OSHA’s Top Ten Citations for 2019

These are OSHA’s top ten most frequently written citations in 2019, with the facts and the explanations surrounding them, as presented in September at the annual National Safety Council Congress.

1. Fall Protection (construction/general requirements)

The interesting part about fall protection is that there are certain height thresholds that, when met, change the safety requirements depending on industry. In construction, it is six feet, unless doing connecting work as a steelworker, which changes the requirement to 25 feet. In general industry it is 4 feet. When the threshold is met it is required for there to be a fall arrest, safety net, or guard rail.

• Loading docks - A common infraction is when an employee is working by the loading dock but there is no vehicle, this could easily be fixed by closing the garage door.
• Floor Holes - Are dangerous when they are wide enough for equipment to fall on employees below.
• Incomplete Guard Rails
• Skylights - Are not designed to support the weight of an employee, without a specific screen added for that purpose.

Is fall protection training required?

Construction: Yes

General Industry: Yes

2. HAZCOM

The first and primary goal with HAZCOM compliance is to ensure that every employee is aware of what chemicals and substances they will be working and coming in contact with.

• Labels:
  • Making sure all chemicals are labeled is a requirement; specifically, if being transferred into a container previously used for food, which could be very misleading.
• SDS:
  • All employees must have quick access to the Safety Data Sheet (SDS) for each chemical (cannot be behind lock and key).
  • Electronic storage is appropriate as long as all employees have quick access.
• PPE:
  • Employees must be working with the appropriate protective equipment depending on the chemical.

Is HAZCOM training required? Yes, for any employees who have access.

3. Scaffolds

Workers on scaffolds are required to wear fall protection anytime a worker is exposed to a fall of 10 feet or greater. How do you know how high the scaffold is? Generally each frame of Scaffold is roughly 5 feet, so anytime more than one frame is used the height should be checked.

• There needs to be “feet” and “mudsills” at the base of all scaffolds, commonly called “Toe-boards”.
  • This is important in case there is rain or uneven terrain to prevent tipping
• The Scaffold needs to be straight/level. There can be no tilting.
• Wrapping a Scaffold
  • If heating a wrapped scaffold with propane, ensure that there is proper ventilation as well as carbon monoxide monitoring.
  • Be aware that wrapping a Scaffold can lead to it catching wind and acting like a “boat sail” leading to it being blown over.

Is scaffold training required?

For construction: Yes

For general industry: No

4. Lockout/Tagout

A very common misconception is that energy sources are only locked out when something is broken. While we do lockout in that circumstance, it should also be done when maintenance is being performed by an employee or when they are working near an energy source that could harm them.

• Anytime more than one energy source is being used there needs to be a written out step by step process on the protocol of how to turn off the power source and then turn it back
  • These processes must be reviewed annually.
• If more than one person is working in the same situation, they must have their own physical lock applied.
  • The last person working should use their key to unlock.
  • This ensures no one is exposed by mistake or misunderstanding.

Is lockout/tagout training required?

Construction: Yes

General Industry: Yes

5. Respiratory Protection

With respiratory protection, the first objective should always be to eliminate the need for a respirator at all. This is primarily done by using a proper ventilation system. A common question is how one can know if they or their employees are using a proper respirator? There are many different types of respirators and all employees required to use a respirator—based on hazard exposure—must be fit-tested and that test must be documented.

• Respirators should be stored in a plastic bag or some other closed container so they don’t get dirty.
• Ensure that each employee knows how to properly use, inspect, and clean their respirator.
• It is important to make sure the respirator fits the employees face appropriately (they are not a one size fit all).
• Not everyone is able to wear a respirator.
  • Employees with asthma or on certain medications may not be permitted.

Is respiratory protection training required?

Construction: Yes

General Industry: Yes

6. Ladders

Ladders are used everyday in both construction and in general industry. When it comes to ladder safety there are essentially two main sets of rules. One applies to extension ladders, the other to fixed ladders. With extension ladders the first focus should be to ensure that the ladder extends three feet beyond the landing.

In the case of fixed ladders the main rule is that there needs to be enough room between the ladder and the object it is fixed to. This ensures there is enough space for the employees foot to use the ladder safely.

• Extension ladders can never be used if they are set from the top-down, they can only be used if they are set from the bottom up.
  • Consider using a longer straight ladder if in a certain situation there is no way to set an extension ladder from the bottom up.
• When using step ladders, they can never be stood on the second to last rung or on the top.
• When placing a ladder the feet need to be on a flat and sturdy surface.
• The rails and steps on a ladder can not be bent.

Is ladder safety training required?

Construction: Yes

General Industry: No

7. Powered Industrial Trucks (Forklifts)

Forklifts are commonly used. Propane powered forklifts are a specific issue when it comes to safety. The mounting of a propane tank is of special concern, there is a vent that runs along the length of the tank and if mounted incorrectly the vent would be at the liquid area of the tank not the air space.

• Anytime a forklift is used to lift a person:
  • The forklift must have been designed for that purpose.
  • The basket must be attached to the mast of the forklift.
  • A guardrail must be in place.
  • The driver must be available at all times to lower the worker.
• If forklifts are being used indoors there should be Carbon Monoxide monitoring in use.
• If electrolytes or water are being added to forklift batteries:
  • There should be a short distance to an eyewash station.
  • The proper PPE should be used.

Is forklift training required?

Construction: Yes

General Industry: Yes

8. Fall Protection (construction/training requirements)

While failing to adhere to fall protection safety standards was number one on the list, failing to provide fall protection safety training makes the list as well. It is not enough to simply meet the physical safety requirements. It is essential for a safe work environment for the employees to have training in fall protection.

• Employees who received training must have it certified in writing.
• The employee must retain all of the safety training
  • It is not enough to simply go through the training. The employee must be able to recall the training
• In situations where an employee did not retain the training, they must be retrained.

9. Machine Guarding

When it comes to machine guarding safety there are four main hazard areas to look for they are points of operation, in running nip points, rotating parts, and flying chips or sparks.

• If a person could reach passed the guard in anyway, then it is in incomplete guard and is insufficient.

Is machine guarding safety training required?

Construction: No

General Industry: No

10. Personal Protective and Lifesaving Equipment (construction/eye and face)

A great number of workers suffer severe eye damage each year. This violation first made this list in 2018, and has made its way back in 2019. There are a wide number of infractions that bring this into the top ten.

• When flying objects are present in a work area, eye and face protection must be provided.
• Eye protection must have side protection.
• Appropriate protection must be provided when working near caustic hazards, gases, and vapors.

Is personal protective equipment safety training required?

Construction: Yes

General Industry: Yes