OSHA’s Top Ten Violations, 2015

osha-top-10-violations-2015Every year at the National Safety Council’s Safety Congress and Expo, OSHA releases its list of the ten most cited violations from the previous fiscal year.

That list for fiscal year 2015 was released in October of 2015.

Then, in December, OSHA updates that list with additional statistics, providing a more comprehensive, detailed look at the violations.

OSHA’s now released those additional statistics as well. And we’ve got all the information for you below.

Check out the list below. We’ve also included links to additional webpages related to each of the commonly violated standards–the additional pages include free training materials, fun word games, interactive glossaries, additional helpful information about the regulation and how to avoid violating it, free safety checklists, and more.

Five Things That Stand Out

Here’s OSHA list of the most commonly cited standard violations for fiscal year 2015, including the additional statistics OSHA released in December, 2015.

One thing that stands out is that all ten standards were on list year’s list too. The only difference is that last year’s #5 and #6 switch places on this year’s list. Last year, the Powered Industrial Trucks standard was #5 on the list and it’s #6 this year, and Lockout/Tagout moved from #6 last year to #5 this year.

Another thing that stands out is the large number of Fall Protection citations (7,402). That’s nearly 2,000 more citations than for the second standard on the list (Hazard Communication, 5,681). In fact, the section of the Fall Protection standard that is most commonly cited, Residential Construction, has 4,079 citations all on its own–that’s enough to place it number four on this entire list!

A third thing that stands out is that 8 of the 10 standards on the list had fewer citations this year than last year, and 2 of the 10 standards saw more citations this year than last year from last year. It’s encouraging that 8 of the 10 standards saw a drop in citations, although it’s not clear why. We’d like to believe it’s because people are violating fewer standards and working more safely, but that’s hard to prove. On the other hand, it’s discouraging that the number of citations increased for two standards. These include Lockout/Tagout, which increased from 3,117 to 3,308 (an overall increase of 191, which is 6.1% of the earlier year’s total), and Machine Guarding, which increased from 2,520 to 2,540 (a smaller overall increase of 20, which is 0.8% of the earlier year’s total).

The fourth thing that pops out is that OSHA also included the number of “willful” and “serious” violations for the year. OSHA defines a “willful” violation as a violation “committed with an intentional disregard of or plain indifference to the requirements of the Occupational Safety and Health Act.” And they define a “serious” violation as 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.” We’ve included lists of serious willful violations near the bottom of this article.

The final thing that stands out is that OSHA also included a list of the ten largest proposed penalties for fiscal year 2015. We should strive for safety for all the right reasons, but if you wonder what the stick is that accompanies the carrot, these penalties are eye-opening. This list is at the very bottom of this article.

And with that intro, let’s get on with lists.

OSHA’s Top Ten Citations List, Fiscal Year 2015

Here are the top ten citations, listed from the standard with the most citations to the standard with the tenth-most citations.

1. Fall Protection, 1926.501

Resources:

Statistics:

Total citations- 7,402. A little less than the previous year, when there were 7,516.

Ranking in previous year-#1 last year (same as this year)

Top five sections cited-

  1. 1926.501(b)(13) Residential construction, 4,079 citations
  2. 1926.501(b)(1) Unprotected sides and edges, 1,385 citations
  3. 1926.501(b)(10) Roofing work on low-slope roofs, 718 citations
  4. 1926.501(b)(11) Steep roofs, 542 citations
  5. 1926.501(b)(4)(I) Protection from falling through holes, 151 citations

Course Sample:

Here’s a sample of our Fall Prevention and Protection e-learning course.

2. Hazard Communication, 1910.1200

Resources:

Statistics:

Total citations- 5,681, a little less than the previous year’s 6,148.

