not be construed as a National Safety Council endorsement.

Richard Fairfax (CIH, retired 2017) joined OSHA in January 1978 and retired from the agency in 2013. At OSHA, he was a practicing field industrial hygienist, as well as the deputy director and director of enforcement programs. In 2008, Richard served as acting director of construction and, in 2010, was designated deputy assistant secretary – overseeing all field, enforcement and training operations. From 1993 through 2010, Richard wrote an industrial hygiene column entitled, “OSHA Compliance Issues” for the Journal of Occupational and Environmental Hygiene. He still serves on the Editorial Review Board. Richard now works part time for NSC-ORC HSE.

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