Back in October, at the National Safety Council’s annual Safety Congress, we got our first look at OSHA’s Top Ten Violations list for 2016. We covered that for you in an earlier blog post.
But every year, OSHA follows up that initial announcement with a second announcement that includes a lot more data.
That information is out now, and we’ve got it for you below.
Remember that in a lot of cases, these violations can be avoided with proper safety and health training at your workplace.
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The first thing you notice is that all ten standards were on list year’s list too.
The standards are in basically the same order on the list, too.
The one difference in order is that Machine Guarding moved up one slot from ninth last year to eighth this year. But even though machine guarding jumped up one slot, there were actually fewer machine guarding violations cited in 2016 (2,448) than there were in 2015 (2,540).
Another thing that stands out is the large number of Fall Protection citations (6,096) and Hazard Communication citations (5,665). This is the same basic story that we saw in 2015.
Nine of the ten standards saw a decrease in the number of citations from 2015 to 2016:
- Fall Protection
- Hazard Communication
- Scaffolding
- Respiratory Protection
- Powered Industrial Trucks
- Ladders
- Machine Guarding
- Electrical Wiring
- Electrical-General Requirements
In many cases, the number of citations were significantly lower.
I have no insight into why the number of citations went down. Are companies being safer and more compliant? Are OSHA inspectors simply issuing fewer citations, for whatever reason? Feel free to share your own opinion in the comments section.
Only one standard saw an increase in violations cited from 2015 to 2016: Lockout/Tagout. Remember to review that standard, folks.
It’s also worth noting that this extended data set from OSHA also includes “Serious” and Willful” violations. We’ve got lists of the serious and willful violations for you later in this article. Until then, here are some definitions for you (from OSHA):
- Serious violation-a violation “in which there is a substantial probability that death or serious physical harm could result, and the employer knew or should have known about the hazard.”
- Willful violation-a violation “committed with an intentional disregard of or plain indifference to the requirements of the Occupational Safety and Health Act.”
And with that intro, let’s get on with the lists.
OSHA’s Top Ten Violations Cited List, Fiscal Year 2016
Here are the top ten violations cited, listed from the standard with the most citations to the standard with the tenth-most citations.
1. Fall Protection, 1926.501
Fall Protection Resources:
- Check out the regulation.
- Check out our webpage with free training materials, informational resources, and more.
- Check out our new and fun fall protection word game.
Statistics:
Total citations- 6,906. Almost 500 fewer than in 2015, when there were 7,402.
Ranking in previous year-#1 last year (same as this year)
Top five sections cited-
- 1926.501(b)(13) Residential construction, 3,911 citations
- 1926.501(b)(1) Unprotected sides and edges, 1,278 citations
- 1926.501(b)(10) Roofing work on low-slope roofs, 625 citations
- 1926.501(b)(11) Steep roofs, 523 citations
- 1926.501(b)(4)(I) Holes and skylights, 154 citations (this is the only section that saw an increase)
Fall Protection Safety Training Suggestion:
Here’s a sample of our Fall Prevention and Protection e-learning course.
2. Hazard Communication, 1910.1200
Hazard Communication Resources:
- Check out the regulation.
- Check out our webpage with free training materials, informational resources, and more.
- Check out our new hazard communication word game.
Statistics:
Total citations- 5,665, a smidge less than 2015’s total of 5,681.
Ranking in previous year- #2 last year (same as this year)
Top five sections cited-
- 1910.1200(e)(1) Developing, implementing, and maintaining a written hazard communication program, 1,833 citations
- 1910.1200(h)(1) Providing effective information and training on hazardous chemicals to workers, 1,446 citations (this is an increase from the previous year)
- 1910.1200(g)(8) Maintaining safety data sheets (SDSs) and keeping the readily accessible, 464 citations
- 1910.1200(g)(1) Developing and maintaining safety data sheets (SDSs), 386 citations
- 1910.1200(h)(3)(iv) Employee training on the hazard communication program, 335 citations
Hazard Communication Training Suggestion
And here’s a sample of our Hazard Communication e-learning course.
