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OSHA’s 2019 Top 10 Violations What You Can
do to Prevent Similar Violations.
Laura SmithIndustrial Safety Consultant Specialist
Ohio BWC- Division of Safety and HygienePhone: 419-528-9120
Email: [email protected]
The results are in from the BLS Survey of Occupational Injuries and Ill-nesses (SOII) for 2018.
2017 State of Ohio Manufacturing injuries
2017 Richland County Manufacturing Injuries
2017 Manufacturing InjuriesOhio Richland County
Most Cited OSHA Citations through the years20161. Fall Protection (1926.501)2. Hazard Communication (1910.1200)3. Scaffolding (1926.451)4. Respiratory Protection (1910.134)5. Control of Hazardous Energy - Lockout/Tagout (1910.147)6. Powered Industrial Trucks (1910.178)7. Ladders (1926.1053)8. Machine Guarding - General Requirement (1910.212)9. Electrical - Wiring Methods (1910.305)10. Electrical - General Requirement (1910.303
20171. Fall Protection (1926.501)2. Hazard Communication (1910.1200)3. Scaffolding (1926.451)4. Respiratory Protection (1910.134)5. Control of Hazardous Energy - Lockout/Tagout (1910.147)6. Ladders (1926.1053)7. Powered Industrial Trucks (1910.178)8. Machine Guarding– General Requirement (1910.212)9. Fall Protection – Training Requirements (1926.503)10. Electrical – Wiring Methods (1910.305)
Top 10 Most Frequently Cited Standardsfor Fiscal Year 20181. Fall protection, construction (29 CFR 1926.501) 2. Hazard communication standard, general industry (29 CFR 1910.1200) 3. Scaffolding, general requirements, construction (29 CFR 1926.451) 4. Respiratory protection, general industry (29 CFR 1910.134) 5. Control of hazardous energy (lockout/tagout), general industry (29 CFR 1910.1476. Ladders, construction (29 CFR 1926.1053) 7. Powered industrial trucks, general industry (29 CFR 1910.178) 8. Fall Protection–Training Requirements (29 CFR 1926.503) 9. Machinery and Machine Guarding, general requirements (29 CFR 1910.212) 10. Eye and Face Protection (29 CFR 1926.102)
Top 10 Most Frequently Cited Standardsfor Fiscal Year 2019 (Oct. 1, 2018, to Sept. 30, 2019).1. Fall protection, construction (29 CFR 1926.501)
2. Hazard communication standard, general industry (29 CFR 1910.1200)
3. Scaffolding, general requirements, construction (29 CFR 1926.451)
4. Control of hazardous energy (lockout/tagout), general industry (29 CFR 1910.147)
5. Respiratory protection, general industry (29 CFR 1910.134)
6. Ladders, construction (29 CFR 1926.1053)
7. Powered industrial trucks, general industry (29 CFR 1910.178)
8. Fall Protection–Training Requirements (29 CFR 1926.503)
9. Machinery and Machine Guarding, general requirements (29 CFR 1910.212)
10. Eye and Face Protection (29 CFR 1926.102)
10. Personal Protective and Lifesaving Equipment—Eye and Face Protection: 1926.102
Prevention tips 1. Conduct a Job Hazard Assessment
◦ Determine job site hazards
2. Hierarchy of Control◦ Eliminate◦ Substitute◦ Engineering Controls◦ Administrative Controls◦ Personal Protective Equipment
3. Training
4. Enforcement
9. Machine Guarding: 1910.212
Prevention tips Machine Guarding assessment for hazardous points
Determine best way to guard machine◦ Fixed◦ Adjustable◦ Self-Adjustable◦ Devices◦ Misc. Aids
Training
Enforcement
8. Fall Protection—Training Requirements: 1926.503
Prevention tips Determine and train competent person
◦ Competent person: one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.
