By Evan Gurley
Every year, the U.S. Occupational Safety and Health Administration (OSHA) releases its top 10 most frequently cited violations from the previous fiscal year as compiled by OSHA inspections. OSHA publishes this list to alert employers and employees about commonly cited standards so they can use the information to take preventive measures. Many, if not all, of these frequently cited standards are preventable injuries or illnesses that occur in the workplace.
Year after year, this top 10 list remains basically the same. There may be a reshuffling of violations from year to year, but essentially the layout remains unchanged.
Patrick Kapust, OSHA’s deputy director of the Directorate of Enforcement Programs, best described the reason for creating a top 10 list in an interview with the Safety and Health Council.
“The data found in the top 10 list is not meant to gauge how well OSHA is performing or how safe businesses in the country are,” Kapust said. “The list is at its best when used by employers as a tool to improve safety at their work sites. Employers who may be interested in what are the possible hazards in their workplaces could look at the top 10 list and see if they’re covering all hazards and assessing the kinds of changes they may have to make to their safety and health programs.”
OSHA’s report for fiscal year 2013 once again cites fall protection as the No. 1 offender. The top 10 most frequently cited OSHA standards and the number of violations are:
- Fall Protection (1926.501) – 8,241 violations
- Hazard Communication (1910.1200) – 6,156
- Scaffolding (1926.451) – 5,423
- Respiratory Protection (1910.134) – 3,879
- Electrical, Wiring Methods (1910.305) – 3,452
- Powered Industrial Trucks (1910.178) – 3,340
- Ladders (1926.1053) – 3,311
- Lockout/Tagout (1910.147) – 3,254
- Electrical, General Requirements (1910.303) – 2,745
- Machine Guarding (1910.212) – 2,701
The top 10 most frequently cited OSHA standards for fiscal year 2012 were:
- Fall Protection (1926.501) – 7,250 violations
- Hazard Communication (1910.1200) – 4,696
- Scaffolding (1926.451) – 3,814
- Respiratory Protection (1910.134) – 2,371
- Ladders (1926.1053) – 2,310
- Machine Guarding (1910.212) – 2,097
- Powered Industrial Trucks (1910.178) – 1,993
- Electrical, Wiring Methods (1910.305) – 1,744
- Lockout/Tagout (1910.147) – 1,572
- Electrical, General Requirements (1910.303) – 1,332
OSHA citations from 2012 to 2013 increased by a staggering 45%. While there are no surprises to which violations they are, the top 10 violations for 2013 totaled 42,502 which is 13,323 more than the 2012’s tally of 29,179.
Overview of the OSHA Fall Protection Standard
In the U.S. construction industry, falls are the leading cause of worker fatalities. Each year, on average, between 150 and 200 workers are killed and more than 100,000 are injured as a result of falls during construction-related activities.
OSHA recognizes that accidents involving falls are generally complex events involving a variety of factors. Consequently, the standard for fall protection deals with both the human and equipment-related issues protecting workers from fall hazards.
OSHA has revised its construction industry safety standardsi and developed procedures designed to prevent employees from falling off, onto or through working levels, and to protect employees from being struck by falling objects.
The OSHA fall protection standard outlines when fall protection is required, which systems are appropriate for given situations, the proper construction and installation of safety systems, proper supervision of employees to prevent falls, safe work procedures for workers who use fall protection systems, and training requirements for workers who use fall protection systems.
Duty to have fall protection
When addressing fall protection during construction-related activities, employers are required to:
- Determine if walking/working surfaces have the strength and structural integrity to support employees safely
- Provide working conditions that are free of known dangers
- Keep floors in work areas in clean and, so far as possible, dry conditions
- Select and provide required personal protective equipment at no cost to workers
- Train workers about job hazards in a language they can understand
When fall protection is needed
The use of 100% fall protection at the point of work, as well as going to and from the work area, is mandatory for all employees and all contractor personnel on projects when employees are at risk of falling or working a minimum of 6 ft or more off the floor or ground, except in plant areas covered by OSHA standard 1910.23, Where the minimum distance off the floor or ground is 4 ft. In addition to the 6-ft rule in construction-related activities, other areas or activities where fall protection may be required include, but are not limited to, formwork and reinforcing steel, leading edge work, unprotected sides and edges, precast concrete erection, ramps, walkways, hoist areas and holes in walking surfaces.
Types of fall protection used
All fall protection components and/or systems must conform to the osha standards prescribed in 1926.502. Under the current standards, employers have the choice of selecting fall protection that aligns with the work being performed. Methods to address fall protection include:
- Elimination or substitution. For example, eliminate a hazard by lowering the work surface to ground level, or substitute a process, sequence or procedure so that workers no longer approach a fall hazard.
- Passive fall protection. Isolate or separate the hazard or work practice from workers through the use of guardrails or by covering exposed floor openings.
- Fall restraint. Secure the worker to an anchor using a lanyard short enough to prevent the worker’s center of mass from reaching the fall hazard.
- Fall arrest. This includes systems designed to stop a worker’s fall after a fall has begun.
- Administrative controls. These work practices or procedures warn a worker to avoid approaching a fall hazard.
Passive systems are those that do not involve the actions of employees. Examples of passive systems include:
• Safety nets
Active systems are systems and components that require manipulation by employees to make them effective in providing protection. Examples of active systems include:
• Anchorage points
• Snap hooks
• Life lines
• Body harnesses
Osha also reiterates that fall protection mechanisms need to be feasible and should not create a greater hazard implementing one or more of the above listed fall protection systems. The employer has the burden of establishing what is appropriate for a particular workplace situation.
Osha states that employers are required to protect their employees from falling objects. Some methods that may have to be used include:
• Installation of toe boards (at least 3.5 in. wide)
• Building a barricade and restricting entrance
• Installation of screens
Employers must provide training programs that teach employees who might be exposed to fall hazards how to recognize such hazards and how to minimize them.
Employers must prepare a written certification that identifies the employee trained and the date of the training. The employer or trainer must sign the certification record, and retraining must be provided when necessary.
Careful planning and preparation lay the groundwork for an accident-free workplace. If you are an employer, you are responsible for anticipating fall hazards at your plant and for including fall protection measures in your day-to-day activities. If you are an employee, you are responsible for following the policies, procedures and training requirements established by your employer.
If falling hazards are present at your plant, plan ahead to eliminate the possibility of a falling accident. Consider these important steps:
• Identify all fall hazards that workers are likely to encounter
• Describe how workers will gain access
• Describe how workers will prevent tools and materials from dropping to lower levels
• Establish procedures for inspecting, maintaining, and storing fall protection equipment
• Identify the tasks that expose workers to fall hazards
• Make sure workers use fall protection systems appropriate for their tasks
• Identify areas in which workers may be exposed to falling objects and determine how to control the hazards
• Describe emergency-response procedures for rescuing workers who fall
• Post emergency responder’s phone numbers and ensure workers are familiar with them
• Describe all equipment that will be available for rescuing workers who fall
It’s not complicated
Fall protection is a broad concept that includes training, procedures, rules, systems and methods intended to protect workers from fall hazards. Fall protection doesn’t mean bulky or cumbersome equipment. It doesn’t interfere with work tasks, and it doesn’t get in the way of co-workers – if you understand the concept and apply it appropriately.
Evan Gurley is a technical engineer with NPCA
i 29 Code of Federal Regulations, Subpart M, Fall Protection, 1926.500, 1926.501, 1926.502 and 1926.503