3. Scaffolding, 1926.451
Scaffolding Resources:
- Check out the regulation.
- Check out our webpage with free training materials, informational resources, and more.
- Check out our new and fun scaffolding safety word game.
Statistics:
Total citations- 3,900, a good-sized drop from 2015’s total of 4,681.
Ranking in previous year- #3 (same as this year)
Top five sections cited-
- 1926.451(g)(1) Employee fall protection, 614 citations
- 1926.451(e)(1) Means of access to scaffold platforms through means such as stairs or ladders, 507 citations
- 1926.451(b)(1) Platform to be fully planked or decked between front uprights and guardrail supports, 464 citations
- 1926.451(g)(1)(vii) Fall arrest or guardrail systems on unspecified scaffolds, 324 violations
- 1926.451(g)(4)(i) Guardrail systems, 203 citations
Scaffolding Training Suggestions
And here’s a sample of our Scaffolding e-learning course.
4. Respiratory Protection, 1910.134
Respiratory Protection Resources:
- Check out the regulation.
- Check out our webpage with free training materials, informational resources, and more.
- Check out our new and fun respiratory protection word game.
Statistics:
Total citations- 3,573, a little less than the 2015 total of 3,626.
Ranking in previous year- #4 (same as this year)
Top five sections cited-
- 1910.134(e)(1) Medical evaluation general requirements, 615 citations
- 1910.134(c)(1) Establishing and implementing a written respiratory protection program, 499 citations
- 1910.134(f)(2) Fit testing prior to first use, whenever a different facepiece is used, and annually, 341 citations
- 1910.134(c)(2)(i) Permitting employees to voluntarily use their own respirators if such use will not create a hazard, 241 citations
- 1910.134(d)(1)(iii) Identifying and evaluating respiratory hazards, 235 citations
Course Sample:
We offer quite a few courses on respirators and respiratory protection. Here they are.
Respirator Medical Evaluation and Fit Testing
5. Lockout/Tagout, 1910.147
Lockout/Tagout Resources:
- Check out the regulation.
- Check out our webpage with free training materials, informational resources, and more.
- Check out our new and fun lockout/tagout for authorized employees word game.
- Check out our new and fun lockout/tagout for affected employees word game.
Statistics:
Total citations- 3,406, a little more than 2015’s total of 3,308. Notice this is the only standard on the list that saw an increase in citations instead of a decrease.
Ranking in previous year- #5 (same as this year)
Top five sections cited-
- 1910.147(c)(4)(i) Establishing and training employees on energy control procedures, 644 citations
- 1910.147(c)(1) Energy control program, 440 citations
- 1910.147(c)(6)(i) Annual periodic inspection of energy control procedure, 376 citations
- 1910.147(c)(7)(i) Employee training on purpose and function of energy control program, 289 violations
- 1910.147(c)(7)(i)(A) Each authorized employee shall receive training, 196 violations
Lockout-Tagout Training Suggestions
We have several courses related to lockout-tagout and control of hazardous energy. Here they are.
Lockout-Tagout For Authorized Employees
Lockout-Tagout Affected Employees
Blocking and Cribbing for Heavy Equipment
6. Powered Industrial Trucks, 1910.178
Powered Industrial Trucks Resources:
- Check out the regulation.
- Check out our webpage with free training materials, informational resources, and more.
- Check out our new and fun forklift safety word game.
Statistics:
Total violations- 2,855, down a tick from the 2015 total of 3,004.
Ranking in previous year- #6 (same as this year)
Top five sections cited-
- 1910.178(l)(1)(i) Ensuring competency of powered industrial truck operators, 617 citations
- 1910.178(l)(4)(iii) Evaluation of powered industrial truck operators performance at least once every three years, 298 citations
- 910.178(l)(6) Certification, 288 citations
- 1910.178(p)(1) Removing unsafe powered industrial trucks from service until repaired, 255 citations
- 1910.178(l)(1)(ii) Training shall consist of a combination of formal instruction, practical training, and evaluation of operator’s performance, 185 citations
Powered Industrial Trucks Training Suggestions
Here is a sample of our Forklift Safety e-learning course.
