On Safety: A closer look at OSHA’s ‘Top 10’ violations – Part II
Part I of this blog series on OSHA’s Top 10 most cited violations focused on an inspection data comparison between fiscal years 2019 and 2020, coupled with the Top 10 OSHA violations in manufacturing, construction and maritime.
The Top 10 OSHA violations for this second blog post will focus on three key industries the agency will be addressing in its new National Emphasis Program on COVID-19: meat processing, health care and warehouse/distribution operations. As a reminder, OSHA in FY 2020 conducted 21,680 inspections – one of the lowest totals on record and down from 33,401 in FY 2019. Hence, the total number of violations in FY 2020 is much lower than in FY 2019, but the most cited violations remain consistent.
The Top 10 OSHA violations for FY 2020 in meat processing, including beef, pork and poultry:
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | 1910.147(c)(4) | 23 | Lockout/Tagout – Energy Control Procedure |
| 2 | 1910.212(a)(1) | 15 | General Machine Guarding |
| 3 | 1910.119(d)(3) | 12 | Process Safety Management – Process Equipment Information |
| 1910.147(c)(6) | 12 | Lockout/Tagout – Periodic Inspections | |
| 5 | 1910.212(a)(3) | 10 | General Machine Guarding – Point of Operation |
| 6 | 1910.147(c)(7) | 7 | Lockout/Tagout – Training and Communication |
| Section 5(a)(1) – OSH Act | 7 | General Duty Clause of the OSH Act | |
| 8 | 1910.305(g)(1) | 5 | Electrical – Use of Flexible Cords |
| 9 | 1904.4(a) | 4 | Recordkeeping – Failure to Keep OSHA Logs |
| 1910.132(d)(1) | 4 | Personal Protective Equipment – Hazard Assessment |
Although there weren’t a lot of inspections in FY 2020 and the overall count of violations is low, the table is indicative of what OSHA is finding and citing, especially lockout/tagout and machine guarding hazards. For FY 2020, OSHA cited a total of 258 violations, 176 of which were serious.
In FY 2020, the Top 10 OSHA violations for the health care industry (hospitals, nursing homes, assisted living and clinics) are:
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | 1910.134(e)(2) | 167 | Respiratory Protection – Medical Evaluations |
| 1910.134(f)(2) | 167 | Respiratory Protection – Fit Testing | |
| 3 | 1910.134(c)(1) | 104 | Respiratory Protection – Written Respiratory Protection Program |
| 4 | 1904.39(a)(1) | 68 | Recordkeeping – Fatality Reporting |
| 5 | 1904.4(a) | 58 | Recordkeeping – Failure to Keep OSHA Logs |
| 6 | 1910.134(k)(1) | 48 | Respiratory Protection – Training and Information |
| 7 | 1910.134(d)(1) | 26 | Respiratory Protection – Respirator Selection |
| 8 | 1910.134(a)(2) | 12 | Respiratory Protection – Failure to Provide Respirators |
| 9 | 1910.1030(c)(1) | 11 | Bloodborne Pathogens – Lack of a Written Bloodborne Pathogens Program |
| 10 | 1910.1200(e)(1) | 9 | Hazard Communication – Lack of a Written Hazard Communication Program |
The clear standout is respiratory protection standard violations. These violations, in many instances, likely are the result of exposure to COVID-19, with health care personnel having to wear N95 filtering facepiece respirators instead of surgical masks. The total number of violations for FY 2020 issued in this industry was 975, of which 694 were serious.
Of interest, in FY 2020, the General Duty Clause – Section 5(a)(1) of the OSH Act – was cited only twice.
The Top 10 OSHA violations for the warehousing and storage industry in FY 2020 were:
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | Section 5(a)(1) of the OSH Act | 19 | OSHA General Duty Clause |
| 2 | 1910.178(l)(1) | 18 | Forklifts – Operator Training and Safe Operation |
| 3 | 1910.37(a)(3) | 16 | Exits – Blocking/Obstructing an Exit Doorway |
| 4 | 1910.176(b) | 15 | Material Handling and Storage – Secure Storage |
| 5 | 1910.272(g)(1) | 14 | Grain Handling Storage – Entry into Grain Storage Areas |
| 6 | 1910.178(l)(6) | 11 | Forklifts – Operator Certification |
| 7 | 1910.28(b)(1) | 10 | Fall Protection – Unprotected Sides and Edges |
| 1910.1200(e)(1) | 10 | Hazard Communication – Lack of a Written Hazard Communication Program | |
| 9 | 1910.178(l)(4) | 9 | Forklifts – Refresher Training |
| 1910.176(a) | 9 | Material Handling and Storage – Use of Mechanical Equipment |
Not surprisingly, the dominant violations were related to the use of forklifts and material handling and storage. The 11th most cited item (eight times) was lockout/tagout – 1910.147(c)(7) – for employee training and information. It’s interesting that the No. 1 violation in this industry was the General Duty Clause. Of the 19 General Duty Clause violations cited, eight were for damaged or unsecured storage racks and five were for not wearing seat belts while operating a forklift. Two of the violations were for heat stress and one was for combustible dust. For FY 2020, OSHA issued a total of 462 violations – 321 of which were serious.
Part 3 of this series will include the top violations in FY 2020 for three other industries – yet to be named.
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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