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)
For the construction of buildings industry, a total of 6,276 violations were issued, of which 4,871 were cited as serious. The top violations were:
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | 1926.501(b)(13) | 557 | Residential Construction – Lack of Edge Guarding on Edges 6 Feet or More Above Lower Level |
| 2 | 1926.501(b)(1) | 264 | Residential Construction – Lack of Leading Edge Guarding 6 Feet or More Above the Lower Level |
| 3 | 1926.451(g)(2) | 206 | Scaffolding – Lack of a Competent Person Checking on the Scaffolding |
| 4 | 1926.503(a)(1) | 192 | Lack of Training on Fall Hazards |
| 5 | 1926.20(b)(2) | 185 | Failure to Conduct Frequent and Regular Inspections of the Jobsite |
| 6 | 1926.453(b)(2) | 183 | Aerial Lifts – Extensions and Booms |
| 7 | 1926.1053(b)(1) | 175 | Portable Ladders Not Extending at Least 3 Feet Above the Roofline |
| 8 | 1926.102(a)(1) | 157 | Failure to Provide/Use Eye Protection |
| 9 | 1926.1052(c)(1) | 126 | Stairways – Lack of Railing on Stairs with Four or More Risers |
| 10 | 1926.451(b)(1) | 106 | Scaffolding – Scaffolds Not Fully Planked |
As for the standards cited, the clear standout is the number of violations related to fall protection, which is also the No. 1 cited hazard in the construction industry.
The top OSHA violations in FY 2020 for the furniture-related products manufacturing industry are listed below. For this industry, a total of 1,376 violations were issued, of which 1,059 were cited as serious.
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | 1910.1200(e)(1) | 65 | Hazard Communication – Lack of a Written Program |
| 2 | 1910.134(e)(1) | 48 | Respiratory Protection – Failure to Provide Medical Evaluation |
| 3 | 1910.1200(h)(1) | 40 | Hazard Communication – Lack of Employee Training and Education |
| 4 | 1910.134(c)(1) | 34 | Respiratory Protection – Lack of a Written Program |
| 1910.212(a)(1) | 34 | Machine Guarding – General Machine Guarding | |
| 1910.213(c)(1) | 34 | Machine guarding – Lack of Guarding on Rip (Circular Saws) | |
| 7 | 1910.147(c)(4) | 33 | Lockout/Tagout – Lack of Written Energy Control Procedures |
| 8 | 1910.22(a)(1) | 26 | Sanitation – Places of Employment Were Not Kept Clean and Sanitary |
| 9 | 1910.134(c)(2) | 25 | Respiratory Protection – Voluntary Use of Respirators |
| 10 | 1910.213(c)(23) | 22 | Machine Guarding – Rip (circular saw) Used Without a Spreader |
| 10 | 1910.213(c)(3) | 22 | Machine Guarding – Rip (circular saw) Used Without Kickback Fingers |
Most of the top cited violations for this industry centered around machine guarding issues. Part VI 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.
