OSHA’s Top 10An Analysis of the Most Cited

Workplace Violations in 2017

Meet Your Moderator:

James Ciccone

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Webinar Overview

Meet Your Presenter

Mark LiffersPractice Director – EHS

Consulting

mliffers@triumvirate.com

What Can You Expect?

Overview of Current “Top 10”

Insight on Most Common Violations

Recommendations for Avoiding Citations

Poll Question

How prepared are

you for your next

OSHA inspection?

Agenda

OSHA Update

OSHA’s Top 10

Strategies for Improving Your OSHA programs

Summary/Q&A

• May 11, 2016 Final Rule

• Establishments with 20-249 employees in certain high-risk industries

must submit information from their 2016 Form 300A by July 1, 2017*,

and their 2017 Form 300A by July 1, 2018.

• Beginning in 2019 and every year thereafter, the information must be

submitted by March 2.

• *OSHA published a notice of proposed rulemaking on June 27, 2017 to

extend the date by which employers are required to submit the

information from July 1, 2017 to December 1, 2017.

Electronic Reporting Delayed

• President Trump signed the Volks Rule Congressional Review Act

authorization directing that this regulation issued in 2016 be expunged on

April 3, 2017.

• Finalized Dec 19, 2016 the “Volks Rule” was issued to allow OSHA to cite

employers for failure to record an injury or illness for up to six months

following the five-year record retention period that would have applied to

such a record had it been made in the first place

• The language of the OSH Act provides that OSHA cannot cite an employer

“after the expiration of six months following the occurrence of any

violation”.

• OSHA is again prohibited from issuing citations for injury or illness record-

keeping violations outside the OSH Act’s six-month statute of limitations.

Volks Rule Repealed

Moved to ‘long-term’ actions:

• Updates to a host of chemical exposure

permissible exposure limits

• Hearing protection for construction

workers

• Vehicle backing hazards in general

industry and construction

OSHA Rulemaking

Indefinitely delayed:

• Reforms to the process safety management

standard developed in response to the 2013

fertilizer plant explosion in West, Texas

• A new regulation addressing emergency

response and preparedness

• A new standard to address infectious diseases

in health care

OSHA Rulemaking

Rulemaking that remains active:

• A new standard addressing

communications tower safety

• An update to the powered industrial

truck standard

• An amendment to the regulation for

mechanical power presses

OSHA Rulemaking

Type of Violation Penalty

Serious

Other-Than-Serious

Posting Requirements

$12,675 per violation

Failure to Abate $12,675 per day beyond the

abatement date

Willful or Repeated $126,749 per violation

https://www.osha.gov/penalties/

OSHA Penalties

OSHA Enforcement

OSHA conducted 31,948 total inspections in 2016

19,217 inspections were unprogrammed

OSHA issued 58,702 total violations

https://www.osha.gov/dep/2016_enforcement_summary.html

Agenda

OSHA Update

OSHA’s Top 10

Strategies for Improving Your OSHA programs

Summary/Q&A

OSHA’s Top 10 for 20171. Fall Protection – General Requirements

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

6. Ladders

7. Powered Industrial Trucks

8. Machine Guarding

9. Fall Protection – Training Requirements

10. Electrical – Wiring Methods

Fall Protection –

General Requirements

(1926.501)

6,072 violations

OSHA requires that fall protection be

provided at elevations of four feet in

general industry workplaces, six feet

in the construction industry.

Fall Protection –

General Requirements

Fall Protection• ANSI Z359 fall protection series of standards

• ANSI Z359.1 Safety requirements for personal

fall arrest systems, subsystems and components

• ANSI Z359.2 Minimum requirements for a

comprehensive managed fall protection program

• ANSI Z359.3 Safety requirements for positioning

and travel restraint systems

• ANSI Z359.4 Safety requirements for assisted-

rescue and self-rescue systems, subsystems

and components

OSHA’s Top 10 for 20171. Fall Protection – General Requirements

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

6. Ladders

7. Powered Industrial Trucks

8. Machine Guarding

9. Fall Protection – Training Requirements

10. Electrical – Wiring Methods

Hazard

Communication

(1910.1200)

4,176 violations

Requires chemical manufacturers or importers to

classify the hazards of chemicals which they produce

or import, and all employers to provide information to

their employees about the hazardous chemicals to

which they are exposed, by means of a hazard

communication program, labels and other forms of

warning, safety data sheets, and information and

training.

