Top 10 OSHA Violationsand How to Avoid Them

Agenda

• OSHA Violations and Penalty Structure– How Much Can the Fines Be?

• Most Frequently Cited Standards in General Industry– What are the Most Common Violations?

• Avoiding Common Violations– What to Do to Avoid the Most Commonly

Cited Items

Violation Penalty Structure

• Civil and Criminal Penalties and Fines

• Criminal Penalties– Willful and Repeat

Offenders– Serious Injuries and

Fatalities Involved– Can Include a Monetary

Fine or Jail Term or Both

• Criminal Penalties– Willful Violation with a

Fatality – First Conviction• Fine: $250,000 per

Individual, $500,000 per Organization

• 6 Months in Prison

– Willful Violation with a Fatality – Second Conviction

• Fine: $250,000 per Individual, $500,000 per Organization

• One Year in Prison

Fines and Penalties

• Civil Fines– Dependent on Severity of

Violation– Increases for Repeats– Increases for Willful

Violation– Subject to the egregious

policy

• Egregious Policy (MULTIPLIER)

• Civil Penalties– Failure to Post (Up to

$7,000)

• Civil Penalties– DeMinimus (None)– Other than Serious (Up to

$7,000 each)– Serious (Minimum $100

each - Up to $7,000 each)– Willful (Minimum $5,000

each – Up to $70,000 each)

– Repeat (Minimum $5,000 each - Up to $70,000 each)

– Failure to Abate (Up to $7,000 per Day per Violation)

Most Frequently Cited Items

0 500 1000 1500 2000 2500 3000 3500 4000

Hazardous Materials

Means of Egress

Industrial Trucks

Walking / Working Surfaces

First Aid - Fire Protection

Personal Protection

Electrical Safety

Lockout Tagout

Hazard Communication

Machine Guarding

Most Cited Item #1

• Machine Guarding Issues– 29 CFR 1910.212, 215, & 219

1. General Machine Guarding Violations

2. Point of Operation

3. Grinders – Tongue Guards

4. Exposed Pulleys

5. Grinders – Work Rests

Machine Guarding

• Key Issues– Prevent Potential Contact

with All Moving Machinery and Energy Sources

• Point of Operation

• Motions– Rotating– Reciprocating– Transversing

• Action– Punching– Cutting– Shearing– Bending

• Action Plan Inventory All Machinery at

the Facility Examine Each Machine for

Hazardous Motions, Actions, and Energies

Implement a Safeguard for Every Identified Hazard

Train Employees Not to Defeat Safeguards

Train Employees in Proper Operation and Service of Machinery

Most Cited Item #2

• Hazard Communication– 29 CFR 1910.1200

1. Hazard Communication Written Program

2. Information and Training

3. Training for New Hazards

4. Missing Material Safety Data Sheets

5. Missing / Incorrect Labels

Hazard Communication

• Key Issues– Written Hazard

Communication Program

– Sharing Chemical Safety Information with Employees

• Accurate Inventories• MSDS Available• Training• Labeling

• Action PlanDevelop a Site

Specific ProgramInventory All

ChemicalsCollect MSDS for All

Identified ChemicalsTrain Employees on

Chemicals and Hazards

Ensure Correct Labeling and Storage

Most Cited Item #3

• Lockout Tagout– 29 CFR 1910.147

1. Lockout Tagout Written Program

2. Lockout Tagout Machine Specific Procedures

3. Training

4. Periodic Inspections

5. Content / Quality of Energy Control Procedures

Lockout Tagout

• Key Issues– Written Energy Control

Program– Written Procedure for

Each Machine, Process, or System

– Readily Identifiable Lockouts Occurring

– Training– Auditing and Follow-up

• Action PlanDevelop a Site

Specific ProgramDevelop a Specific

Procedure for Each Machine or Process

Train EmployeesProvide Appropriate

Locks, Tags, Etc.Frequent Program

Audits (Routine and Non-Routine Tasks)

Most Cited #4

• Electrical Safety– 29 CFR 1910.303, 304, & 305

1. Conductor Protection from Abrasion

2. Exposed Live Parts

3. Inadequate Grounding

4. Missing Electrical Box Covers

5. No Strain Relief on Flexible Cords and Cables

Electrical Safety

• Key Issues– Prevent Contact with

Live Electrical Parts• Guarding• Maintenance of

Connectors, Covers, Boxes, Etc.

