OSHA’s Top 10
The most frequently cited standards for fiscal year 2024
A conversation with OSHA's Scott Ketcham
OSHA and Safety+Health announced preliminary data for OSHA’s Top 10 most cited standards for fiscal year 2024 on Sept. 17 during the 2024 NSC Safety Congress & Expo in Orlando, FL.
Later, Scott Ketcham, director of OSHA’s Directorate of Enforcement Programs, answered questions from S+H Associate Editor Kevin Druley regarding the list, Ketcham’s background and actions safety professionals can take to help prevent hazards on the job. (This conversation has been lightly edited.)
Safety+Health: Fall Protection – General Requirements is No. 1 for the 14th consecutive fiscal year. Fall Protection – Training Requirements has appeared in the Top 10 for eight years in a row. Why do falls continue to be a problem?
Ketcham: Falls are troublesome because they comprise such a large portion of the fatalities that OSHA investigates. Many workers who experience a fall that doesn’t result in a fatality can suffer a serious, life-altering injury, while others can recover from their injury. We know what control measures are necessary to reduce the risk of injury from a fall when working at height. The bottom line is that all workers deserve a safe job, with controls in place to prevent the hazards at their workplace.
S+H: Why, for more than a decade, have disabling and fatal injuries from falls continued in the construction industry?
Ketcham: Falls continue to be a problem because workers are required to perform work where they’re exposed to this hazard without the necessary fall protection systems available and in place or used. Most of the time this work happens without incident. However, the more times or the longer a worker works at height without proper fall protection systems in place, the greater the likelihood they will experience a fall.
OSHA emphasizes three critical elements to enhance workplace safety, and these elements definitely apply to fall protection: plan, provide and train.
Plan: Anticipate potential hazards and develop proactive strategies.
Provide: Ensure access to the necessary safety equipment and resources.
Train: Educate all employees on safety protocols and the importance of compliance.
Many organizations provide valuable resources to address these issues and help provide fall protection systems.
S+H: What steps is OSHA taking to help employers abate fall hazards?
Ketcham: From an outreach perspective, OSHA has been actively working to prevent fall hazards. For example, OSHA partners with NIOSH, the National Occupational Research Agenda, and CPWR – The Center for Construction Research and Training to raise awareness about common fall hazards. In 2014, OSHA launched the annual National Safety Stand-Down to Prevent Falls in Construction. This event, which takes place every May, brings together many partners at the local level to engage their members, workers and their families.
The stand-down is a voluntary event where employers are encouraged to directly address employees about safety concerns, particularly those related to fall hazards and prevention. Although primarily focused on the construction industry, the stand-down is not limited to this sector. We want all employers in every industry to join the safety stand-down. We also want unions, other government agencies, employer associations, worker centers and safety equipment manufacturers to participate. The key is to reach as many people as possible.
More information can be found on the OSHA Stop Falls Stand-Down webpage.
From an enforcement perspective, OSHA’s National Emphasis Program, which now includes general industry and maritime, in addition to construction, is aimed at reducing fall incidents by prioritizing inspections in all workplaces where work at height is observed.
S+H: Which other trends or data from the Top 10 stand out to you?
Ketcham: Upon review of the Top 10 issues OSHA cites, it always occurs to me that there’s great interest in the subject. I’ve been working for OSHA for almost 30 years and these cited standards continually repeat over and over – changing in position over the years. I think it’s important to put into perspective that these hazards are real, they do lead to fatalities and injure workers, and they are preventable. They’re most commonly cited because, sadly, we’re still finding them in the workplace.
S+H: You’ve spoken about the importance of safety and health management systems and establishing safety as a core value. How can organizations integrate these into their operations and cultures?
Ketcham: Safety and health management systems provide a structure for employers and workers to identify and correct hazards, and improve the controls in place, to ensure they can start and finish their work safely. Rather than reacting to incidents or regulatory agency citations, management and workers collaborate to proactively identify and solve issues before they occur. Building a culture that integrates safe work practices into daily work requires employer commitment and involvement from workers. Employers should clearly communicate and demonstrate their commitment to safety. Worker involvement is a key component that enhances communication, uses the institutional experience and knowledge of the workers, and builds trust.
