On Safety

On Safety: A closer look at OSHA's Top 10 violations – Part IV

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As for the standards cited, the clear standouts are lockout/tagout, machine guarding and respiratory protection. Although not making the Top 10 list, several health-related OSHA standards were cited:

  • Noise (1910.95) – Overexposure to noise, lack of a hearing conservation program, not providing personal protective equipment and employee training
  • Asbestos (1910.1001) – Overexposure to asbestos, lack of controls and housekeeping
  • Arsenic (1910.1018) – Housekeeping
  • Beryllium (1910.1024) – Notification of employees of monitoring results
  • Lead (1910.1025) – Lack of monitoring, no initial determination, employee notification of sampling results, lack of PPE, housekeeping, lack of hygiene facilities and information/training to employees
  • Hexavalent chromium (1910.1026) – Employee overexposure above the PEL, lack of exposure determination, employees not notified of sampling results, lack of respiratory protection, lack of hygiene facilities and employee training
  • Cadmium (1910.1027) – Lack of exposure monitoring, employees not notified of the sampling results, housekeeping and employee hazard training
  • Benzene (1910.1028) – Lack of employee notification of the sampling results
  • Bloodborne pathogens (1910.1030) – Lack of a written program
  • Formaldehyde (1910.1048) – Lack of exposure monitoring
  • Methylene chloride (1910.1052) – Lack of exposure monitoring, lack of initial monitoring, hygiene facilities and employee hazard training
  • Crystalline silica (1910.1053) – Lack of an exposure assessment

The total number of violations cited in FY 2020 for this industry was 1,823, of which 1,329 were cited as serious.

The Top 10 OSHA violations in FY 2020 for the electrical equipment, appliance and components manufacturing industry:

Rank OSHA standard No. of violations Standard description
1 1910.212(a)(1) 20 Machine Guarding – General Machine Guarding
2 1910.1200(e)(1) 19 Hazard Communication – Written Program
3 1910.1200(h)(1) 16 Hazard Communication – Employee Training and Education
4 1910.147(c)(4) 14 Lockout/Tagout – Energy Control Procedures
5 1910.147(c)(8) 11 Lockout/Tagout – Energy Isolation by Authorized Employees
6 1910.147(c)(7) 10 Lockout/Tagout – Employee Training and Communication
  1910.147(c)(6) 10 Lockout/Tagout – Periodic Inspections
8 1910.212(a)(3) 9 Machine Guarding – Point of Operation Guarding
9 General Duty Clause 8  
10 1910.134(k)(6) 7 Respiratory Protection – Employee Training, Providing Basic Information from Appendix D

Not surprisingly, 60% of the Top 10 violations cited were related to lockout/tagout and machine guarding. Regarding the General Duty Clause https://www.safetyandhealthmagazine.com/articles/19258-oshas-general-duty-clause, there was no apparent trend in hazards cited. For FY 2020, OSHA issued a total of 427 violations, of which 305 were cited as serious.

Part V of this series will include the top violations in FY 2020 for three other industries – yet to be named.

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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