On Safety

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


In the previous installment (Part V) of this blog series on OSHA’s Top 10 most cited violations for fiscal year 2020, we looked at the following industries: fabricated metal products manufacturing (NAICS 332), construction of buildings (NAICS 236) and furniture-related products manufacturing (NAICS 337).

Here, we’ll look at the top violations issued by OSHA in FY 2020 in these industries:

  • Primary metal manufacturing (NAICS 331)
  • Heavy civil engineering and construction (NAICS 237)
  • Miscellaneous manufacturing – including medical equipment, jewelry, sporting and athletic goods, toy and doll manufacturing, sign manufacturing, manufacture of musical instruments, fastener manufacturing, and the manufacturing of brooms and caskets (NAICS 239)

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 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 primary metal products manufacturing industry (including foundries), only 1,404 total violations were issued, of which 1,037 were cited as serious. The top violations for the industry are:

Rank OSHA standard No. of violations Standard description
1 1910.212(a)(1) 86 Machine Guarding – General machine guarding
2 1910.147(c)(4) 43 Lockout/Tagout – Lack of energy control procedures
3 1910.147(c)(6) 33 Lockout/Tagout – Lack of periodic inspections
4 1910.147(c)(7) 27 Lockout/Tagout – Lack of training and education for employees
5 1910.28(b)(1) 25 Walking-Working Surfaces – Lack of guarding on unprotected sides and floors 4 feet or more above the lower surface
6 Section 5(a)(1) of the OSH Act – the General Duty Clause 24 Failure to provide a safe and healthy work environment
7 1904.39(a)(2) 22 Failure to report the hospitalization of one or more injured employees to OSHA within 24 hours
8 1910.1200(e)(1) 21 Hazard Communication – Lack of a written program
  1910.212(a)(3) 21 Machine Guarding – Failure to provide point of operation machine guarding
10 1910.305(b)(1) 20 Electrical Wiring Methods and Components – Deficiencies and lack of protection for electrical boxes and fittings
  1910.1200(h)(1) 20 Hazard Communication – Lack of or efficiencies in employee training

The top standouts for this group include machine guarding, lockout/tagout and hazard communication. This industry also had a considerable number of violations for OSHA’s expanded health standards, of which employers should be aware. Most of these violations centered around lack of monitoring, overexposures, lack of controls, lack of training, respirators, and lack of medical assessments or evaluations. The most cited of the expanded health standards is related to lead (1910.1025 – brass and bronze foundries). The cited expanded health standards for FY 2020 included:

  • Permissible exposure limits (1910.1000)
  • Inorganic arsenic (1910.1018)
  • Beryllium (1910.1024)
  • Hexavalent chromium (1910.1026)
  • Cadmium (1910.1027)
  • Formaldehyde (1910.1048)
  • Crystalline silica (1910.1053)

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