Top 10 OSHA Violations in the Manufacturing Industry

The manufacturing industry is expansive and encompasses everything from chemical manufacturing to food processing. As manufacturing involves many different workflows and companies, federal regulators frequently cite it as one of the most hazardous industries for employees.

Failing to be in compliance and violating safety standards can be very costly to the lives of your employees and the livelihood of your business. You not only need to protect the health and safety of your workforce, but also the reputation of your business.

That’s why we’ve outlined the top 10 OSHA violations in the manufacturing industry from 2018 and provided tips on how to avoid them.

1. Machine Guarding

Standard: 1910.212, 219 – General Requirements and Mechanical Power-transmission Apparatus

Number of Citations in 2018: 2,048

Heavy machinery is an essential part of any manufacturing facility, but pose as one of the top safety hazards in the manufacturing industry. Moving machine parts have the potential to cause serious workplace incidents. Unless proper machine guard techniques are used, workers could suffer crushed fingers or hands, amputations, burns, or blindness.

Machine guards protect employees from hazards created by a machine’s ingoing nip points, rotating parts, flying chips, and sparks. Using the steps below, you can implement safeguards against machine hazards.

• Initial Inspection – Each piece of equipment on the plant floor should be inspected for proper machine guarding and related safeguarding before it is first used. This will help you identify any pieces of equipment that have exposed parts or outdated guarding techniques.
• Employee Training – Before using any equipment, operators and employees working in the machine area should be trained in how to use its machine guards, where the guards are located, what protection they provide, and which hazards they protect against. Employees also need to know how and under what circumstances the machine guards can be removed. Finally, they must also be able to identify when guards are damaged, missing, or don’t provide adequate protection.
• Ongoing Inspections – Virtually every manufacturing facility is required by OSHA to have frequent and regular inspections. Machine guarding should be part of that inspection process. Several pieces of equipment that utilize an emergency stop function as part of the machine safety should be tested at the beginning of each shift.

2. Lockout/Tagout (LOTO)

Standard: 1910.147 - The Control of Hazardous Energy

Number of Citations in 2018: 1,356

Working near or operating heavy machinery also exposes workers to hazardous energy hazards.

Workers servicing or maintaining machines or equipment may be seriously injured or killed if its energy is not properly controlled. Injuries resulting from the failure to use LOTO procedures during maintenance activities can include electrocution, burns, crushing, cutting, lacerating, amputating, or fracturing of body parts.

To achieve compliance with LOTO standards, manufacturers must develop, implement, and enforce an energy control program.

Employees need to be trained to ensure that they know, understand, and follow the applicable provisions of the hazardous energy control procedures. This training must cover at least three areas:

1. aspects of the employer’s energy control program;
2. elements of the energy control procedure relevant to the employee’s duties or assignment;
3. and the various requirements of the OSHA standards related to lockout/tagout.

It’s also important to only use lockout/tagout devices that are authorized for the particular equipment or machinery. Finally, these devices should be inspected regularly to ensure that they are in good working condition.

3. Hazard Communication (HAZCOM)

Standard: 1910.200

Number of Citations in 2018: 1,312

Manufacturing employees that work in areas where chemicals are used, distributed, or produced are required to comply with OSHA’s HAZCOM standard.

This standard was developed to ensure that manufacturers communicate certain information regarding chemical hazards. Employers must develop and maintain a written HAZCOM program that lists any hazardous chemicals used in the workplace and includes safety data sheets (SDSs) pertaining to these chemicals.

Examples of hazardous chemicals that are commonly found in manufacturing environments include cleaning solutions, battery acid, and flammable substances such as ethanol.

Employers must make SDSs accessible to employees in their work area for each hazardous chemical.

HAZCOM training should teach employees how to move, load, and use these chemicals safely. It is important for you to track employee training in hazard communication in order to avoid an OSHA citation.

4. Respiratory Protection

Standard: 1910.134

Number of Citations: 1,246

It’s not surprising that respiratory protection violations were included in 2018’s top ten list. Respiratory protection is the most technically complex categories of personal protective equipment (PPE).

For example, there are many factors that affect the correct choice of respiratory equipment. Manufacturers must consider the form of the hazard (such as gas or dust), the toxicity and concentration of contaminants, exposure times, the tasks being undertaken by employees, and any risks such as the potential for lack of oxygen or flammable agents.

When it comes to respiratory protection, manufacturers should keep in mind that one size does not fit all and each workplace has its own needs.

Some of the most common factors that lead to non-compliance with OSHA’s respiratory protection standards include:

• Poor selection of respiratory equipment;
• Not undertaking a site assessment to identify all respiratory hazards and possible exposure levels;
• Improper storage and maintenance of equipment;
• Inadequate training and information on care and storage;
• And failing to provide workers with ongoing support to address compliance issues with fit, comfort, and use.

