OSHA’s Top 10 – C’mon Now!!

The OSHA Top 10 List of most frequently cited violations for 2013 is making it’s rounds on the internet recently. 

Doesn’t it look familiar?! Do you even pay attention to it anymore? It’s a must-have list for those of us that conduct safety training, it’s an attention-grabber for those new to OSHA stats and safety philosophy. It’s a good introductory slide; a “this is why you’re here” bit of trivia. 

Let’s look at it a little differently as we navigate 2014 and safety at our workplaces.

The official Top 10 is posted here at OSHA’s website: https://www.osha.gov/dcsp/compliance_assistance/frequent_standards.html

1. Fall protection, construction

We all know falls are the number one cause of death in construction. It’s been that way for years. Falls are the first cause of death you list when you recite the Focus Four: Falls, Electrocutions, Struck-by, Caught-in. 

Evaluate your workplace for fall hazards (duh), and make sure you are employing ENGINEERING controls FIRST. Remember, PPE (harnesses and lanyards, etc) are your last resort. Think outside the box, think of different work methods you can use to avoid working at heights. These work methods will probably help your production too, just sayin’. 

2. Hazard communication standard, general industry

You guys, there’s no excuse for this one to be #2 from 2013. You ALL should have been conducting HAZCOM training last year AT LEAST to meet the GHS standard requirements that were “due” by December 1st. 

Assess your workplace for chemicals and other hazards that are covered by the HAZCOM standard; identify what training needs to be done; identify times to conduct that training and get it done. Repeat next year. If this hasn’t been done in awhile, consider calling a consultant to get a unbiased look at what your facility or jobsite really needs.

3. Scaffolding, general requirements, construction

OK contractors, when you’re working off of scaffolding (because it’s a solid engineering and administrative control for preventing falls), what are your best practices? Do you have your own scaffolding that limps from job to job, forcing your people to make-do with the parts they have that don’t fit together? Are there more 2x4s and tie-wire on your scaffold than original coordinating components? Consider renting scaffold systems or upgrading your owned scaffolds. It’s a lot more pleasant to put erect scaffolding that is in good condition. It also saves time and money to not have to repair something each day before personnel can work off of the scaffold. 

Consider using scissor and boom lifts instead of scaffolding in appropriate situations. For example: why require your crew to erect a scaffolding for four hours to do four hours worth of work off of that scaffold? Put them to work right away by renting or using an owned scissor or boom lift.

4. Respiratory protection, general industry

You know when you’re doing your assessment for HAZCOM as stated in #2? You’re also identifying substances and hazards at that stage that could present a hazard to your personnel’s respiratory systems. There are multiple OSHA eTools available on building your Respiratory Protection Program. If you already have a favorite respirator brand or vendor, they have similar tools available and can help you at most stages of implementation. Lean on them and use their resources. Often, a vendor or brand rep will come to your site to provide assistance if you’re a paying customer using their products.

5. Electrical, wiring methods, components and equipment, general industry

This is another topic that OSHA has published extensive eTools to help business. Electrocutions are the 2nd leading cause of death in industry, so OSHA is very interested in making sure you are aware of how to minimize your risk. For sites that sub out or hire electricians, you still should have a written program that addresses electrical hazards with provisions for those subcontractors and for your own people to follow. If you frequently work with electrical subcontractors, ask them to put on an educational session for your employees on electrical safety. It’s very effective to receive safety training from your peers.

6. Powered industrial trucks, general industry

I can nearly recite 1910.178 word for word. I have created many training programs on the topic, yet I’ve never driven a forklift. I’ve had great success in delivering meaningful and efficient PIT training by partnering with a seasoned operator. Identify someone or multiple people on your site who are experienced PIT operators to work in concert with your training staff, i.e.: someone like me who has never farted in a forklift seat (as they say), to develop a practical instruction program for your PIT operators. Contrary to what many think, you can conduct your PIT training in-house with your own personnel, there is no need to outsource as long as you allot the time for your own people to conduct good training. This training could last anywhere from two to eight hours depending on your facility or site needs. Training must be done for EACH TYPE of PIT your personnel are required to operate. Make wallet cards that note each type of PIT the crew member is certified to operate, it looks cool, everyone likes wallet cards, and it proves you have met the standard. 

7. Ladders, construction

Ladders continue to be a well-used and abused piece of jobsite equipment. Basic ladder safety must be reinforced often: select the right ladder for the job, inspect the ladder, do not use ladders in poor condition, ladders are not work platforms, etc. Since just about everyone has a ladder at home, this valuable piece of equipment is taken for granted and used without thought. Remember to not assume general knowledge on anyone’s part, get back to basics when you speak about ladder safety with your crews.

8. Control of hazardous energy (lockout/tagout), general industry

Similar to electrical, make sure you have written procedures that apply to your employees as well as contractors who will work at your site. Get specific with each LOTO task, do not rely on a vague written program, reviewed once a year, to cover every situation. If any task deserved a thorough task hazard analysis, it is LOTO. It is important for all involved parties to understand the order of shutdown and restart and everything in between. 

9. Electrical systems design, general requirements, general industry

See #5 above.

10. Machines, general requirements, general industry

You’re probably thinking GUARDING when you read this one, and you’re likely correct. Equipment must be operated the way the manufacturer intended with all of the pieces the manufacturer made it with being intact. It’s as simple as that. If your personnel are Mickey-Mousing something, that machine should be taken out of operation until the proper repair or replacement can be made, no excuses. You and your company will not gain anything by forcing equipment to limp along when it is not in manufacturer-intended condition.

If you found this helpful, let me know! I will publish a follow-up post on safety tips related strictly to OSHA compliance later this week.


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