On Safety: A closer look at OSHA’s ‘Top 10’ violations – Part VII
In the previous installment (Part VI) of this blog series on OSHA’s Top 10 most cited violations for fiscal year 2020, we looked at primary metal fabrication (NAICS 331), heavy civil engineering and construction (NAICS 237), and miscellaneous manufacturing – including medical equipment, jewelry, sporting and athletic goods, toy and doll manufacturing, sign manufacturing, manufacture of musical instruments, fastener manufacturing, and the manufacturing of brooms and caskets – (NAICS 239).
Here, we’ll look at the top violations issued by OSHA in FY 2020 in these industries:
- Plastics and rubber products manufacturing (NAICS 326)
- Personal and laundry services (NAICS 812)
- U.S. Postal Service (NAICS 491)
- Chemical manufacturing (NAICS 325)
As a reminder, OSHA in FY 2020 conducted only 21,680 inspections – one of the lowest totals on record and down from 33,401 in FY 2019. (Those totals are also down from 70,000-plus inspections per year in the 1980s.) Hence, the number of violations in FY 2020 is fewer than in FY 2019, but the most cited violations remain consistent.
For the plastics and rubber products manufacturing industry, 1,719 violations were issued, of which 1,173 were cited as serious. The top standards cited are:
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | 1910.212(a)(1) | 160 | Machine Guarding – General machine guarding |
| 2 | 1910.147(c)(4) | 123 | Lockout/Tagout – Lack of energy control procedures |
| 3 | 1910.147(c)(7) | 85 | Lockout/Tagout – Lack of training and education for employees |
| 4 | 1910.147(c)(6) | 76 | Lockout/Tagout – Lack of periodic inspections |
| 5 | 1910.212(a)(3) | 49 | Machine Guarding – Failure to provide point of operation machine guarding |
| 6 | 1910.147(d) | 44 | Lockout/Tagout – Lack of established procedures for the application of lockout/tagout, including preparation for shutdown, machine or equipment shutdown, machine or equipment isolation, application of the lockout/tagout device, addressing stored energy, and verification of lockout/tagout |
| 7 | 1910.1200(e)(1) | 39 | Hazard Communication – Lack of a written program |
| 1910.1200(h)(1) | 39 | Hazard Communication – Lack of or deficiencies in employee training | |
| 9 | Section 5(a)(1) of the OSH Act | 31 | General Duty Clause |
| 10 | 1910.28(b)(1) | 24 | Walking-Working surfaces – Unprotected sides of floors and walkways 4 feet or more above the lower surface |
| 1910.305(g)(1) | 24 | Electrical – Use of flexible cords and/or cables in place of permanent wiring |
The standouts include machine guarding, lockout/tagout and hazard communication violations. The industry also had a considerable number of violations under OSHA’s General Duty Clause. The agency uses the clause to cite hazards that are likely to cause death or serious injury/illness to employees. Although all of the cited hazards were serious, all are also associated with the control of fatality and serious injury/illness. Examples of the cited hazards include:
- Crushing (11 violations)
- Fire and/or combustible dust (nine)
- Struck-by (nine)
- Heat stress (three)
- Caught in or between (three)
- Ergonomics (one)
- Lack of an exposure control plan for COVID-19 (one)
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