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ARTICLE

OSHA’s Top Ten Violations, Explored


As OSHA's 2022 fiscal year came to a close at the end of September, its acting director of Directorate of Enforcement Programs, Patrick Kapust, took to the stage at NSC Safety Congress and Expo to host a session entitled "OSHA's Top Ten Violations." During this session, which was moderated by Safety + Health's Associate Editor Kevin Druley, the latest Top 10 Most Frequently Cited Standards list was released based on preliminary data.

OSHA releases this list annually to help employers recognize ongoing workplace safety trends and focus on ways to create safer, more compliant work environments. However, NSC president and CEO Lorraine Martin stated in a press release, "Despite advancements in workplace safety, we continue to see the same types of violations each year. It's more important than ever employers seek education and resources to keep their workers safe."

This statement rings true, as Fall Protection – General Requirements tops the list for the 12th consecutive year, and other listed violations shuffled in order from last year. Notably, Hazard Communication moved from being the 5th highest cited standard in FY 21 to the 2nd highest in FY 22. Why is that, and what else should businesses consider as they review this year's list of top violations?



Top 10 most frequently cited standards for FY 2022:
  1. Fall Protection - General Requirements (1926.501): 5,980 violations
  2. Hazard Communication (1910.1200): 2,682 violations
  3. Ladders (1926.1053): 2,471 violations
  4. Respiratory Protection (1910.134): 2,430 violations
  5. Scaffolding (1926.451): 2,285 violations
  6. Lockout/Tagout (1910.147): 2,175 violations
  7. Powered Industrial Trucks (1910.178): 1,922 violations
  8. Fall Protection - Training Requirements (1926.503): 1,778 violations
  9. Personal Protective and Lifesaving Equipment - Eye and Face Protection (1926.102): 1,582 violations
  10. Machine Guarding (1910.212): 1,488 violations


Why is Fall Protection First… Again?

Fall Protection – General Requirements was ranked as the #1 most violated standard for the 12th year. This may be surprising to some, as continued advancements in product technology and a heightened focus on improving workplace safety would ideally cause violations of this standard to decrease. Unfortunately, many Fall Protection Programs still fall short. How can this be remedied?

First, businesses must do more than aim to comply when creating their fall protection programs. Taking a more holistic, proactive approach is critical to avoiding fall protection-related incidents, injuries, and citations. A robust fall protection program that includes training, inspection, and oversight parameters helps keep your business safe, productive, and compliant, but there is more. Companies must also prioritize building and maintaining effective safety cultures to improve adoption of all parts of their Safety Programs.

Is Documentation Your Downfall?

Why did Hazard Communication climb from 5th to 2nd on the list? Businesses were cited under the Hazard Communication standard 2,424 times in FY 22, compared to 1,947 citations in FY 21. This standard, 1910.1200, requires a proper HazCom program, hazard classification, labels, and worker training.

The standard also details the requirement for employers to document the hazard identification, first aid measures, storage, and transport information of each chemical used, produced, or imported in their workplace. This documentation is done on Safety Data Sheets (SDS), which must contain all 16 required sections and be available in English. Another critical component of this standard is that any changes to a chemical must be updated on the SDS promptly to avoid any employee injury or illness that may occur as a result of this change. Documentation can be a headache, but old, outdated SDS can cause significant harm to employees and, by extension, your bottom line. Ensuring your Hazard Communication program is properly managed is crucial to your business operations.

Is Your Training Program Falling Short?

Under the Fall Protection – Training Requirements standard, which ranked #8 on the 2022 Top Violations list, employers must put their employees through a fall protection training program, but that's not all. The education provided must meet specific criteria, and the employer must provide a written certification and be sure to include the employee's name, date, and signature. Fall protection training must include hazard identification, procedural review, and education around fall protection and fall arrest systems in the workplace. Remember, this training needs to occur when employees become unfamiliar with the content or when the equipment changes.

Employers must be intentional about the content, cadence, and communicator chosen to deliver this essential training. In the construction industry, a competent person must provide this training. Fall protection training programs are meant to decrease fall-related injury, illness, and fatality in the workplace, but these programs only work as hard as you do.

The Bottom Line

Navigating OSHA standards and other local, state, and federal regulations relevant to a particular sector can take time and effort. Businesses around the globe need support to maintain safe, productive, compliant operations amidst rising materials costs, labor shortages, and evolving workplace safety requirements. Wesco can help. Our specialized teams are committed to making it easier than ever for you to protect your greatest asset – your workforce.



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Lorenza Ordonez

ABOUT THE AUTHOR

Lorenza Ordonez, Director of Global Safety Sales, Wesco
Lorenza Ordonez joined Wesco in 2022 as Director of Safety Sales for our Communications and Security Solutions (CSS) strategic business unit. Within this role, Ordonez is responsible for articulating strategies that drive positive outcomes for our safety business, and empowering our CSS organization to deliver comprehensive safety solutions to the global customers we serve. Ordonez brings decades of expertise in safety, strategic market analysis, and sales management to Wesco.