Avoiding OSHA Top 10 Violations

Each year the Occupational Safety and Health Administration announces its Top 10 workplace safety violations, which are said to be a reminder to employers to avoid complacency.

The rankings remain largely the same from year to year, and all the violations have something in common – they all are preventable if you are a conscientious employer.

Here is this year’s Top 10 list – including some specific examples that are offered by John Ho, an attorney with the law firm of Cozen O'Connor:

1. Fall Protection (from spaces with unprotected edges and open sides).
2. Hazard Communication (failing to have a hazard communication program or safety data sheets).
3. Scaffolding (improper access to surfaces and lack of guardrails).
4. Respiratory Protection (failing to establish a respiratory protection program and failing to provide medical evaluations).
5. Lockout/Tagout Protection on Equipment. (inadequate worker training and inspections).
6. Ladders (improper use of ladders, damaged ladders, and using the top step).
7. Powered Industrial Trucks (inadequate worker training).
8. Machine Guarding (exposure to points of operation).
9. Fall Protection – Training requirements (failing to train workers in identifying fall hazards and proper use of fall protection equipment).
10. Electrical – Wiring methods (industries commonly cited include food and beverage, retail and manufacturing).

“Because the Top 10 list is so consistent, it remains an excellent starting point for businesses that want to review safety practices and policies and may not be sure where to start,” Ho says. “It also can serve as a helpful tool for safety committees to periodically review along with the OSHA logs.”

National Safety Council President Deborah A.P. Hersman observes, "The OSHA Top 10 is more than just a list, it is a blueprint for keeping workers safe. When we all work together to address hazards, we can do the best job possible to ensure employees go home safely each day."

Tressi Cordaro, an attorney with the law firm of Jackson Lewis, says, "If employers have hazards at the worksite that are on this list, they should review their programs and policies to ensure they are up-to-date and in compliance.”

Fisher Phillips attorney Ed Foulke, who was head of OSHA under President George W. Bush, suggests:

• Hold weekly safety talks. Employers should review all the applicable OSHA standards and talk to employees for about 15 minutes on one topic each week. After a year, an employer should have touched on all the relevant topics at least once.
• Post a list of safety rules and enforce them. Employers should make sure workers are familiar with the rules and fully understand that violations of the rules won't be tolerated.
• Look at OSHA 300 logs, which record worksite injuries and illnesses, and conduct an incident analysis for each entry to figure out the root cause of the incidents and ways to eliminate future risks.
• Perform accident investigations and root cause analysis for near misses as well. The latter are incidents that could have easily resulted in a serious injury but did not.

OSHA also offers an online guide for employers about how to create and maintain a safety program.