OSHA Top Ten Violations, 2016: What Grabs Your Attention
The first thing you notice is that all ten standards were on list year's list too.
The standards are in basically the same order on the list, too.
The one difference in order is that Machine Guarding moved up one slot from ninth last year to eighth this year. But even though machine guarding jumped up one slot, there were actually fewer machine guarding violations cited in 2016 (2,448) than there were in 2015 (2,540).
Another thing that stands out is the large number of Fall Protection citations (6,096) and Hazard Communication citations (5,665). This is the same basic story that we saw in 2015.
Nine of the ten standards saw a decrease in the number of citations from 2015 to 2016:
Powered Industrial Trucks
In many cases, the number of citations were significantly lower.
I have no insight into why the number of citations went down. Are companies being safer and more compliant? Are OSHA inspectors simply issuing fewer citations, for whatever reason? Feel free to share your own opinion in the comments section.
Only one standard saw an increase in violations cited from 2015 to 2016: Lockout/Tagout. Remember to review that standard, folks.
It's also worth noting that this extended data set from OSHA also includes "Serious" and Willful" violations. We've got lists of the serious and willful violations for you later in this article. Until then, here are some definitions for you (from OSHA):
Serious violation-a violation "in which there is a substantial probability that death or serious physical harm could result, and the employer knew or should have known about the hazard."
Willful violation-a violation "committed with an intentional disregard of or plain indifference to the requirements of the Occupational Safety and Health Act."
And with that intro, let's get on with the lists.
OSHA's Top Ten Violations Cited List, Fiscal Year 2016
Here are the top ten violations cited, listed from the standard with the most citations to the standard with the tenth-most citations.
Total violations- 2,625, down a little more than 100 from the 2015 total of 2,732.
Ranking in previous year- #7 (same as this year)
Top five sections cited-
1. 1926.1053(b)(1) Requires ladder side rails to extend at least three feet above an upper landing surface, 1,458
2. 1926.1053(b)(4) Use of ladders restricted to only the purpose for which they were designed, 354
3. 1926.1053(b)(13) The top or top step of a ladder shall be not be used as a step, 235
4. 1926.1053(b)(16) Tagging and removing ladders from service portable ladders with structural defects, 127
5. 1926.1053(b)(5)(i) Non-self-supporting ladders shall be used at an angle such that the horizontal distance from the top support to the foot of the ladder is approximately one-quarter of the working length of the ladder, 65
5. 1926.1053(b)(22) An employee shall not carry an object or load that could cause the employee to lose balance and fall, 75
Total violations- 1,937, a BIG drop from the 2015 total of 2,624.
Ranking in previous year- #8 (one lower than this year--this was a big drop and bears some scrutiny)
Top five sections cited-
1910.305(g)(1)(iv) Flexible cords and cables not used as substitute for fixed wiring of a structure, 338 citations
1910.305(b)(1)(ii) Unused openings in cabinets, boxes, and fittings shall be effectively closed, 314 citations
1910.305(g)(2)(iii) Flexible cords and cables shall be connected to devices and fittings so that strain relief is provided that will prevent pull from being directly transmitted to joints or terminal screws, 302 citations
1910.305(b)(2)(i) All pull boxes, junction boxes, and fittings shall be provided with covers identified with the purpose, 250 citations
1910.305(b)(1)(i) Conductors entering cutout boxes, cabinets, or fittings shall be protected from abrasion, 76 citations
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"Serious" and "Willful" Violations in Fiscal Year 2016: The Bad and the Even Worse
Here are the lists of serious and willful violations for 2016.
The Bad: Top Ten "Serious Violations" in Fiscal Year 2016
Let's start with the definition again:
Serious violation: "in which there is a substantial probability that death or serious physical harm could result, and the employer knew or should have known about the hazard."
Let's look at that definition and break it down into two parts. First, these violations include "a substantial probability that death or serious physical harm could result." And second, "the employer knew or should have known about the hazard." So that's pretty bad.
Here's the list of serious violations:
Fall Protection, 1926.501, 5,635 citations (6,173 last year)
Hazard Communication, 1910.1200, 3,544 citations (3,180 last year)
Scaffolding, 1926.451, 3,535 citations (4,281 last year)
Lockout/Tagout, 1910.147, 3,414 citations (2,739 last year)
Respiratory Protection, 1910.134, 2,421 citations (2,250 last year)
Ladders, 1926.1053, 2,365 citations (2,512 last year)
Machine Guarding, 1910.212, 2,147 citations (2,242 last year)
Powered Industrial Trucks, 1910.178, 2,043 citations (2,182 last year)
Electrical-Wiring Methods, 1910.305, 1,424 citations (1,976 last year)
Electrical-General Requirements, 1910.303, 1,285 citations (1,557 last year)
What catches the attention here? How about that serious violations for all these standards went DOWN except for serious violations for Hazard Communication, which went UP pretty significantly (3,544 compared to 3,180). I'd guess this had to do with the transition to GHS alignment.
The Even Worse: Top Ten "Willful Violations" in Fiscal Year 2016
If serious violations are bad, these willful violations are worse.
Here's the definition:
Willful violation: "committed with an intentional disregard of or plain indifference to the requirements of the Occupational Safety and Health Act."
You shouldn't intentionally disregard an OSHA standard and indifference is unacceptable as well.
We're not going to analyze this list in detail--it's pretty short and you can look at it quickly on your own--but we will point out that Fall Protection is on top of this list, just as it is with the general list. We'll also put an asterisk (*) next to standards listed below that don't appear on the larger general list above.
Here's the list:
Fall Protection, 1926.501, 173 citations (161 last year)
Lockout/Tagout, 1910.147, 114 citations (37 last year)
Lead, 1910.1025, 52 citations (not on the list last year)
Excavations, 1926.652, 49 citations (not on the list last year, although 1926.651 was and had 12 citations)
Mechanical Power Presses, 44 citations (not on last year's list)
Scaffolding, 1926.541, 40 citations (38 last year)
Machine Guarding, 1910.212, 19 citations (35 last year)
Specific Excavation Requirements, 1926.651, 19 citations (12 last year)
General Duty Clause, 5(a)(1), 16 citations (not on the list last year)
Grain Handling, 1910.272, and Welding, Cutting, and Heating, 1915.53, both with 14 citations (neither were on the list last year
What catches the attention here? The very significant increase in lockout/tagout willful violations, along with the items that weren't on last year's list...Lead (related to the situation in Flint, Michigan presumably), Excavations (related to recent risk in fatalities, presumably), and Mechanical Power Presses.
That's all we got for you today. Leave any thoughts, comments, or questions you have about this in the comments section.
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Jeff Dalto, Senior Learning & Performance Improvement Manager
Jeff is a learning designer and performance improvement specialist with more than 20 years in learning and development, 15+ of which have been spent working in manufacturing, industrial, and architecture, engineering & construction training. Jeff has worked side-by-side with more than 50 companies as they implemented online training. Jeff is an advocate for using evidence-based training practices and is currently completing a Masters degree in Organizational Performance and Workplace Learning from Boise State University. He writes the Vector Solutions | Convergence Training blog and invites you to connect with him on LinkedIn.