Ranking in previous year- #2 last year (same as this year)

Top five sections cited-

  1. 1910.1200(e)(1) Developing, implementing, and maintaining a written hazard communication program, 1746 citations
  2. 1910.1200(h)(1) Providing effective information and training on hazardous chemicals to workers, 1,350 citations
  3. 1910.1200(g)(8) Maintaining safety data sheets (SDSs) and keeping the readily accessible, 505 citations
  4. 1910.1200(h)(3)(iv) Employee training on the hazard communication program, 496 citations
  5. 1910.1200(g)(1) Developing and maintaining safety data sheets (SDSs), 352 citations

Course Sample:

And here’s a sample of our Hazard Communication e-learning course.

3. Scaffolding, 1926.451

Resources:

Statistics:

Total citations- 4,681, a little less than the previous year’s 4,968.

Ranking in previous year- #3 (same as this year)

Top five sections cited-

  1. 1926.451(g)(1) Employee fall protection, 788 citations
  2. 1926.451(e)(1) Means of access to scaffold platforms through means such as stairs or ladders, 644 citations
  3. 1926.451(b)(1) Platform to be fully planked or decked between front uprights and guardrail supports, 577 citations
  4. 1926.451(g)(1)(vii) Fall arrest or guardrail systems on unspecified scaffolds, 403 violations
  5. 1926.451(c)(2) Adequate firm foundation for supported scaffold poles, legs, posts, frames, and uprights, 266 citations

Course Sample:

And here’s a sample of our Scaffolding e-learning course.

4. Respiratory Protection, 1910.134

Resources:

Statistics:

Total citations- 3,626, a little less than the previous year’s 3,843.

Ranking in previous year- #4 (same as this year)

Top five sections cited-

  1. 1910.134(e)(1) Medical evaluation general requirements, 670 citations
  2. 1910.134(c)(1) Establishing and implementing a written respiratory protection program, 527 citations
  3. 1910.134(f)(2) Fit testing prior to first use, whenever a different facepiece is used, and annually, 330 citations
  4. 1910.134(c)(2)(i) Permitting employees to voluntarily use their own respirators if such use will not create a hazard, 262 citations
  5. 1910.134(d)(1)(iii) Identifying and evaluating respiratory hazards, 232 citations

Course Sample:

And here’s a sample of our Respiratory Protection e-learning course.

5. Lockout/Tagout, 1910.147

Resources:

Statistics:

Total citations- 3,308, a little more than the previous year’s 3,117. Notice this is the first standard on the list that saw an increase in citations instead of a decrease.

Ranking in previous year- #6 (one lower than this year, meaning this crawled up a notch on the list this year)

Top five sections cited-

  1. 1910.147(c)(4)(i) Establishing and training employees on energy control procedures, 627 citations
  2. 1910.147(c)(1) Energy control program, 445 citations
  3. 1910.147(c)(6)(i) Annual periodic inspection of energy control procedure, 424 citations
  4. 1910.147(c)(7)(i) Employee training on purpose and function of energy control program, 277 violations
  5. 1910.147(d)(4)(i) Lockout or tagout device application, 197 violations

Course Sample:

Here’s a sample of our Lockout/Tagout e-learning course.

6. Powered Industrial Trucks, 1910.178

Resources:

Statistics:

Total violations- 3,004, a little less than the previous year’s 3,147.

Ranking in previous year- #5 (one higher than this year, as Lockout/Tagout leapfrogged from #6 to #5)

Top five sections cited-

  1. 1910.178(l)(1)(i) Ensuring competency of powered industrial truck operators, 544 citations
  2. 1910.178(l)(4)(iii) Evaluation of powered industrial truck operators performance at least once every three years, 339 citations
  3. 1910.178(p)(1) Removing unsafe powered industrial trucks from service until repaired, 281 citations
  4. 1910.178(l)(6) Certification, 264 citations
  5. 1910.178(q)(7) Examination of industrial trucks before placing into service on a daily or per-shift basis, 211 citations

Course Sample:

Here is a sample of our Forklift Safety e-learning course.

7. Ladders, 1926.1053

Resources:

Statistics:

Total violations- 2,732, a little less than the previous year’s 2,967.

