At the National Safety Council Congress & Expo, OSHA shared the 10 most cited violations of 2017 as it has done every year. For those who follow this list, there typically isn’t any dramatic movement among the various violations. Instead, violations move up and down the list by only one place, if at all. However, it’s still important to take a closer look at the top 2 violations to see how the complexity of safety regulations and compliance translates to sustainable supply chains.
Top 10 OSHA Cited Violations of 2017
- Fall Protection (29 CFR 1926.501)
- Hazard Communication (29 CFR 1910.1200)
- Scaffolding (29 CFR 1926.451)
- Respiratory Protection (1910.134)
- Control of Hazardous Energy - Lockout/Tagout (1910.147)
- Ladders (1926.1053)
- Powered Industrial Trucks (29 CFR 1910.178)
- Machine Guarding – General Requirement (29 CFR 1910.212)
- Fall Protection – Training Requirements (29 CFR 1926.503)
- Electrical – Wiring Methods (29 CFR 1910.305)
Fall Protection: This violation has topped the list for the past five years albeit lower by 900 citations year-over-year. No doubt that the number of ways that an organization can violate this standard has kept these citations high. For instance, there are specific fall protection standards for the construction industry as opposed to non-construction industries. Construction industry standards further break down into different categories, which include ladders and scaffolding, which also happen to be on this list.
In general, employers must provide railings and toe-boards around floor holes, elevated platforms, and raised floors. Additionally, guard rails and toe-boards must be in place to prevent workers from falling into dangerous machinery regardless of height. Finally, depending on the job site, special equipment, like harnesses, must be used to prevent injuries.
Hazard Communication: In 2012, OSHA replaced the Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This move was intended to provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. In addition to safety, there was also a business component for American companies that regularly handle, store, and use hazardous chemicals. Adopting GHS would ostensibly reduce trade barriers and improve productivity. Some argue that one side effect of changing the HazCom standard is confusion surrounding compliance. As a result, citations keep this violation in the second spot on the list. However, that number is down by roughly 1500 citations year-over-year, so perhaps the confusion is ebbing.
In general, chemical manufacturers and importers are required to evaluate the hazards of the chemicals they produce or import, and prepare labels and safety data sheets to convey the hazard information to their downstream customers. Additionally, all employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers, and train them to handle the chemicals appropriately. A deeper dive into the regulation shows more specific standards regarding handling, storage, first-aid measures, fire-fighting measures, and more. Having a complete understanding of these standards is a monumental task.
OSHA regulations can be complex and sometimes tedious but they're an important mechanism for improving safety and lowering risk. Organizations should seek to partner with contractors and suppliers that understand and respect OSHA requirements, in order to lower their own risk and avoid supply chain disruption. Avetta makes finding partners who meet compliance standards easy by vetting these companies before you engage them.
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