On Safety: A closer look at OSHA’s ‘Top 10’ violations: A review
In the previous installments of this blog series reviewing the top violations cited by OSHA in different NAICS codes in fiscal year 2020, a consistency was evident with past years in the violations cited to protect employees from serious injury and illness. The Top 10 violations cited by OSHA for both construction and general industry demonstrated that most of the cited hazards were directed at employee exposure most likely to result in fatalities and serious injuries. This demonstrates that the agency’s compliance staff is focusing its efforts on the most serious hazards facing workers.
For the construction industry, OSHA directs between 45% and 55% of its enforcement efforts at conducting inspections. Although targeted inspections are conducted through local and national emphasis programs, many of the inspections are made as a result of agency self-referrals and complaints received by employees. In the construction industry, 60% of the Top 10 violations were tied in with fall protection, including:
- Residential fall protection – lack of guard rails and/or lack of using a fall arrest system
- Incorrect or improper use of portable ladders
- Lack of employee training on fall protection
- Protection from fall hazards from open-sided floors and edges
- Unguarded or unprotected scaffolding
- Improper guards or lack of a fall arrest system on aerial lifts
The remainder of the top violations cited by OSHA in construction included:
- Lack of eye and/or face protection
- Lack of head protection (hard hats)
- General employee training on unsafe working conditions
- Lack of a site incident prevention program
In general industry, most OSHA inspections are directed from employee complaints, referrals, and planned or targeted inspections. The planned and targeted inspections are derived from local and national emphasis programs and the Site-Specific Targeting Program. The top violations in manufacturing for FY 2020 included:
- Failure to have a written hazard communication program
- Failure to provide a medical assessment for employees required to wear a respirator
- OSHA’s General Duty Clause – Section 5(a)(1) of the Occupational Safety and Health Act of 1970
- Lack of training for employees under the Hazard Communication Standard (1910.1200)
- Failure to provide fit testing for employees required to wear a respirator
- Failure to report the hospitalization of an employee within 24 hours
- Lack of a written respiratory protection program
- Lack of guard rails, netting or use of a personal fall arrest system for employees working 4 feet or move above ground or the next level
- Inadequate working space around electrical equipment
- Exit routs were obstructed, and lack of a clear and direct exit route
From an employee health perspective, it was important to see violations related to the Hazard Communication Standard in the Top 10. The standard mandates that employees receive training and education on the chemicals with which they work and that employees are provided the protections needed for those chemicals. Education of employees in this area goes a long way to help ensure their health and safety. The violations related to the General Duty Clause were reviewed and found to be attributed to a variety of serious safety hazards, including explosion and fire, combustible dust, struck-by, caught-in, and crushing hazards.
Although not in the Top 10, but in the top 15 violations cited were those for hazards associated with general machine guarding, lockout/tagout, lack of point of operation guarding and unsafe operation of powered industrial trucks. The most cited violations for lockout/tagout included lack of a written program and lack of lockout/tagout equipment-specific procedures.
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.