Ranking in previous year- #7 (same as this year)

Top five sections cited (note there’s a 2-way tie for spot #5)-

1. 1926.1053(b)(1) Requires ladder side rails to extend at least three feet above an upper landing surface, 1,512

2. 1926.1053(b)(4) Use of ladders restricted to only the purpose for which they were designed, 365

3. 1926.1053(b)(13) The top or top step of a ladder shall be not be used as a step, 278

4. 1926.1053(b)(16) Tagging and removing ladders from service portable ladders with structural defects, 150

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, 65

Course Sample:

Here is a sample of our Ladder Safety e-learning course.

8. Electrical-Wiring Methods, 1910.305

Resources:

Statistics:

Total violations– 2,624, a little less than the previous year’s 2,967.

Ranking in previous year– #8 (same as this year)

Top five sections cited

  1. 1910.305(g)(1)(iv) Flexible cords and cables not used as substitute for fixed wiring of a structure, 447 citations
  2. 1910.305(b)(1)(ii) Unused openings in cabinets, boxes, and fittings shall be effectively closed, 433 citations
  3. 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, 428 citations
  4. 1910.305(b)(2)(i) All pull boxes, junction boxes, and fittings shall be provided with covers identified with the purpose, 329 citations
  5. 1910.305(b)(1)(i) Conductors entering cutout boxes, cabinets, or fittings shall be protected from abrasion, 115 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.

 

9. Machine Guarding, 1910.212

Resources:

Statistics:

Total violations- 2,540, a very little bit more than the previous year’s 2,520. Still, it’s noteworthy that this is only the second standard on the list that saw an increase in citations.

Ranking in previous year- #9 (same as this year)

Top five sections cited-

  1. 1910.212(a)(1) Types of guarding, 1,575 citations
  2. 1910.212(a)(3)(ii) Guarding the points of operations of machines whose operation exposes an employee to injury, 629 citations
  3. 1910.212(b) Anchoring fixed machinery, 165 citations
  4. 1910.212(a)(5) Exposure of blades, 72 citations
  5. 1910.212(a)(2) General requirements for machine guards, 58 citations

Course Sample:

Here is a sample of our machine guarding e-learning course.

10. Electrical, General Requirements, 1910.303

Resources:

Statistics:

Total violations- 2,181, less than the previous year’s 2,427.

Ranking in previous year- #10 (same as this year)

Top five sections cited-

  1. 1910.303(b)(2) Installing and using equipment in accordance with instructions included in the listing or labeling, 606 citations
  2. 1910.303(g)(1) Space about electrical equipment, 238 citations
  3. 1910.303(g)(2) Using approved cabinets to guard live parts operating at 50 volts or more, 223 citations
  4. 1910.303(g)(1) Working space required by this standard may not be used for storage, 186 citations
  5. 1910.303(f)(2) Services, feeders, and branch circuits, 168 citations

Course Samples:

Electrical Safety General Awareness e-learning course.

Electric Shock e-learning course.

From Bad to Worse: “Serious” and “Willful” Violations in Fiscal Year 2015

Now that we’ve presented the inclusive “general” list of all the Top Ten citations, let’s look at two smaller lists OSHA put together: the top ten “serious” and “willful” violations. Although the items in each of these lists include a smaller number of citations than the items in the general list above (these are sub-sets, remember), the serious and willful nature of the violations makes them very important.

As a reminder, here are some definitions from OSHA:

  • 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.”
  • Willful violation:  “committed with an intentional disregard of or plain indifference to the requirements of the Occupational Safety and Health Act.”

Top Ten “Serious Violations” in Fiscal Year 2015

If you read the definition above, you’ll notice it has two aspects. 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.” That second part is especially bad.

You’ll notice that every standard on this list also appears on the larger, inclusive “general” list above, and that Fall Protection is on top once again.