Competent person:◦ Assesses worksite◦ Determines fall protection requirements
Competent person trains other employees
Document training appropriately
7. Powered Industrial Trucks: 1910.178
Prevention tips Train employees
◦ Classroom◦ Hands on with evaluation◦ Documented
◦ License (forklift and drivers) not required
Conduct recertification every 3 years◦ Retrain when deficiencies are observed
Conduct daily operator inspections◦ Pre-shift ◦ Once prior to use if one shift operation
6. Ladders: 1926.1053
Prevention tips Assess worksite for appropriate ladder size
Use ladder as the manufacturer intended◦ Correct angle (extension ladder)
◦ 4 to 1 angle
◦ NIOSH Ladder App
◦ 3 rungs above landing surface◦ Never use the top step to stand on
Inspect ladder frequently
5. Respiratory Protection: 1910.134
Prevention tips Determine PEL of hazard
◦ IH Sampling
Determine most appropriate respirator per hazard
Medical evaluation and fit testing for respirator users◦ Annually◦ Documented
Voluntary program◦ MUST provide employees with Appendix D
Voluntary Use - Appendix D
4. Lockout/Tagout: 1910.147
Prevention tips Develop a written program
Determine and train Authorized users◦ Proper LOTO procedure◦ Periodic inspections◦ Maintenance and Servicing
Maitenance or Servicing
Constructing Equipment
Electrical work
Changing tooling
Set up
Clearing jammed materials
Cleaning
Removing equipment
Modifying equipment
Lubrication
Repairing Equipment
Installing Equipment
Prevention tips Develop a written program
Determine and train Authorized users◦ Proper LOTO procedure◦ Periodic inspections◦ Maintenance and Servicing◦ Minor Serving Exception
Train Affected and Other employees
Enforce use of LOTO
3. Scaffolds—General Requirements: 1926.451
Prevention tips Designate a competent person
◦ "one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.”
Follow manufactures instruction on set up and use◦ Never climb the braces unless indicated by the manufacture
◦ Use a ladder, stairs, etc. to access the scaffold
◦ Fully planked◦ Fall Prevention/Protection◦ Stable foundation
2. Hazard Communication: 1910.1200
Prevention tips4 elements of Hazard Communication Standard
1. Written Program2. Chemical Inventory List
◦ Table of Contents in SDS book
3. Safety Data Sheets (SDS)◦ Secondary container labeling
◦ NFPA, HMIS, GHS, Company specific
4. Employee Training◦ Initially upon hire, new job, non-routine task
1. Fall Protection—General Requirements: 1926.501
Prevention tips Competent Person
Know when to be protected◦ Construction = 6 foot & General Industry = 4 foot
Fall Prevention◦ Guard Rail System, Safety Net
Fall Protection◦ Anchor, Body Harness, Connectors
Warning lines and Safety Monitor◦ Low-slope Roofing
Conclusion Utilize resources OSHA.GOV
◦ OSHA Small Business Guide◦ Compliance Directive◦ What to do When OSHA Knocks?
Ohio BWC Division of Safety and Hygiene◦ Consultant visits
◦ Safety, Ergonomic, Industrial Hygiene (non-regulatory)
◦ PERRP
◦ OSHA On-Site
◦ Training classes◦ Safety program review and development
OSHA 2020 Plan January- Inaugurate a Small Business Regulatory Enforcement Fairness Act review panel that will begin an effort to create a standard designed to address workplace violence in the healthcare and social services industries
April- Intends to release a notice of proposed rulemaking for the walking-working surfaces rule to clarify requirements for stair rail systems
May- Issue a proposal to amend parts of the cranes and derricks in construction standard, as well as those that deal with industrial trucks
June- release proposed rule on occupational exposure to crystalline silica (meeting current Construction requirements)
November- propose rules regarding post-incident drug testing and safety incentive programs
OSHA 2020 Plan OSHA also says it will begin the process of analyzing comments that it received after issuing requests for information regarding potential revisions to its lockout/tagout and powered industrial truck regulations. OSHA is seeking to revise both regulations as evolving technologies have affected each and hopes to bring both of the regulations up to date and in line with current consensus standards.
In addition to the upcoming proposed rules, OSHA has several agenda items that are in the pre-rule stage. These include initiation a Small Business Regulatory Enforcement Fairness Act panel in August for the development of an Emergency Response rule, a request for information slated for July as a preliminary to updating the Mechanical Power Press rule (which hasn’t been updated in 40 years), and the issuance of an advanced notice of proposed rulemaking in September for the Blood Lead Level for Medical Removal rule.
Questions?