On Safety: A closer look at OSHA's ‘Top 10’ violations – Part III
Part II of this blog series on OSHA’s Top 10 most cited violations focused on three key industries OSHA will be directing agency resources to under its new National Emphasis Program on COVID-19: meat processing, health care and warehouse/distribution operations.
Here, we’ll look at the Top 10 violations in fiscal year 2020 for three other industries: oil and gas extraction, paper manufacturing, and wood products. 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 in FY 2020 for the oil and gas extraction industry include, as one would expect, multiple process safety-related violations.
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | 1910.119(f)(1) | 7 | Process Safety Management – Written Operating Procedures |
| 2 | 1910.119(d)(3) | 6 | Process Safety Management – Providing Process Safety Information |
| 1910.119(h)(2) | 6 | Process Safety Management – Employer Responsibility to Contractors | |
| 4 | 1910.119(j)(2) | 5 | Process Safety Management – Written Procedures for Mechanical Integrity |
| 5 | 1910.119(e)(3) | 3 | Process Safety Management – Process Hazard Analysis |
| 1910.119(f)(3) | 3 | Process Safety Management – Review of Operating Procedures | |
| 1910.119(f)(4) | 3 | Process Safety Management – Development of Safe Work Practices | |
| 1910.134(h)(3) | 3 | Respiratory Protection – Inspection of Respirators | |
| 1910.219(d)(1) | 3 | Machine Guarding – Guarding on Pulleys | |
| 1910.334(a)(2) | 3 | Electrical – Visual Inspection of Electrical Equipment |
Although inspections were limited in FY 2020 and the overall count of violations was low, the table is indicative of an OSHA focus driven by process safety management in this industry. In the oil and gas extraction industry in FY 2020, a total of 258 OSHA violations were cited. Of those, 102 were cited as serious.
The Top 10 OSHA violations in FY 2020 for the paper manufacturing industry:
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | 1910.212(a)(1) | 72 | Machine Guarding – General Machine Guarding |
| 2 | 1910.147(c)(4) | 48 | Lockout/Tagout – Energy Control Procedures |
| 3 | 1910.147(c)(6) | 25 | Lockout/Tagout – Periodic Inspections |
| 4 | 1910.147(c)(7) | 16 | Lockout/Tagout – Employee Training and Communication |
| 1910.212(a)(3) | 16 | Machine Guarding – Point of Operation Machine Guarding | |
| 6 | 1910.219(f)(3) | 14 | Power Transmission – Guarding of Chains and Sprockets |
| 7 | 1910.305(g)(1) | 13 | Electrical Safety – Electrical Extension Cords Used as Permanent Wiring |
| 8 | 1910.147(d) | 12 | Lockout/Tagout – Application of LOTO Controls |
| 9 | 1910.242(b) | 11 | Compressed Air Used Above 30 PSI |
| 1910.1200(h)(1) | 11 | Hazard Communication – Lack of Employee Training |
As for the standards cited, the clear standout was lockout/tagout, followed by machine guarding-related hazards. At No. 11 was 1910.147(c)(1) – for lack of a lockout/tagout written program. That was followed by 1910.132(d)(1) – for personal protective equipment hazard assessments. The total number of violations cited in FY 2020 for this industry was 738, of which 524 were serious.
The Top 10 OSHA violations in FY 2020 for the wood products industry:
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | 1910.147(c)(4) | 110 | Lockout/Tagout – Energy Control Procedures |
| 2 | 1910.212(a)(1) | 91 | Machine Guarding – General Machine Guarding |
| 3 | 1910.147(c)(7) | 71 | Lockout/Tagout – Employee Training and Communication |
| 4 | 1910.147(c)(6) | 65 | Lockout/Tagout – Periodic Inspections |
| 5 | 1910.1200(e)(1) | 58 | Hazard Communication – Written Hazard Communication Program |
| 6 | 1910.22(a)(1) | 57 | General Requirements – Housekeeping |
| 7 | 1910.147(c)(1) | 48 | Lockout/Tagout – Written LOTO program |
| 8 | 1910.219(f)(3) | 47 | Power Transmission – Guarding on Sprockets and Chains |
| 9 | 1910.95(c)(1) | 44 | Noise – Hearing Conservation Program |
| 10 | 1910.178(l)(1) | 11 | Powered Industrial Trucks – Safe Operator Training |
Not surprisingly, 40% of the Top 10 violations cited were related to lockout/tagout. Among the top 20 violations in this industry, we found OSHA’s General Duty Clause, which was cited 36 times. However, no apparent trend was noted. Of interest were the violations related to a lack of a hearing conservation program for noise exposure (No. 9) – one of the few health-related hazards in the Top 10. For the wood products industry in FY 2020, a total of 2,494 violations were cited by OSHA, with 1,865 of them serious.
Part IV 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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