• Training• Lockout Tagout

Program• Labeling

• Action PlanExamine Electrical

Equipment at the SiteIdentify All Potential

Exposures to Live Parts

Repair or Replace Damaged Equipment As Soon as Identified

Train Employees on Basic Safe Practices

Most Cited #5

• Personal Protection– 29 CFR 1910.132, 133, & 134

1. Eye and Face Protection

2. General PPE

3. Hazard Assessments

4. Written Respiratory Protection Program

5. Respirator Medical Evaluation

Personal Protection

• Key Issues– Evaluation and Certification

of Requirements– Supplying Appropriate PPE– Maintaining PPE in Good

Condition– Training on Use and

Limitations– Engineering Controls

• Action Plan Examine Each Job Task to

Identify Hazards Engineer Out Hazards if

Possible Develop PPE Assessments Certify PPE Assessments Supply PPE for Hazards as

Appropriate Respiratory Protection

Programs Train Employees

Most Cited #6

• First Aid and Fire Protection– 29 CFR 1910.151 & 157

1. Eye and Body Flushing Facilities

2. Fire Extinguisher Training

3. Presence and Accessibility of Fire Extinguishers

4. Fire Extinguisher Maintenance

5. First Aid Supplies and Training

First Aid and Fire Protection

• Key Issues– Provide Eye and Body

Water Flushing Facilities where Chemical Hazards Indicate Need

– Availability of Immediate, Quality First Aid

– Maintenance of Fire Protection and Life Safety Systems

– Training Employees on Emergency Procedures

• Action Plan Identify Potential Chemical

Hazards to Eyes and Provide Flushing Facilities

Devise a Program to Provide First Aid and Provider Protection When Needed

Set Up PM Schedules and Checklists for Fire Protection and Other Life Safety Equipment

Train Employees

Most Cited #7

• Walking and Working Surfaces– 29 CFR 1910.22, 23, &24

1. Open Sided Floors and Platforms

2. General Housekeeping

3. Wet Floors

4. Stair and Platform Railings

5. Floor Holes

Walking / Working Surfaces

• Key Issues– Protect Employees

from Falls Off Edges– Prevent Slips, Trips,

and Falls

• Action PlanExamine Walking and

Working Surfaces at the Site

Correct Any Potential Hazards Identified

Conduct Regular Housekeeping Inspections and Correct Deficiencies

Most Cited #8

• Industrial Trucks– 29 CFR 1910.176 & 178

1. Operator Competency and Training

2. Truck Operating Condition

3. Secured Storage

Industrial Trucks

• Key Issues– Operator Training and

Certification– Forklift Operating

Conditions and Safety Equipment

– Handling Large, Heavy, and Awkward Loads

• Action PlanIdentify Employees

Who Drive Industrial trucks

Train Employees – Include Hands-on Demonstration and Certification of Skills

Monitor Driving and Load Handling and Correct Behaviors as Needed

Most Cited #9

• Means of Egress– 29 CFR 1910.36, 37, & 38

1. Obstructed Exit Pathways

2. Exit Pathways not Clearly Marked

3. Exit Pathways not Marked

4. Emergency Action Plans

5. Failure to Mark “Not an Exit” on Dead Ends

Means of Egress

• Key Issues– Employees Must be

Able to Evacuate Quickly

– Posting of Exit Signs and Exit Routes

– Employee Training– Hardware Issues

• Door Locks• Door Swing• Door and Hall Width

• Action PlanDevelop a

Comprehensive Emergency Response Plan with Identified Exit Pathways

Train EmployeesPractice (Have a Drill

Periodically)Examine Exit

Pathways and Conditions Regularly

Most Cited #10

• Hazardous Materials– 29 CFR 1910.101, 106, & 107

1. Compressed Gas Handling, Storage, and Use

2. Flammable Liquids Dispensing

3. Spray Booth Ventilation

4. Spray Areas – Electrical Wiring

5. Spray Areas – Combustible Residue

Hazardous Materials

• Key Issues– Handling, Storage, and

Disposal• Compressed Gases• Flammable Liquids• Hazardous Chemicals• Flammable and

Combustible Painting

– Housekeeping to Reduce Fire and Health Hazards

• Action PlanIdentify Areas Where

Specialty Chemicals are Being Used

Examine Specific OSHA Requirements

Train EmployeesConduct Routine

Housekeeping Inspections

Other Standards to Evaluate

• Permit Required Confined Space Entry

• Hearing Conservation• Welding, Cutting, and

Brazing• Hand and Power Tools• Powered Platforms• HAZWOPER• Specific Chemical

Standards• Laboratory Safety

• Special Industry Standards– Pulp and Paper– Textiles– Bakery Equipment– Laundry Machines– Sawmills– Logging– Telecommunications– Electric Power Generation– Grain Handling

Questions?

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