On Safety

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

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In the previous installment (Part IV) of this blog series on OSHA’s Top 10 most cited violations for fiscal year 2020, we looked at telecommunications; computers and electronics manufacturing; machinery manufacturing; and electrical equipment, appliances and components manufacturing. Here, we’ll look at the top violations issued by OSHA in FY 2020 in the following industries:

  • Fabricated metal products manufacturing (NAICS 332)
  • Construction of buildings (NAICS 236)
  • Furniture-related products manufacturing (NAICS 337)

As a reminder, OSHA in FY 2020 conducted only 21,680 inspections – one of the lowest totals on record and down from 33,401 in FY 2019. (Those totals are also down from 70,000-plus inspections per year in the 1980s.) Hence, the number of violations in FY 2020 is less than in FY 2019, but the most cited violations remain consistent.

For the fabricated metal products manufacturing industry, only 6,909 total violations were issued, of which 5,068 were cited as serious. The Top 10 violations for the industry are:

Rank OSHA standard No. of violations Standard description
1 1910.212(a)(1) 387 General Machine Guarding
2 1910.212(a)(3) 235 Machine Guarding – Point of Operation Guarding
3 1910.1200(e)(1) 207 Hazard Communication – Written Hazard Communication Program
4 1910.147(c)(4) 193 Lockout/Tagout – Lack of Energy Control Procedures
5 1910.1200(h)(1) 174 Hazard Communication – Lack of Employee Training and Communication
6 1910.147(c)(6) 146 Lockout/Tagout – Failure to Conduct Periodic Inspections
7 1910.134(e)(1) 138 Respiratory Protection – Failure to Provide Medical Evaluations
8 1910.134(c)(1) 123 Respiratory Protection – Lack of a Written Respiratory Protection Program
9 1910.147(c)(7) 116 Lockout/Tagout – Lack of Training and Communication
10 1910.178(l)(1) 102 Powered Industrial Trucks – Lack of Operator Training in Safe Operations of the Trucks

Although no standard related to noise made the Top 10, the total number of violations for noise exposure in the industry was 191, which would have placed noise at No. 5. The standout cited standards for noise included 54 violations for the lack of a hearing conservation program – 1910.95(C)(1) – and 28 for lack of employee training on noise – 1910.95(K)(2). The top standouts among this Top 10 included machine guarding, lockout/tagout and respiratory protection.

For the industry, a considerable number of violations were issued for OSHA’s expanded health standards, of which employers should be aware. Most of these violations centered around a lack of monitoring, overexposures, lack of controls, lack of training, respirators, and lack of medical assessments or evaluations. The most cited of the OSHA expanded health standards was hexavalent chromium (1910.1026), with a total of 148 violations (which would have placed hexavalent chromium at No. 6 in the Top 10). The cited OSHA expanded health standards for FY 2020 included:

  • Permissible exposure limits (1910.1000)
  • Inorganic arsenic (1910.1018)
  • Beryllium (1910.1024)
  • Lead (1910.1025)
  • Hexavalent chromium (1910.1026)
  • Cadmium (1910.1027)
  • Methylene chloride (1910.1052)
  • Crystalline silica (1910.1053)

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