If you want a safer workplace, and to avoid fines at the same time, knowing the top ten most cited safety violations can be a great first step to a better, safer facility.
The top ten list of violations recorded by the Occupational Safety and Health Administration (OSHA) are fairly similar from 2015 to 2017. And the reason is that these are often ignored trouble spots. This column explores common factors in the citations, relevance to the pallet industry and ways you can reduce your liability. Due to space limitations, this column will only focus on the top ten violations that are common in the pallet industry.
OSHA’s 2017 Top-Ten Violation List
1. 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
When reviewing these violations to the standards, without a doubt, the most common non-compliances that I see are the employer has no written safety program required to meet the basic requirements of the standard, has failed to provide adequate safety training relevant or has not enforced the standard.
As an employer, you must have written safety programs specific to the OSHA standards that are relevant to your industry, and the job tasks in your workplace. In the pallet industry, I would recommend the following:
• Safety Program Policies and Procedures
• Crane and Hoist Program (Workplaces with fixed jib, gantry, or bridge cranes)
• Emergency Preparedness and Emergency Action Plan Program
• Equipment Safety Training Program
• Ergonomics Program
• Fall Protection Program (Includes ladders, railing, guarding, etc..)
• Forklift Operational and Safety Training Program
• Fleet Safety Program (Employers with a vehicle or truck fleet)
• Hazard Communication and The Globally Harmonized System Program
• Hearing Conservation Program (Noise exposures over 85 decibels)
• Hot Work Safety Training Program (Welding, cutting, and fabrication)
• Lockout-Tagout Program / Control of Hazardous Energy
• Personal Protective Equipment Program
• Personnel Lifts (Workplaces with telescoping or scissor lifts)
Fall Protection – General Requirements (OSHA Standard 1926.501) Total violations = 6,072
According to the Bureau of Labor and Statistics (BLS), slip, trip and fall injuries, depending on the occupation, account for 18-30% of all job-related injuries, and 12-15% of all workers’ compensation expenses. Slips, trips, and falls are second only to motor vehicle accidents, as the cause of 15% of all fatalities in the workplace.
As of this past January, many states have adopted new regulations in regard to “Trigger Heights” for the requirements of fall protection. As an example; what used to be the 10-foot rule, is now the 6-foot rule. If your facility performs structural maintenance and repairs, you should familiarize yourself and your staff of the new regulations.
Regarding fall protection, the OSHA Standards require employers to:
• Guard every floor hole into which a worker can accidentally walk (using a railing and toe-board or a floor hole cover).
• Provide a guard rail and toe-board around every elevated open sided platform, floor or runway.
• Regardless of height, if a worker can fall into or onto dangerous machines or equipment (such as a vat of acid or a conveyor belt), employers must provide guardrails and toe-boards to prevent workers from falling and getting injured.
• Other means of fall protection that may be required on certain jobs include safety harness and line, safety nets, stair railings and hand rails.
• Provide working conditions that are free of known dangers.
• Keep floors in work areas in a clean and, so far as possible, a dry condition.
• Select and provide required personal protective equipment at no cost to workers.
• Train workers about job hazards in a language that they can understand.
Respiratory Protection (OSHA Standard 1910.134) Total violations = 3,097
Most of the new clients that I inspect are not in compliance with the Respiratory Protection Standard. In fact, most don’t even come close. The standard requires employers to provide controls to protect the employees from breathing hazardous chemicals, irritants, dusts, and vapors, and to provide breathing air to environments with oxygen concentrations lower, than 19.5%.
An employer cannot simply purchase a particulate respirator, or an air supplied respirator, and have the worker wear it. Believe it or not, even the use of a dust mask requires training. I have found very little lenience by OSHA enforcement to violations of the Respiratory Protection Standard. This is mostly due to that fact that the fastest route of entry into the human body by a dangerous or poisonous chemical is through the lungs.
Along with the written program, the Respiratory Protection Standard requires the following:
• Hazard identification
• Exposure monitoring and testing
• Administrative controls
• Engineering controls
• NIOSH approved respirators
• Training (Initial and annual)
• Mandatory medical evaluations
• Fit testing
• Documented inspections, cleaning, maintenance and storage of respirator components
Lockout/Tagout (OSHA Standard 1910.147) Total violations = 2,877
Failure to control hazardous energy accounts for nearly 10% of the serious accidents in many industries. Proper lockout/tagout (LOTO) practices and procedures safeguard workers from hazardous energy releases. It’s all too common to find the side access panel of a machine left off, or the cover removed from an electrical junction box, or a breaker removed from a distribution panel by the operator, or a maintenance person, and not reinstalled. This creates a serious electrocution hazard, and results in a violation with a serious price tag.