Employers, workers and the public can find information to help with implementing or improving their safety and health management systems by visiting these webpages:
S+H: The presentation also included data about the agency’s fatal injury investigations. What are some key takeaways?
Ketcham: First, I want to say that it’s important for all to understand that workplace fatalities are preventable. I’ve been in the safety business for over 34 years as an investigator, manager and senior leader. I’ve seen the effects of fatal incidents firsthand and have seen upfront the tragedies of losing a family member, co-worker or friend in the workplace.
I want to emphasize the importance of surveillance and prevention to seek out and reduce risk that would prevent these incidents. In each, a commonality OSHA has found is that, invariably, there were near misses and other indicators that worker safety was either not a priority or a safety and health management system was not fully implemented. During the presentation at the NSC Safety Congress & Expo, I shared anecdotes about categories of fatalities that OSHA has inspected over the past year. My advice on prevention is to fully implement a safety and health management system that identifies and corrects hazards on your worksite and develop a work culture that nurtures the importance of worker safety as a core value of the organization. This is a major step where we can make a difference in reducing needless injuries and loss of life.
S+H: Has OSHA continued adding compliance safety and health officers, as has been the case recently? What do new compliance officers and enforcement staff learn at the OSHA Training Institute to help them conduct inspections?
Ketcham: Upon hire, new CSHOs are enrolled and take a series of introductory courses that provide them with the fundamentals of conducting inspections. Topics include hazard identification, inspection techniques, and inspection policies and procedures. In addition to training at the OSHA Training Institute during the first three years, new CSHOs are paired with a mentor at the area office level and have frequent interaction with their supervisor. The new CSHOs are provided information to review and become familiar with such as, but not limited to, OSHA regulations, interpretations, OSHA policy directives, online resources and OSHA case files of interest. New hires accompany their mentor and other experienced CSHOs during field inspection activities and case file development, progressing from observing inspection work to eventually doing the inspection work while observed by senior CSHOs or their supervisor.
S+H: What kind of influence can National Emphasis Programs have on the Top 10? What updates can you provide about NEPs that are in the works?
Ketcham: OSHA National Emphasis Programs provide for inspection of worksites known to be performing high-risk work. These inspections are directly related to identification of every hazard on the Top 10 list. The NEP on falls and programmed construction inspections examine the use of fall protection, fall protection training, scaffolding, ladders and personal protective equipment on construction sites. Inspections related to OSHA’s NEP on amputations examine machine guarding and control of hazardous energy (lockout/tagout) on general industry sites. Multiple occupational health-related NEPs (those on silica, hexavalent chromium, lead) examine employer compliance with respiratory protection and hazard communication, in addition to other topics. Site-specific targeting inspections are conducted with a comprehensive scope, and frequently identify some or all the hazards mentioned. OSHA’s attention to worker conditions in the most hazardous industries has driven the identification and abatement of these conditions that could have otherwise resulted in injury or illness to workers.
OSHA regularly reviews its NEPs to gauge their impact and need. For example, the agency is reviewing its NEP on amputations and will make updates to ensure we’re targeting industries based on the most current injury data. The most recent NEP we implemented was in the warehousing and distribution industry, where generally elevated injury rates and ergonomic hazards were of particular concern. OSHA will continue to be data driven in its approach to targeting hazards and industries strategically to have the most impact on protecting workers.
S+H: What are some common misconceptions you hear about agency enforcement?
Ketcham: There’s a persistent myth that employers with 10 or fewer employees are broadly not covered by OSHA. This isn’t correct. Employers who have at least one employee are generally covered by the Occupational Safety and Health Act of 1970 and have an obligation to understand their responsibilities under that law. There are certain exceptions in OSHA policies for recordkeeping and planned enforcement activity that are dependent on the number of employees, However, employers should understand and take steps to meet their obligations under the OSH Act.
