OSHA Top 10: A Guide to Safety in Your Plant

By Evan Gurley

Adherence to safety protocol is an essential aspect of everything that happens in a precast plant. When the Occupational Safety and Health Administration releases its list of the top 10 most frequently cited safety and health violations each year, it serves as a reminder to stay vigilant. The 2016 report was compiled from nearly 32,000 inspections of workplaces by federal OSHA staff.

“Every year the OSHA Top 10 serves as a guide for employers to address the biggest safety risks facing their employees,” said National Safety Council President and CEO Deborah A.P. Hersman.

Despite the warning the list provides, year after year OSHA inspectors see thousands of the same on-the-job hazards that can result in a fatality or severe injury. More than 4,500 workers are killed on the job each year, and approximately 3 million more are injured. According to the Bureau of Labor Statistics, 4,836 fatal work injuries were recorded in the United States in 2015, which was an increase from the previous year.

Increasing citations and fines

Not only have the number of OSHA citations increased, so have the fines that go along with them. Under a provision in the congressional budget deal signed in November 2015, OSHA fines will increase for the first time in a quarter century. The legislation requires federal agencies to adjust their civil penalties for inflation, and, as a result, the Department of Labor has adjusted penalties for its agencies, including OSHA.

OSHA’s maximum penalties, which were last adjusted in 1990, will increase by 78% and the agency will continue to make adjustments each year based on the Consumer Price Index. States that operate their own occupational safety and health plans are required to adopt maximum penalty levels that are at least as effective as OSHA.

The new penalties took effect Aug. 2, 2016. Any citations issued by OSHA on or after that date will be subject to the new penalties if the related violations occurred after Nov. 2, 2015.

OSHA last updated guidance for determining penalties in the 2015 edition of the agency’s Field Operations Manual, a handbook detailing the inspection and citation process. Gravity of the violation, size of the company, good faith effort to comply and history of previous violations are the four factors that go into calculating exact fines. Before any other calculations are made, the gravity of each individual violation is determined:

• High gravity violations carried the maximum amount for serious, repeat and willful violations
• Moderate gravity violations carried penalties between 57% and 86% of the allowable maximum
• Low gravity violations carried penalties of 43% to 57% of the allowable maximum

Gravity-based penalties can also be reduced by several factors such as the number of employees, whether prior inspections found the workplace to be in compliance with OSHA requirements and if the employer had a safety and health management system in place.

2016 Top 10

Patrick Kapust, deputy director of OSHA’s Directorate of Enforcement Programs, unveiled the top 10 most frequently cited standards during the National Safety Council Congress & Expo in Anaheim, Calif., in October 2016. OSHA’s 2016 fiscal year most violated workplace standards are listed below and on the next page.

This list is identical to the 2015 list with the exception of Machine Guarding and Electrical-Wiring Methods, which switched positions. Kapust offered an approach to properly use the OSHA Top 10 data.

“Take the list and look at your own workplace,“ he said. “These are the things OSHA is finding. Would they find these at my workplace? It’s a good place to start.”

1. Fall Protection (1926.501) – 6,929 citations

This standard outlines where fall protection is required, which systems are appropriate for given situations, the proper construction and installation of safety systems, and the proper supervision of employees to prevent falls. It is designed to protect employees on walking/working surfaces (horizontal or vertical) with an unprotected side or edge above 6 feet in construction activities and 4 feet in general industry.

2. Hazard Communication (1910.1200) – 5,677 citations

This standard addresses chemical hazards – both those chemicals produced in the workplace and imported into the workplace. It also governs the communication of those hazards to workers. The top five cited sections are:

1. 1200(e)(1) Implementation of hazcom program
2. 1200(h)(1) Training
3. 1200(g)(8) Requirement to maintain SDS
4. 1200(g)(1) Requirement to develop SDS
5. 122(h)(3)(iv) Explanation of label received on shipping containers. SDSs including the order of information and how employees obtain and use appropriate hazard information  

3. Scaffolds (1926.451) – 3,906 citations

This standard covers general safety requirements for scaffolding, which should be designed by a qualified person and constructed and loaded in accordance with that design. Employers are bound to protect construction workers from falls and falling objects while working on or near scaffolding at heights of 10 feet or higher.