Any time that an employee performs any task that involves removing guarding, or putting themselves or any body part into the point of operation, he or she must follow the Control of Hazardous Energy Standard. Besides the danger of electrocution, employees may be hurt if a body part gets near a pinch point, catch point, gears, sprocket, chain, belt, shaft, blade or other dangerous machinery.
As an employer, or supervisor, you can’t take this standard lightly. Doing so, will cost you stiff fines and possibly even more in worker accident or liability expenses.
Powered Industrial Trucks (OSHA Standard 1910.178) Total violations = 2,162
With approximately 1 million powered industrial trucks/forklifts in the United States, the BLS reports nearly 100,000 injury accidents annually involving forklifts. Estimates are that nearly 70% of all forklift accidents could have been prevented by proper operator training.
Employers must ensure that each operator is competent to operate a forklift safely, as demonstrated by the successful completion of the training and evaluation. Training needs to include class instruction, written testing and documented practical evaluation. Training should cover each forklift type that the employee will be operating.
Employers must enforce forklift safety rules in the workplace. Safe practices include: following plant speed limits; using warning devices before entering blind corners, backing, or going through doorways; never allowing riders; and never raising or lowering the load while the forklift is in motion
Every forklift in use, must have a documented and detailed inspection for defects or damage prior to each shift, and any forklift that is found to be unsafe, must be taken out of service immediately.
Machine Guarding (OSHA Standard 1910.212) Total violations = 1,933
Like most of these standards, machine guarding is an article by itself. See September 2015 Pallet Enterprise article; Machine Guarding Protects Employees.
If the machinery has open gears, shafts, chains, sprockets, pulleys, or belts, these points must be guarded. Guarding is also required, if a worker can be pinched, caught, fall into, or become entangled in the machinery. All hazardous exposure points must be guarded. Machine guarding must closely coincide with your workplace’s Control of Hazardous Energy Program.
Accidents due to unguarded points of operation are not uncommon in the wood products industry. There are many points of operation that cannot be guarded to the point to sufficiently prevent someone from becoming entangled if a body part is placed in the wrong location. That is where safety training, barricades, fencing and warning signs can make all the difference.
Fall Protection – Training Requirements Total violations = 1,523
With falls resulting in 18-30% of all job-related injuries, and 12-15% percent of all workers’ compensation expenses, fall protection and prevention training is a high priority. Many employers think that being in general industry, and not in construction, that fall protection training is not important. This is where employers get caught off guard, and end up paying for violations due to lack of training.
As an employer, you can’t simply purchase a personal fall protection harness, and send the employee into harm’s way. Employers must provide safety training that is specific to the job tasks and hazardous exposures that the employees will be facing.
I recommend that you go online and review OSHA’s free training materials. OSHA, as well as your worker compensation insurance provider, has a vast amount of free publications for employers to use. The following link: https://www.osha.gov/SLTC/fallprotection/standards.html provides employers with a resource for fall protection in general industry.
Electrical – Wiring Methods (OSHA Standard 1910.305) Total violations = 1,405
Improper electrical distribution can be common in general industry facilities. Frequenlty this is due to in-house electrical work that is not performed to the National Electrical Code. Having someone in your workplace, perform electrical work that is not licensed to perform electrical work, is asking for a lawsuit, electrocution or an electrical fire. Improper electrical wiring methods can damage equipment and cause premature electrical motor failure. It may also result in an employee’s electrocution when a circuit is improperly wired or labeled.
Stationary equipment should be hard wired, and not electrically fed by soft wiring, and extension cord use limited to short term use, and never as a long-term electrical supply. Tool and extension cords need to be inspected periodically for damage, and when damage is found, that tool or cord needs to be taken out of service.
All electrical supply distribution needs to meet National Electrical Codes, and repairs completed by qualified personnel. Damaged electrical cords and extension cords must be repaired properly, and never by using vinyl “electrical tape” to fix a frayed wire or damaged cord. Never run cords through walls, under carpets or through combustibles. And cords should never be strung or suspended by staples, hooks or nails.
Editor’s Note: Jary Winstead is a safety consultant, author and trainer who serves a variety of industries including the forest products sector. He owns Work Safety Services LLC and can be reached at SAFEJARY@gmail.com.