Here’s the list:

1. Fall Protection, 1926.501, 6,173 citations

2. Scaffolding, 1926.451, 4,281 citations

3. Hazard Communication, 1910.1200, 3,180 citations

4. Lockout/Tagout, 1910.147, 2,739 citations

5. Ladders, 1926.1053, 2,512 citations

6. Respiratory Protection, 1910.134, 2,250 citations

7. Machine Guarding, 1910.212, 2,242 citations

8. Powered Industrial Trucks, 1910.178, 2,182 citations

9. Electrical-Wiring Methods, 1910.305, 1,976 citations

10. Electrical-General Requirements, 1910.303, 1,557 citations

Top Ten “Willful Violations” in Fiscal Year 2015

These are bad. 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:

1. Fall Protection, 1926.501, 161 citations

*2. Asbestos, 1926.1101, 47 citations

*3. Excavations, 1926.652, 44 citations

4. Scaffolding, 1926.451, 38 citations

5. Lockout/Tagout, 1910.147, 37 citations

6. Machine Guarding, 1910.212, 35 citations

*7. Permit-Required Confined Spaces, 1910.147, 22 citations

*8.Specific Excavation Requirements, 1926.651, 12 citations

*9. Fall Protection-Steel Erection, 1926.760, 11 citations

10. Respiratory Protection, 1926.134, 10 citations

*10. Occupational Noise Exposure, 1910.95, 10 citations

*10.Bloodborne Pathogens, 1910.1030, 10 citations

 

Source: All the information in this article about the various OSHA Top Ten lists come from the December issue of Safety+Health magazine, in an article titled “OSHA’s Top Ten: Growing Data and Changing Inspection Strategies.” The link you just passed gives you the online version. If you’re looking at the print version, the article begins on page 47.

EHS-training-course-library

OSHA’s Top Ten Proposed Penalties for Fiscal Year 2015

Here’s a list of OSHA’s biggest proposed penalties for the fiscal year. Remember, these are proposed penalties, so the companies may end up paying less.

1. $1.94 million, Joseph Kehrer/Kehrer Brothers Construction/D7 Roofing–16 egregious, nine willful, and six serious violations.

2. $1.77 million, Ashley Furniture–More than 1,0000 work-related injuries over a three-year period at their Winesburg, Ohio location.

3. $861,500, Case Farms Processing, Inc.–Many hazards and violations

4. $822,000, Lloyd Industries, Inc.–An amputation injury and, OSHA claims, “a pattern of defiance toward OSHA standards.”

5. $604,300, Case Farms Processing, Inc. (Canton, Ohio location); and Callaghan and Callaghan–Two amputation injuries, many violations.

6. $530,000, Fastrack Erectors, Inc. and ARCO National Construction–KC Inc.–Fatal fall while working from heights, multiple violations.

7. $490,000, First Capital Insulation, Inc.–Asbestos exposure and multiple violations.

8. $477,900, Alfa Laval, Inc.–Violations discovered during inspection, many of which were noted in previous inspections; multiple violations.

9. $470,300, DMAC Construction LLC–Scaffolding hazards at multiple worksites; multiple violations.

10. $423,900, Hassell Construction Co., Inc.–Trenching-related injury, multiple violations.

Download Our Free Guide to Effective EHS Training

Once you’re done checking out the list above, and the links to the associated resources and free training materials, download our free 42-page guide to Effective EHS Training and start doing what you can to cut down the number of violations at your workplace.

effective-EHS-training-guide

 

 

Jeffrey Dalto

Jeffrey Dalto

Jeffrey Dalto is an Instructional Designer and the Senior Learning & Development Specialist at Convergence Training. He's worked in training/learning & development for 25 years, in safety and safety training for more than 10, is an OSHA Authorized Outreach Trainer for General Industry OSHA 10 and 30, has completed a General Industry Safety and Health Specialist Certificate from the University of Washington/Pacific Northwest OSHA Education Center and an Instructional Design certification from the Association of Talent Development (ATD), and is a member of the committee creating the upcoming ANSI/ASSP Z490.2 national standard on online environmental, health, and safety training. Jeff frequently writes for magazines related to safety, safety training, and training and frequently speaks at conferences on the same issues, including the Washington Governor's Safety and Health Conference, the Oregon Governor's Occupational Safety and Health Conference, the Wisconsin Safety Conference, the MSHA Training Resources Applied to Mining (TRAM) Conference, and others.

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