Some small employers may feel that compliance with OSHA regulations is so complex as to be impossible. In reality, though, OSHA finds an in-compliance rate during inspections to be anywhere from 20% to 30% annually. Although there are several OSHA regulations that may be applicable to the work an employer does, the effort required to comply is generally straightforward. Working with OSHA’s On-Site Consultation Program, which is provided free of charge, consultants can focus their efforts on small employers, which is a good first step to take in helping employers identify potential hazards to workers and find solutions to fix those hazards.
Employers often believe if they request assistance from OSHA’s On-Site Consultation Program, they’re more likely to receive an enforcement inspection. This isn’t accurate. OSHA consultations are confidential and separate from OSHA enforcement activities. Consultants are committed to working cooperatively with employers who wish to receive an inspection of their jobsite and assistance with coming into compliance with applicable OSHA regulations.
S+H: Which experiences or observations from early in your occupational safety career continue to influence you today?
Ketcham: I’ve always been a people person – in life and in work. The safety field gives me a tremendous feeling of accomplishment when we make the workplace safer. I remember the losses and try harder to do the right things to prevent further tragedies. When it comes down to it, I remember what a mother told me every year while I was in Lubbock, TX, when she reminded me that her son would have been a year older today if he hadn’t been killed on the job. It still makes me sad to think of that, but at the same time it makes me more determined to do my best every day to prevent needless tragedies – that’s what we’re in the business for, in my opinion, to make a positive difference for all.
S+H: What can employers do to avoid being a statistic in the FY 2025 Top 10 list?
Ketcham: Employers should commit themselves to ensuring safety is a core value within their organizational culture, with the ultimate goal of being able to anticipate, identify and correct hazards before they impact workers. It’s important that employers show leadership by infusing safety and health values into every policy, procedure and business decision in hopes of demonstrating to workers that their safe return home to their families is a primary and fundamental company value.
Developing an organizational culture of safety must also include involvement of workers in the establishment of a broader safety and health management system. We encourage employers and workers to consult our Safety as a Core Value webpage (osha.gov/safety-management/safety-core-value) for information on how to plan and approach development of a safety management system.
S+H: Where can employers turn for assistance?
Ketcham: OSHA is committed to providing employers with the tools and resources they need to meet their obligations under the OSH Act, and to embrace safety as a core value of their business.
OSHA’s compliance assistance specialists provide advice, education and assistance to businesses that request help with occupational safety and health issues. They also work with trade and professional associations to advance workplace safety and health.
In addition, OSHA’s On-Site Consultation Program offers free and confidential safety and occupational health advice to small and medium-sized businesses in all states across the United States, with priority given to high-hazard worksites. The consultation program is separate from the OSHA inspection effort, and employers can learn about potential hazards at their workplace, improve programs that are already in place and even qualify for a one-year exemption from routine OSHA inspections. These services are free of charge, no citations or penalties are issued, and the employer’s only obligation is to correct serious job safety and health hazards.
If your readers have questions or just want to learn more, I urge them to visit osha.gov, where the Help and Resources tab at the top of the website is a great starting point.
S+H: What might you like to add?
Ketcham: I know I’m speaking primarily to the safety community, but I would ask people to get to know their local OSHA area office staff and management in both State Plans and federal OSHA.
At OSHA, we’re all dedicated safety and health professionals with the same goal of protecting workers. When you need assistance, we’re there to provide compliance assistance in addition to performing our enforcement mission. Both are important to ensure workers are safe.
Post a comment to this article
Safety+Health welcomes comments that promote respectful dialogue. Please stay on topic. Comments that contain personal attacks, profanity or abusive language – or those aggressively promoting products or services – will be removed. We reserve the right to determine which comments violate our comment policy. (Anonymous comments are welcome; merely skip the “name” field in the comment box. An email address is required but will not be included with your comment.)