7. Ladders, 1926.1053
Ladders Resources
- Check out the regulation.
- Check out our webpage with free training materials, informational resources, and more.
- Check out our new and fun ladder safety word game.
Statistics:
Total violations- 2,625, down a little more than 100 from the 2015 total of 2,732.
Ranking in previous year- #7 (same as this year)
Top five sections cited-
1. 1926.1053(b)(1) Requires ladder side rails to extend at least three feet above an upper landing surface, 1,458
2. 1926.1053(b)(4) Use of ladders restricted to only the purpose for which they were designed, 354
3. 1926.1053(b)(13) The top or top step of a ladder shall be not be used as a step, 235
4. 1926.1053(b)(16) Tagging and removing ladders from service portable ladders with structural defects, 127
5. 1926.1053(b)(5)(i) Non-self-supporting ladders shall be used at an angle such that the horizontal distance from the top support to the foot of the ladder is approximately one-quarter of the working length of the ladder, 65
5. 1926.1053(b)(22) An employee shall not carry an object or load that could cause the employee to lose balance and fall, 75
Ladders Training Suggestion
Here is a sample of our Ladder Safety e-learning course.
8. Machine Guarding, 1910.212
Resources:
- Check out the regulation.
- Check out our webpage with free training materials, informational resources, and more.
- Check out our new and fun machine guarding word game.
Statistics:
Total violations- 2,448, a very little bit less than the previous year’s 2,540.
Ranking in previous year- #9 (one lower than this year)
Top five sections cited-
- 1910.212(a)(1) Types of guarding, 1,575 citations
- 1910.212(a)(3)(ii) Guarding the points of operations of machines whose operation exposes an employee to injury, 629 citations
- 1910.212(b) Anchoring fixed machinery, 165 citations
- 1910.212(a)(5) Exposure of blades, 72 citations
- 1910.212(a)(2) General requirements for machine guards, 58 citations
Course Sample:
Here is a sample of our machine guarding e-learning course.
9. Electrical-Wiring Methods, 1910.305
Resources:
- Check out the regulation.
- Check out our webpage with free training materials, informational resources, and more.
- Check out our new and fun electrical wiring word game.
Statistics:
Total violations– 1,937, a BIG drop from the 2015 total of 2,624.
Ranking in previous year– #8 (one lower than this year–this was a big drop and bears some scrutiny)
Top five sections cited–
- 1910.305(g)(1)(iv) Flexible cords and cables not used as substitute for fixed wiring of a structure, 338 citations
- 1910.305(b)(1)(ii) Unused openings in cabinets, boxes, and fittings shall be effectively closed, 314 citations
- 1910.305(g)(2)(iii) Flexible cords and cables shall be connected to devices and fittings so that strain relief is provided that will prevent pull from being directly transmitted to joints or terminal screws, 302 citations
- 1910.305(b)(2)(i) All pull boxes, junction boxes, and fittings shall be provided with covers identified with the purpose, 250 citations
- 1910.305(b)(1)(i) Conductors entering cutout boxes, cabinets, or fittings shall be protected from abrasion, 76 citations
Course Samples:
We have several e-learning courses related to electrical hazards. Check out the samples below.
Arc Flash Safety e-learning course.
NFPA 70E e-learning course.
10. Electrical, General Requirements, 1910.303
Resources:
- Check out the regulation.
- Check out our webpage with free training materials, informational resources, and more.
- Check out our new and fun electrical general requirements word game.
Statistics:
Total violations- 1,704, a pretty good-sized drop compared to the 2015 total of 2,181.
