On Safety: A closer look at OSHA’s ‘Top 10’ violations – Part I
As part of the annual National Safety Council Safety Congress & Expo, OSHA presents its Top 10 most cited violations for each fiscal year. The data is interesting but can be confusing, as the information presented often combines general industry with construction. The Top 10 violations in this case tends to be dominated by fall hazards from construction.
This blog post is the first in a series that looks at OSHA data and the top violations, broken down first by major industry (manufacturing, construction and maritime) and followed by data from industries listed in the North American Industry Classification System codes. Before looking at the OSHA Top 10, it might be of interest to see a breakdown of agency data by inspection type, comparing fiscal year 2019 with FY 2020.
Fiscal year 2019 OSHA inspections | Fiscal year 2020 OSHA inspections | ||
---|---|---|---|
Total health inspections | 5,511 | Total health inspections | 4,119 |
Total safety inspections | 27,890 | Total safety inspections | 17,561 |
Total | 33,401 | Total | 21,680 |
Unprogrammed inspections | |||
Complaints | 7,408 | Complaints | 2,178 |
Fatality/catastrophe | 929 | Fatality/catastrophe | 1,502 |
Referrals | 3,147 | Referrals | 2,178 |
Planned or targeted | |||
Health | 1,245 | Health | 689 |
Safety | 11,794 | Safety | 7,051 |
Total | 13,309 | Total | 7,740 |
Construction | |||
Health | 933 | Health | 493 |
Safety | 16,567 | Safety | 10,582 |
Total | 17,500 | Total | 11,075 |
Manufacturing | |||
Health | 2,098 | Health | 1,396 |
Safety | 4,948 | Safety | 2,972 |
Total | 7,046 | Total | 4,368 |
Note: The data includes broad categories of OSHA inspections and does not include smaller categories such as program related or federal agencies.
Of interest in this table is the decline in the number of inspections in FY 2020 from FY 2019. In FY 2019, OSHA conducted a total on 33,401 inspections – an increase over its totals from the previous few years. The number of inspections in FY 2020 dropped to 21,680 – a decrease of 35%. However, the percentage of inspections in each category remained approximately the same. For example, in FY 2019, 52% of all inspections were in construction and, in FY 2020, 51% of all inspections were in construction. The decline in FY 2020 is likely because of the COVID-19 pandemic.
Next, we turn to the OSHA Top 10 for manufacturing, construction and maritime for FY 2020. For manufacturing:
Rank | OSHA standard | No. of violations | Standard description |
---|---|---|---|
1 | 1910.1200(e)(1) | 353 | Written hazard communication program |
2 | 1910.134(e)(1) | 312 | Respirator medical evaluation |
3 | Section 5(a)(1) OSH Act | 283 | General Duty Clause |
4 | 1910.1200(h)(1) | 259 | Hazard Communication information and training |
5 | 1910.134(f)(2) | 257 | Respirator fit testing |
6 | 1904.39(a)(2) | 212 | Reporting a hospitalization within 24 hours |
7 | 1910.134(c)(1) | 210 | Written respiratory program |
8 | 1910.28(b)(1) | 150 | Protection from fall hazards – sides and edges |
9 | 1910.303(g)(1) | 150 | Working space around electrical equipment |
10 | 1910.37(a)(3) | 142 | Unobstructed exit routes |
Note: 1904.39(a)(1), which requires reporting a fatality within eight hours, was cited 124 times.
In FY 2020, OSHA issued a total of 9,744 violations in manufacturing.
For construction:
Rank | OSHA standard | No. of violations | Standard description |
---|---|---|---|
1 | 1926.501(b)(13) | 3,028 | Residential construction, fall protection, use of guard rails, netting or personal protective equipment |
2 | 1926.102(a)(1) | 1,227 | Eye and face protection |
3 | 1926.1053(b)(1) | 1,034 | Portable ladders |
4 | 1926.503(a)(1) | 949 | Fall protection training |
5 | 1926.501(b)(1) | 676 | Fall protection, unprotected sides and edges |
6 | 1926.100(a) | 673 | Head protection |
7 | 1926.451(g)(1) | 533 | Fall protection – scaffolding |
8 | 1926.453(b)(3) | 467 | Fall protection – aerial lifts |
9 | 1926.21(b)(2) | 388 | Employer training of employees on unsafe conditions |
10 | 1926.20(b)(1) | 369 | Employer maintaining an incident prevention program |
Employee protection in excavations (1926.652(a)(1)) was cited 350 times. Not having an incident prevention program (1926.20(b)(1)) was cited 339 times. When looking at both 1926.20(b)(1) and (b)(2), they were cited by OSHA for a combined 708 violations. In FY 2020, OSHA issued a total of 20,377 violations in construction.
The violation data for maritime – including shipyards, ship breaking, marine terminal and longshoring – was pretty weak for FY 2020. OSHA conducted 211 inspections with a total of 383 violations. Of the maritime standards cited, all showed a total violation count of fewer than 10 violations, except for 1910.303(g)(1), which had 14 total violations for inadequate space surrounding electrical equipment.
Part II of this series will include the top violations for FY 2020 in health care, warehousing and meat processing – all of which are focus areas of OSHA’s National Emphasis Program for employee exposure to COVID-19.
This article represents the views of the authors and should not be construed as a National Safety Council endorsement.
Richard Fairfax (CIH, retired 2017) joined OSHA in January 1978 and retired from the agency in 2013. At OSHA, he was a practicing field industrial hygienist, as well as the deputy director and director of enforcement programs. In 2008, Richard served as acting director of construction and, in 2010, was designated deputy assistant secretary – overseeing all field, enforcement and training operations. From 1993 through 2010, Richard wrote an industrial hygiene column entitled, “OSHA Compliance Issues” for the Journal of Occupational and Environmental Hygiene. He still serves on the Editorial Review Board. Richard now works part time for NSC-ORC HSE.
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