In a presentation at the 2018 National Safety Council Congress & Expo in Houston, Texas, Patrick Kapust, deputy director of OSHA’s Directorate of Enforcement Programs, announced the list of the agency’s top 10 violations for fiscal year (FY) 2018 to a standing-room-only crowd of safety professionals. While the list—particularly its top half—is largely familiar from previous years, one standard made an appearance for the first time. Although the talk was directed at safety professionals, as a facility manager you should be aware of these violations to help maintain a focus on safety in your buildings.
The data, which covers violations cited from October 1, 2017, through September 30, 2018, is preliminary, and as such, the precise numbers associated with each violation may change. However, the ranking is likely to remain consistent when OSHA releases the final numbers.
The top 10 violations of FY 2018 are:
- Duty to provide fall protection (29 CFR 1926.501): 7,270 violations. The duty to provide fall protection has been OSHA’s top citation for several years. According to Kapust, common violations under this standard included failure to provide fall protection near unprotected sides or edges and on both low-slope and steep roofs. Many of the citations were issued to roofing contractors, framing contractors, masonry contractors, and new single-family housing construction contractors.
- Hazard communication (29 CFR 1910.1200): 4,552 violations. Hazard communication has been in the number-two spot for several years. Common deficiencies include lack of a written program, inadequate training, and failure to properly develop or maintain safety data sheets (SDSs). Auto repair facilities, hotels, and motels were among the industries that received many hazard communication citations.
- Scaffolds—general requirements (29 CFR 1926.451): 3,336 violations. Common violations included lack of proper decking, failure to provide personal fall arrest systems and/or guardrails where required, and failure to ensure that supported scaffolds are adequately supported on a solid foundation. Masonry, siding, and framing contractors were particularly prone to scaffolding violations.
- Respiratory protection (29 CFR 1910.134): 3,118 violations. Failure to establish a program, failure to perform required fit testing, and failure to provide medical evaluations were among the most frequently cited issues. Auto body refinishing, painting contractors, and wall covering contractors received many citations under this standard.
- Lockout/tagout (29 CFR 1910.147): 2,944 violations. Many employers cited under this standard failed to establish an energy control procedure altogether, while others were cited for failing to provide adequate employee training, failure to develop machine-specific procedures, and failure to use lockout/tagout devices or equipment.
- Ladders (29 CFR 1926.1053): 2,812 violations. Common deficiencies included failure to have siderails extend 3 feet (ft) beyond a landing surface, using ladders for unintended purposes, using the top step of a stepladder, and ladders with broken steps or rails. These violations were common among roofing, framing, siding, and masonry contractors.
- Powered Industrial Trucks (29 CFR 1910.178): 2,294 violations. Violations commonly addressed deficient or damaged forklifts that were not removed from service, operators who had not been trained or certified to operate a forklift, and failure to evaluate forklift drivers every 3 years as required. Forklift violations were widespread across a number of industries, but were particularly prevalent in warehousing and storage facilities, fabricated and structural metal manufacturing, and wood container and pallet manufacturing.
- Fall protection—training requirements (29 CFR 1926.503): 1,982 violations. Commonly cited issues include failing to provide training to each person required to receive it, failure to certify training in writing, failing to ensure that training is provided by a competent person, and failing to train the proper use of guardrails and personal fall arrest systems.
- Machine guarding (29 CFR 1910.212): 1,972 violations. Violations included failing to guard points of operation, failing to ensure that guards are securely attached to machinery, and failure to properly anchor fixed machinery. Machine guarding violations occur in many industries, but common targets include machine shops, fabricated metal manufacturing, and plastics manufacturing.
- Personal protective and lifesaving equipment—eye and face protection (29 CFR 1926.102): 1,536 violations. The final violation is a newcomer to OSHA’s top 10 list and replaces electrical wiring methods (29 CFR 1910.305), which took the number 10 spot for FY 2017. Commonly cited issues included failing to provide eye and face protection where employees are exposed to hazards from flying objects; failing to provide protection from caustic hazards, gases, and vapors; and allowing employees to wear combinations of prescription and safety eyewear that compromise the protective qualities.