Every year OSHA releases the infamous Top 10 list and every year there is little change. Why is this list important and why should top management quit ignoring it?
During the National Safety Council 2023 Congress & Expo, OSHA released the results of the Top 10 standards most frequently cited for violations across all industries for which OSHA standards apply. OSHA issued over 29,000 citations in its Top 10 categories during 2023.
The results don't change that much over the years. While it may feel like a broken record playing over and over again, it's really an opportunity for employers to change their tune about workplace safety by proactively identifying hazards and training employees to work safely.
“Although incredible advancements are made in safety each year, we continue to see many of the same types of violations appear on OSHA’s Top 10 list,” said Lorraine Martin, NSC President and CEO. “As a safety community, we must come together to acknowledge these persistent trends and identify solutions to better protect workers.”
Here are the top OSHA standards most often cited for violations for fiscal year 2023, which ended September 30. This list always includes both Construction (1926) and General Industry (1910) standards.
1. Fall Protection 1926.501
Fall Protection has been the number one most cited violation for the past several years. The fall protection standard is designed to prevent falls, which, according to statistics, account for just about 40 percent of deaths in the construction industry. Not surprisingly, most fall accidents happen on residential work sites where there is little oversight given to fall protection requirements.
To prevent fall injuries and fatalities, it is critical that employers supply their workers with guardrail systems, safety net systems or personal fall arrest systems when working at heights is required. In addition to just providing proper fall protection, the employer is also responsible for ensuring that all employees are trained on how to properly use fall protection and know when to use it.
OSHA has set requirements for employers to provide fall protection for their workers that are working on unstable surfaces or work sites that have unprotected sides and edges. Employers can provide fall prevention training by a competent person or they may prefer that their workers complete construction training courses that cover fall hazards and prevention at regional OSHA Training Institute Education Centers.
The sections of the Fall Protection standard that are most often cited for violations include residential construction, unprotected sides or edges, roofing work and floor holes including skylights.
2. Hazard Communication 1910.1200
The Hazard Communication standard addresses chemical hazards produced or used in the workplace. OSHA’s standard for hazard communication is in line with the international standard but remains on the top 10 list year after year. The hazard communication rule has not been properly implemented by a large percentage of businesses and it’s clear that many workers are not being trained on the new standards that went into effect in 2013.
The sections of the Hazard Communication standard that are most often cited for violations by OSHA include implementation of the hazcom program, training on hazardous materials, and requirements to develop and maintain Safety Data Sheets.
3. Ladders 1926.1053
Working with ladders on the job can be hazardous, especially if the ladders are not functioning properly or not used correctly. Many injuries caused by ladders are serious enough to require time off the job. OSHA rules apply to all ladders used in construction, alteration, repair, painting, decorating and demolition of worksites covered by OSHA’s construction safety and health standards.
The sections of the Ladder Safety standard that are most often cited for violations by OSHA include failure to extend an extension ladder at least 3 feet above the upper landing surface, using ladders in an unsafe manner, and continuing to use ladders after they are broken or found to be defective.
4. Scaffolding 1926.451
The OSHA Scaffolding standard covers safety requirements for scaffolding, which should be designed by a qualified person and constructed exactly in accordance with that design. Employers are required to protect all workers that use scaffolding from falls and falling objects. In addition, all scaffolds should be inspected by a competent person before use by the workers. The workers affected the most by scaffolding hazards include those in charge of framing, roofing, siding, and masonry.
The sections of the Scaffolding standard that are most often cited for OSHA violations include fall protection including guardrail systems, use of cross-braces for access, and planking/decking.
5. Powered Industrial Trucks 1910.178
OSHA's powered industrial truck standard covers the design, maintenance, and operation of powered industrial trucks, including forklifts and motorized hand trucks. It also covers operator training requirements.
The sections of the powered industrial truck standard that are most often cited include safe operation, initial training as well as refresher training and evaluation, inspections, and the requirement to remove trucks from service when they are found to be unsafe.
6. Lockout/Tagout 1910.147
Lockout/Tagout (LOTO) affects workers that service, repair and maintain equipment or machines. Hazards exist if the equipment being handled can suddenly become energized or started during work.
For companies that require LOTO procedures, these are the sections of the LOTO standard that OSHA has cited most often for violations: general procedures, energy control program, periodic inspections, and training.
7. Respiratory Protection 1910.134
OSHA’s Respiratory Protection standard directs employers on establishing and maintaining a respiratory protection program in the workplace. All aspects of respiratory protection are covered in this standard including procedures, administration, selection, training, fit testing, evaluation, use, cleaning, maintenance and repair. Employers should be familiar with OSHA’s requirements for voluntary use of respirator dust masks too.
The sections of the Respiratory Protection standard that are most often cited for violations by OSHA include medical evaluations, respiratory protection requirements, fit testing, failure to establish a necessary respiratory protection program and identifying respiratory hazards in the workplace.
To round out the Top 10 list, standards with the most cited OSHA violations in 2023 were:
8. Fall Protection - Training Requirements 1926.503
8. Eye and Face Protection 1926.102
10. Machine Guarding 1910.212
To quote Lorraine Martin, President and CEO of the National Safety Council, one more time, "With the best ideas, the right tools, and everyone showing up to redefine what's possible, no safety challenge will be too big for us to overcome, from the workplace to anyplace."