Enforcement and Inspection

OSHA’s Top 10 List and How to Stay Off It

By Chris Kilbourne Dec 4, 2012 Enforcement and Inspection

Updated: Dec 4, 2012

OSHA’s newest top 10 list of violations includes familiar hazards. Today and tomorrow, we look at a number of these entries and suggest ways to avoid OSHA violations and penalties.

As you probably already know, the top 10 violations for 2012 are:

Fall protection—general requirements
Hazard communication
Scaffolding
Respiratory protection
Ladders
Machine guarding
Powered industrial trucks
Electrical—wiring methods
Lockout/tagout
Electrical—general requirements.

In 2011 the top three violations were, in order, scaffolding, fall protection, and hazard communication.

What can you do to make sure your facility doesn’t run afoul of top 10 violations and end up dealing with citations and paying dollars for penalties that could better be spent elsewhere? Here are some tips.

Fall Protection (29 CFR 1926 Subpart M)

Tips for being in compliance with this standard include:

Determine if walking/working surfaces have the strength and structural integrity to support employees safely.
Protect employees on walking/working surfaces (horizontal and vertical) with an unprotected side or edge that is 6 feet or more above a lower level. The use of guardrail systems, safety net systems, or personal fall arrest systems is required.
Protect employees constructing a leading edge 6 feet or more above a lower level from falling with guardrail systems, safety net systems, or personal fall arrest systems.
Protect workers from tripping in or stepping into or through holes (including skylights) with covers, guardrails, or personal fall arrest systems.

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Hazard Communication (29 CFR 1910.1200)

Tips for being in compliance with this standard include:

Have a written hazard communication program that identifies all hazardous substances in the workplace.
Make sure all hazardous chemicals are properly labeled.
Provide an SDS for each hazardous chemical in the workplace.
Train employees about chemical hazards and precautions.
Provide appropriate PPE, and make sure employees use it.
Retrain employees whenever new chemical hazards are introduced into the workplace and following any incidents involving hazardous substances.

Scaffolding (29 CFR 1926 Subpart L)

The key to staying in compliance with this standard is a “competent person.” The standard requires a competent person to perform the following duties:

Select and direct employees who erect, dismantle, move, or alter scaffolds.
Determine if it is safe for employees to work on or from a scaffold during storms or high winds and to ensure that a personal fall arrest system or windscreens protect these employees.
Train employees involved in erecting, disassembling, moving, operating, repairing, maintaining, or inspecting scaffolds to recognize associated work hazards.
Inspect scaffolds and scaffold components for visible defects before each work shift and after any occurrence that could affect the structural integrity and to authorize prompt corrective actions.
Inspect ropes on suspended scaffolds prior to each work shift and after every occurrence that could affect the structural integrity, and to authorize prompt corrective actions.
Inspect manila or plastic (or other synthetic) rope being used for top rails or midrails.
Determine if a scaffold will be structurally sound when inter-mixing components from different manufacturers or when components of dissimilar metals are used.

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Respiratory Protection (29 CFR 1910.134)

An estimated 5 million workers are required to wear respirators in 1.3 million workplaces throughout the United States. Respirators protect workers against insufficient oxygen environments and harmful dusts, fogs, smokes, mists, gases, vapors, and sprays.

Tips for staying in compliance with this standard include:

Provide respirators, training, and medical evaluations at no cost to employees.
Make sure all respirators are fit-tested before use.
Provide employees with respirators whenever this PPE is necessary to protect against respiratory hazards.
Provide respirators suitable to protect against the specific hazard employees face.