Ranking in previous year- #10 (same as this year)
Top five sections cited-
- 1910.303(b)(2) Installing and using equipment in accordance with instructions included in the listing or labeling, 446 citations
- 1910.303(g)(1) Space about electrical equipment, 169 citations
- 1910.303(g)(1)(3) Working space required by this standard may not be used for storage, 168 citations
- 1910.303(g)(1) Space above electrical equipment, 166 citations
- 1910.303(f)(2) Services, feeders, and branch circuits, 149 citations
Course Samples:
Electrical Safety General Awareness e-learning course.
Electric Shock e-learning course.
“Serious” and “Willful” Violations in Fiscal Year 2016: The Bad and the Even Worse
Here are the lists of serious and willful violations for 2016.
The Bad: Top Ten “Serious Violations” in Fiscal Year 2016
Let’s start with the definition again:
Serious violation: “in which there is a substantial probability that death or serious physical harm could result, and the employer knew or should have known about the hazard.”
Let’s look at that definition and break it down into two parts. First, these violations include “a substantial probability that death or serious physical harm could result.” And second, “the employer knew or should have known about the hazard.” So that’s pretty bad.
Here’s the list of serious violations:
- Fall Protection, 1926.501, 5,635 citations (6,173 last year)
- Hazard Communication, 1910.1200, 3,544 citations (3,180 last year)
- Scaffolding, 1926.451, 3,535 citations (4,281 last year)
- Lockout/Tagout, 1910.147, 3,414 citations (2,739 last year)
- Respiratory Protection, 1910.134, 2,421 citations (2,250 last year)
- Ladders, 1926.1053, 2,365 citations (2,512 last year)
- Machine Guarding, 1910.212, 2,147 citations (2,242 last year)
- Powered Industrial Trucks, 1910.178, 2,043 citations (2,182 last year)
- Electrical-Wiring Methods, 1910.305, 1,424 citations (1,976 last year)
- Electrical-General Requirements, 1910.303, 1,285 citations (1,557 last year)
What catches the attention here? How about that serious violations for all these standards went DOWN except for serious violations for Hazard Communication, which went UP pretty significantly (3,544 compared to 3,180). I’d guess this had to do with the transition to GHS alignment.
The Even Worse: Top Ten “Willful Violations” in Fiscal Year 2016
If serious violations are bad, these willful violations are worse.
Here’s the definition:
Willful violation: “committed with an intentional disregard of or plain indifference to the requirements of the Occupational Safety and Health Act.”
You shouldn’t intentionally disregard an OSHA standard and indifference is unacceptable as well.
We’re not going to analyze this list in detail–it’s pretty short and you can look at it quickly on your own–but we will point out that Fall Protection is on top of this list, just as it is with the general list. We’ll also put an asterisk (*) next to standards listed below that don’t appear on the larger general list above.
Here’s the list:
- Fall Protection, 1926.501, 173 citations (161 last year)
- Lockout/Tagout, 1910.147, 114 citations (37 last year)
- Lead, 1910.1025, 52 citations (not on the list last year)
- Excavations, 1926.652, 49 citations (not on the list last year, although 1926.651 was and had 12 citations)
- Mechanical Power Presses, 44 citations (not on last year’s list)
- Scaffolding, 1926.541, 40 citations (38 last year)
- Machine Guarding, 1910.212, 19 citations (35 last year)
- Specific Excavation Requirements, 1926.651, 19 citations (12 last year)
- General Duty Clause, 5(a)(1), 16 citations (not on the list last year)
- Grain Handling, 1910.272, and Welding, Cutting, and Heating, 1915.53, both with 14 citations (neither were on the list last year
What catches the attention here? The very significant increase in lockout/tagout willful violations, along with the items that weren’t on last year’s list…Lead (related to the situation in Flint, Michigan presumably), Excavations (related to recent risk in fatalities, presumably), and Mechanical Power Presses.
That’s all we got for you today. Leave any thoughts, comments, or questions you have about this in the comments section.
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