On Safety

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

OSHATop10_2020

For the personal and laundry services industry, a total of 374 violations were issued, of which 260 were cited as serious. The top standards cited are:

Rank OSHA standard No. of violations Standard description
1 1910.1200(e)(1) 39 Hazard Communication – Lack of a written program
2 1910.1200(h)(1) 19 Hazard Communication – Lack of or deficiencies in employee training
3 1910.1200(g)(8) 11 Hazard Communication – Failure to maintain copies of Safety Data Sheets in the workplace
  1904.39(a)(2) 11 Failure to report the hospitalization of one or more injured employees to OSHA within 24 hours
5 1910.147(c)(4) 10 Lockout/Tagout – Lack of a written energy control program
  1910.212(a)(1) 10 Machine Guarding – General machine guarding
7 1910.1030(c)(1) 9 Bloodborne Pathogens – Lack of a written exposure control plan

Most of the violations cited were related to the Hazard Communication Standard (1910.1200).

For the U.S. Postal Service, a total of 242 violations were issued, of which 74 were cited as serious. The top three violations included: 1910.22(a)(1) for housekeeping, with 11 violations; 1910.303(g)(1) for not keeping open spaces around electrical equipment, with 10 violations; and 1910.305(g)(1) for using flexible cords as permanent wiring, with nine violations.

For the chemicals manufacturing industry, 1,993 total violations were issued, of which 1,431 were cited as serious. The top standards cited are:

Rank OSHA standard No. of violations Standard description
1 1910.147(c)(4) 69 Lockout/Tagout – Lack of a written energy control program
2 1910.134(e)(1) 58 Respiratory Protection – Failure to provide medical evaluations for employees required to wear a respirator
  1910.212(a)(1) 58 Machine Guarding – General machine guarding
  1910.1200(h)(1) 58 Hazard Communication – Lack of or deficiencies in employee training
5 1910.1200(e)(1) 53 Hazard Communication – Lack of a written program
6 1910.119(d)(3) 43 Process Safety Management – Process safety information, failure to document information necessary to the process
7 Section 5(a)(1) of the OSH Act 40 General Duty Clause
8 1910.119(f)(1) 38 Process Safety Management – Failure to develop and implement written operating procedures
9 1910.147(c)(7) 37 Lockout/Tagout – Lack of training and education for employees
10 1910.134(c)(1) 34 Respiratory Protection – Lack of a written program

The most cited violations in this industry centered on hazard communication, respiratory protection, lockout/tagout and process safety management. For PSM, of the total violations cited in the industry, 246 covered all major paragraphs of the standard. Additionally of note, 40 violations were issued under the General Duty Clause. These violations were also tied to fatality and serious injury/illness reduction and included:

  • Crushing (11 violations)
  • Fire and combustible dust (nine)
  • Struck by (nine)
  • Heat stress (three)
  • Caught in (three)
  • Lack of training (two)
  • Failure to use a seatbelt or lack of seat belts on forklifts (one)
  • Ergonomics (one)
  • Lack of an exposure control plan for COVID-19 (one)

Part VIII 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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