On Safety: A closer look at OSHA’s ‘Top 10’ violations – Part VIII
In the previous installment (Part VII) of this blog series on OSHA’s Top 10 most cited violations for fiscal year 2020, we looked at plastics and rubber manufacturing (NAICS 326), personal and laundry services (NAICS 812), the U.S. Postal Service (NAICS 491), and chemical manufacturing (NAICS 325).
Here, we’ll look at the top violations issued by OSHA in FY 2020 in these industries:
- Petroleum and coal products (NAICS 324)
- Food manufacturing (NAICS 311)
- Forestry and logging services (NAICS 113)
- Waste management and remediation services (NAICS 562)
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 petroleum and coal products manufacturing industry, 261 violations were issued, of which 193 were cited as serious. The Top 10 standards cited are:
| Rank | OSHA standard | No. of violations | Standard description |
|---|---|---|---|
| 1 | 1910.147(c)(4) | 15 | Lockout/Tagout – Lack of energy control procedures |
| 2 | 1910.119(j)(4) | 12 | Process Safety Management – Mechanical integrity, inspection and testing |
| 3 | 1910.119(d)(3) | 10 | PSM – Process safety information, information pertaining to the process and equipment |
| 4 | 1910.119(e)(3) | 7 | PSM – Process hazard analysis shall address the hazards of the process, engineering and administrative controls, consequences of controls failure, and facility siting |
| 5 | 1910.119(f)(1) | 6 | PSM – Failure to develop and implement operating procedures |
| 6 | 1910.1200(f)(6) | 5 | Hazard Communication – Workplace labeling |
| 1910.119(f)(4) | 5 | PSM – Operating procedures, failure to develop safe work practices | |
| 1910.119(h)(2) | 5 | PSM – Contractors, employer responsibilities | |
| 1910.132(d)(1) | 5 | Personal Protective Equipment – Failure to conduct a hazard assessment for PPE use | |
| General Duty Clause – Section 5(a)(1) of the OSH Act | 5 | General Duty Clause |
The top standouts for this group were dominated by Process Safety Management. In fact, of the total violations cited, 70 were tied to 1910.119, with 20 specific paragraphs of the standard cited. The General Duty Clause was in the Top 10 with five violations – no trends in the use of the clause were noted.
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