4. Respiratory Protection (1910.134) – 3,585 citations

This standard directs employers in establishing or maintaining a respiratory protection program. It lists requirements for program administration, work site-specific procedures, respirator selection, employee training, fit testing, medical evaluation, respirator use, and respirator cleaning, maintenance and repair. The top five cited sections are:

1. 134(e)(1) Medical evaluation for respiratory protection
2. 134(c)(1) Respiratory protection requirement
3. 134(f)(2) Respirator fit testing
4. 134(c)(2)(i) Employer must establish a respiratory program
5. 134(d)(1)(iii) The employer shall identify and evaluate the respiratory hazard(s) in the workplace

5. Lockout/Tagout (1910.147) – 3,414 citations

This standard outlines minimum performance requirements for the control of hazardous energy during servicing and maintenance of machines and equipment. The top five cited sections are:

1. 147(c)(4)(i) General procedures
2. 147(c)(1) Energy control program
3. 147(c)(6)(i) Employer shall conduct periodic inspection
4. 147(c)(7)(i) Training
5. 147(c)(7)(i)(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources

6. Powered Industrial Trucks (1910.178) – 2,860 citations

This standard covers the design, maintenance and operation of powered industrial trucks, including forklifts and motorized hand trucks. It also covers operator training requirements. The top five cited sections are:

1. 178(l)(1)(i) Safe operation
2. 178(l)(4)(iii) Evaluation for operator’s performance at least once every three years
3. 178(l)(6) Certification
4. 178(p)(1) Truck repair and maintenance
5. 178(l)(1)(ii) Training shall consist of a combination of formal instruction, practical training and evaluation of operator’s performance

7. Ladders (1926.1053 (C)) – 2,639 citations

This standard covers general requirements for all ladders. The top five cited sections are:

1. 1053(b)(1) Portable ladder access
2. 1053(b)(4) Shall be used only for the purpose for which they were designed
3. 1053(b)(13) The top or top step of a step ladder should not be used as a step
4. 1053(b)(16) With structural defects
5. 1053(b)(22) An employee shall not carry any object or load that could cause the employee to lose balance and fall

8. Machine Guarding (1910.212) – 2,451 citations

This standard covers guarding of machinery to protect operators and other employees from hazards, including those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. The top five cited sections are:

1. 212(a)(1) One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards
2. 212(a)(3)(ii) Point of operation
3. 212(b) Anchoring fixed machinery
4. 212(a)(2) General requirements
5. 212(a)(5) Exposure of blades. When the periphery of the blades of a fan is less than 7 feet above the floor or working level, the blades shall be guarded

9. Electrical Wiring (1910.305) – 1,940 citations

This standard covers the grounding of electrical equipment, wiring and insulation. It includes temporary wiring and splicing, such as flexible cords and cables. The top five cited sections are:

1. 305(g)(1)(iv)(A) Substitute for fixed wiring of a structure
2. 305(b)(1)(ii) Opening shall be effectively closed
3. 305(g)(2)(iii) Flexible cords and cables (strain relief)
4. 305(b)(2)(i) Covers and canopies
5. 305(b)(1)(i) Conductors entering cutout boxes, cabinets or fittings shall be protected from abrasion, and openings through which conductors enter shall be effectively closed

10. Electrical, General Requirements (1910.303) – 1,704 citations

This section covers general safety requirements for designing electrical systems. The top five cited sections are:

1. 303(b)(2) Installation and use
2. 303(g)(2)(i) Guarding of live parts
3. 303(g)(1)(ii) Working space requirements
4. 303(g)(1) Space about electrical equipment
5. 1910.303(f)(2) Each service, feeder and branch circuit, at its disconnecting means or overcurrent device, shall be legibly marked to indicate its purpose

It doesn’t take more than a momentary lapse in focus or judgement for a safety violation to occur. Employers must remain vigilant and train employees on safety best practices, as well as find ways to remind them during their everyday workflow. For more information on safety in the precast concrete industry, visit NPCA’s safety webpage at precast.org/safety.  

Evan Gurley is a technical services engineer with NPCA.