On Safety

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

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For the forestry and logging services, 78 total violations were issued, of which 48 were cited as serious. The top five violations cited included 1910.266(h)(2) for violations related to manual felling, with seven violations; 1910.266(i)(7) for a lack of first aid training, with five violations; 1910.266(d)(1) for PPE, with five violations; 1904.39(a)(2) for not reporting a hospitalization within 24 hours, with four violations; and 1910.266(f)(3) for equipment not provided with falling object protection, with four violations.

For the waste management and remediation services industry, 899 total violations were issued, of which 612 were cited as serious. The top standards cited are:

Rank OSHA standard No. of violations Standard description
1 General Duty Clause – Section 5(a)(1) of the OSH Act 30 General Duty Clause
2 1910.1200(e)(1) 23 Hazard Communication – Lack of a written program
3 1910.28(b)(1) 22 Fall Protection – Protection against unguarded/unprotected sides and edges greater than 4 feet above the lower surface
4 1910.1200(h)(1) 21 Hazard Communication – Lack of or deficiencies in employee training
5 1910.212(a)(1) 17 Machine Guarding – General machine guarding
6 1910.134(e)(1) 14 Respiratory Protection – Failure to provide a medical evaluation
7 1910.134(f)(2) 13 Respiratory Protection – Fit testing, failure to ensure an employee wearing a tight-fitting respirator is fit tested before initial use
8 1910.147(c)(4) 12 Lockout/Tagout – Lack of written energy control procedures
  1910.178(l)(1) 12 Powered Industrial Trucks – Operator Training – Safe operation
10 1904.39(a)(2) 10 Failure to report a hospitalization within 24 hours
  1910.22(a)(1) 10 Housekeeping – Keeping all places of employment clean and sanitary
  1910.146(d)(4) 10 Confined Spaces – Failure to provide necessary equipment specified in this section to entrants at no cost
  1910.146(e)(1) 10 Confined Spaces – Permit system, before entry is authorized, the employer shall document the completion of measures required by section (d)(3) of this section
  1910.132(d)(1) 10 Personal Protective Equipment – Failure to conduct a hazard assessment for PPE use

The top cited violations in this industry centered on hazard communication, confined spaces, respiratory protection, lockout/tagout and the General Duty Clause. The top cited item was the General Duty Clause, cited 30 times. These violations were also tied to fatality and serious injury/illness reduction and (ranked from most to the fewest) included:

  • Crushing/caught-in hazards
  • Struck-by hazards
  • Heat stress hazards
  • Falls
  • Lack of training
  • Hazards related to fire and explosion
  • Release of compressed gas
  • Asbestos
  • Electrical hazards
  • Lack of a safety program
  • PPE

Part IX of this series will include a final summary of the top violations for FY 2020.

This article represents the views of the author 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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