OSHA’s Top 10 Safety Violations for FY 2015

Miles & Stockbridge P.C.

On September 29, 2015, OSHA issued its preliminary list of the agency’s top 10 cited standards for fiscal year 2015. The list was presented at the National Safety Council’s 2015 Congress & Expo in Atlanta, Georgia by Patrick Kapust, deputy director of OSHA’s Directorate of Enforcement Programs.

The following rankings reflect OSHA’s data through September 8, 2015, and will be updated after the fiscal year ends on September 30, 2015:

  1. Fall Protection, 29 C.F.R. § 1926.501 – 6,721 violations (2014 Rank: #1)

    Common Violations: failure to wear fall protection; unprotected sides and edges.

  2. Hazard Communication, 29 C.F.R. § 1910.1200 – 5,192 violations (2014 Rank: #2)

    Common Violations: failure to maintain a written program; inadequate employee training; failure to maintain or provide employees with access to safety data sheets; improper labeling of containers.
  3. Scaffolding – General Requirements, 29 C.F.R. § 1926.451 – 4,295 violations (2014 Rank: #3)

    Common Violations: improper scaffold construction; lack of guardrails; failure to comply with point of access requirements.
  4. Respiratory Protection, 29 C.F.R. § 1910.134 – 3,305 violations (2014 Rank: #4)

    Common Violations: failure to maintain a written program; failure to conduct required medical evaluations; failure to comply with fit test requirements.
  5. Lockout / Tagout, 29 C.F.R. § 1910.147 – 3,002 violations (2014 Rank: #6)

    Common Violations: failure to implement an energy control program; failure to develop, document, and use energy control procedures; inadequate employee training; failure to conduct periodic inspections of energy control procedures.  
  6. Powered Industrial Trucks, 29 C.F.R. § 1910.178 – 2,760 violations (2014 Rank: #5)

    Common Violations: failure to ensure that operators are properly certified; inadequate operator training; failure to provide refresher training and evaluation; failure to remove trucks from service when repairs are necessary.
  7. Ladders, 29 C.F.R. § 1926.1053 – 2,489 violations (2014 Rank: #7)

    Common Violations: using damaged or defective ladders; excessive loads; using the top or top step of stepladders as a step.
  8. Electrical – Wiring Methods, 29 C.F.R. § 1910.305 – 2,404 violations (2014 Rank: #8)

    Common Violations: improper use of flexible cords and cables; uninsulated wiring; non-compliant temporary wiring; unused openings in electrical cabinets.
  9. Machine Guarding – General Requirements, 29 C.F.R. § 1910.212 – 2,295 violations (2014 Rank: #9)

    Common Violations: point of operation exposure; removal of guards; failure to anchor fixed machinery.
  10. Electrical – General Requirements, 29 C.F.R. § 1910.303 – 1,973 violations (2014 Rank: #10)

    Common Violations: improper installation or use of equipment; blocked electrical panels.

Generally speaking, there is very little variation in these rankings from year to year. Thus, employers should consider using this list as a starting point to identify and correct potential safety violations in their establishments.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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