Hazard

Communication

Hazard Communication

Plan ContentEmployers shall develop, implement, and

maintain at each workplace, a written hazard

communication program which at least

describes how the criteria of this section for

labels and other forms of warning, safety data

sheets, and employee information and

training will be met.

• A list of the hazardous chemicals known to be present

using a product identifier that is referenced on the

appropriate safety data sheet (the list may be compiled

for the workplace as a whole or for individual work

areas); and,

• The methods the employer will use to inform employees

of the hazards of non-routine tasks (for example, the

cleaning of reactor vessels), and the hazards

associated with chemicals contained in unlabeled pipes

in their work areas.

Hazard Communication

Plan Content

• The employer shall make the written hazard

communication program available, upon request, to

employees, their designated representatives, the

Assistant Secretary and the Director.

• Where employees must travel between workplaces

during a work shift, i.e. their work is carried out at

more than one geographical location, the written

hazard communication program may be kept at the

primary workplace facility.

Hazard Communication

Plan Content

OSHA’s Top 10 for 20171. Fall Protection – General Requirements

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

6. Ladders

7. Powered Industrial Trucks

8. Machine Guarding

9. Fall Protection – Training Requirements

10. Electrical – Wiring Methods

Scaffolding

(1926.451)

3,288 violations

Suspended Scaffolds

Scaffolding

Supported Scaffolds

Scaffolding

Scissor Lifts

Scaffolding

Aerial Lifts

Scaffolding

OSHA’s Top 10 for 20171. Fall Protection – General Requirements

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

6. Ladders

7. Powered Industrial Trucks

8. Machine Guarding

9. Fall Protection – Training Requirements

10. Electrical – Wiring Methods

Respiratory

Protection

(1910.134)

3,097 violations

Respiratory

Protection Plan• A respirator shall be provided to each employee when such

equipment is necessary to protect the health of such employee.

• The employer shall provide the respirators which are applicable

and suitable for the purpose intended. The employer shall be

responsible for the establishment and maintenance of a

respiratory protection program.

• The program shall cover each employee required by this

section to use a respirator.

OSHA’s Top 10 for 20171. Fall Protection – General Requirements

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

6. Ladders

7. Powered Industrial Trucks

8. Machine Guarding

9. Fall Protection – Training Requirements

10. Electrical – Wiring Methods

Lockout/Tagout

(1910.147)

2,877 violations

• This standard covers the servicing and

maintenance of machines and

equipment in which the unexpected

energization or start up of the machines

or equipment, or release of stored

energy, could harm employees.

• This standard establishes minimum

performance requirements for the

control of such hazardous energy.

Lockout/Tagout

• Procedures shall be developed, documented

and utilized for the control of potentially

hazardous energy when employees are

engaged in the activities covered by this

section.

• The procedures shall clearly and specifically

outline the scope, purpose, authorization,

rules, and techniques to be utilized for the

control of hazardous energy, and the means to

enforce compliance including, but not limited

to, the following:

Lockout/Tagout

• A specific statement of the intended use of the

procedure;

• Specific procedural steps for shutting down,

isolating, blocking and securing machines or

equipment to control hazardous energy;

• Specific procedural steps for the placement,

removal and transfer of lockout devices or

tagout devices and the responsibility for them;

and

• Specific requirements for testing a machine or

equipment to determine and verify the

effectiveness of lockout devices, tagout devices,

and other energy control measures.

Lockout/Tagout

OSHA’s Top 10 for 20171. Fall Protection – General Requirements

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

6. Ladders

7. Powered Industrial Trucks

8. Machine Guarding

9. Fall Protection – Training Requirements

10. Electrical – Wiring Methods

Ladders

(1926.1053)

2,241 violations

Falls from portable ladders (step,

straight, combination and

extension) are one of the leading

causes of occupational fatalities

and injuries

Ladders

29 CFR 1910.23• In late 2016, OSHA published an update to

its walking-working surface rules for

general industry.

• As part of the update, OSHA combined its

previously separate regulations for

portable wood ladders, portable metal

ladders and fixed ladders under one

comprehensive ladder standard.

Ladders

OSHA’s Top 10 for 20171. Fall Protection – General Requirements

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

6. Ladders

7. Powered Industrial Trucks

8. Machine Guarding

9. Fall Protection – Training Requirements

10. Electrical – Wiring Methods

(1910.178)

2,162 violations

Powered Industrial

Trucks

Powered Industrial

Trucks(OSHA) defines a powered

industrial truck as a mobile,

power-propelled truck used

to carry, push, pull, lift,

stack or tier materials.

• Training program based on the general principles of safe truck operation, the

types of vehicle(s) being used and the hazards they create

• Trained operators must know how to do the job properly and safely, as

demonstrated by workplace evaluations.

• Formal (classroom, lecture) training

• Practical (demonstration and practical exercises) training

• Employers must also certify that each operator has received the training and

evaluate each operator’s performance at least once every three years.

Powered Industrial Trucks

OSHA’s Top 10 for 20171. Fall Protection – General Requirements

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

6. Ladders

7. Powered Industrial Trucks

8. Machine Guarding

9. Fall Protection – Training Requirements

10. Electrical – Wiring Methods

Machine Guarding

(1910.212)

1,933 violations

Machine GuardingAmputations are among the most

severe and disabling

workplace injuries that often

result in permanent disability.

They are widespread and involve

various activities and equipment.

Machine GuardingANSI B11 series of American

National Standards and Technical

Reports consists of nearly three

dozen different documents that deal

with machine / machinery / machine

tool safety, and they specify

requirements for both the

manufacturers (suppliers) and users

of the machines.

OSHA’s Top 10 for 20171. Fall Protection – General Requirements

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

6. Ladders

7. Powered Industrial Trucks

8. Machine Guarding

9. Fall Protection – Training Requirements

10. Electrical – Wiring Methods

Fall Protection – Training

Requirements

(1926.503)

1,523 violations

Fall Protection – Training

Requirements• Performance-based, use methods that are most effective.

• Classroom, audio-visual, demonstrations, field training, web-based,

computer-based or other forms of training

• Training must be performed by a qualified person and if web, video or

computer-based methods are used, a qualified person must be available to

answer questions.

OSHA’s Top 10 for 20171. Fall Protection – General Requirements

2. Hazard Communication

3. Scaffolding

4. Respiratory Protection

5. Lockout/Tagout

6. Ladders

7. Powered Industrial Trucks

8. Machine Guarding

9. Fall Protection – Training Requirements

10. Electrical – Wiring Methods

Electrical – Wiring

Methods

(1910.305)

1,405 violations

NFPA 70:

National Electrical Code (NEC)

Electrical – Wiring

Methods

Agenda

OSHA Update

OSHA’s Top 10

Strategies for Improving Your OSHA programs

Summary/Q&A

Improving OSHA Programs

Safety 101 - Simple?

• Management sets safety policies and procedures.

• After employees are hired, they're trained on safe

work practices.

• Supervisors watch workers or have them watch

each other to prevent unsafe actions.

• Inspections find safety problems which are then

corrected.

Agenda

OSHA Update

OSHA’s Top 10

Strategies for Improving Your OSHA programs

Summary/Q&A

Summary

OSHA Rulemaking

Top 10 is Consistent

Have a Clear Strategy!

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Contact Mark Liffers:

mliffers@triumvirate.com