5. Electrical

Standard: 1910.303, 1910.305 – General Requirements and Wiring Methods

Number of Citations: 1,048

In manufacturing environments, everyone needs to be aware of the hazards that can arise when working around electrical or energized equipment. Workers need to know how to avoid an arc flash, electrocution, overload or shock from occurring.

The following tips can help manufacturers avoid electrical violations:

• Ensure that energized equipment or devices are properly guarded from accidental exposure.
• Follow proper LOTO procedures.
• Do not leave the doors on electrical panels open. This increases the chances of damage to the device and the possibility of injury.
• When energizing an electrical breaker or main, stand off to the side. This will help protect you from an arc flash or explosion in the off chance that the device fails.
• Never work in wet areas near electrical equipment.
• If employees must work near energized or electrical equipment, proper PPE should be worn. These safeguards will protect employees from injuries related to heat; intense light, sound, and explosion from an arc flash.
• Don’t fall behind with housekeeping and keeping work areas clean. If an area is dirty, it’s more difficult to see electrical hazards until it’s too late.
• Provide workers with electrical safety training on how to operate and work safely around energized devices.

6. Powered Industrial Trucks (PITs)

Standard: 1910.178

Number of Citations: 863

Over the past few years, violations involving the use of Powered Industrial Trucks (PITs) have been increasing. This is why following forklift regulations is a common warehouse safety tip. To address this trend, OSHA currently has implemented powered industrial trucks regional emphasis programs in 28 states. This means that if you’re selected for an OSHA inspection, it’s likely that your compliance officer will review your PIT program while they are onsite -- no matter the initial purpose of the inspection.

The following items are the most common violations noted by OSHA inspectors:

1. Attachments - You cannot add any non-factory attachments to your truck unless you obtain written approval from its manufacturer. When using attachments, all data plates, tags and decals must display their capacity, operation and maintenance data. In addition, anytime attachments are used, even if a truck is unloaded, the operator still needs to treat the forklift as partially loaded.
2. Legible Markings - It’s extremely important that a truck’s controls, nameplates and markings be visible and legible. If something has worn or fallen off, you need to find a way to re-label that item so it can easily be read and understood. Your warehouse’s aisleways and walkways must also be clearly marked so pedestrians know where trucks will be operating.
3. Training - Before an operator uses a truck, they must obtain their certification. PIT training must include a blend of instruction methods. Instructional training (or information delivered in a classroom, video, online course, etc.) must be paired with hands-on demonstrations, and an evaluation of how the employee operates the equipment. Refresher training must be conducted every 3 years.
4. Inspections - Inspections must be conducted daily. However, in circumstances in which a PIT is used around the clock, inspections must be conducted after each shift. If a PIT is found to contain defects, has issues with overheating or unsafe conditions, or is need of repair, it must be taken out of service until these issues can be corrected. Looking for more tips to meet forklift inspection requirements?
5. Seat belts - While it’s not explicitly stated in OSHA’s PIT standard, seat belts must be worn by truck operators. In a letter of interpretation, OSHA explains that they cite employers for lack of seat belt use under the General Duty Clause of OSH Act 5(a)(1). Any PITs manufactured after 1992 are required by American Society of Mechanical Engineers (ASME) standards to contain restraint devices such as a seatbelt. However, if your PIT doesn’t have a seatbelt, OSHA advises you contact its manufacturer to determine the best way to have one installed. Older models can easily be retrofitted.

7. Personal Protective Equipment (PPE)

Standard: 1926.100, 1926.102 – Head, Eye and Face Protection

Number of Citations: 432

Manufacturers face many challenges when it comes to PPE compliance. For example, workers in metal manufacturing can be put in situations where they need to remove their hardhats to don a welding helmet or to add a face shield as they shift between different work tasks. In an effort to simplify the inefficiency of switching between different types of PPE, manufacturing safety professionals are having to select and ensure PPE is consistently used in a way that not only protects workers, but also does not cause compliance issues and inefficiencies.

Manufacturers need to train employees to use PPE that is standardized, constant, and appropriate to the tasks performed. Workers need to know when and what types of PPE are necessary, its limitations, as well as how to properly care, use, store, and discard the equipment.

8. Occupational Noise Exposure

Standard: 1910.95

Number of Citations: 349

Twenty-two million workers are exposed to potentially damaging noise at work each year. Last year, U.S. business paid more than $1.5 million in penalties for not protecting workers from noise.

Fortunately, there are several ways to control and reduce worker exposure to noise.

Engineering controls involve modifying or replacing equipment. Engineering controls can also involve or making other physical changes at the noise source or in its surroundings to reduce workers' exposure. Examples of inexpensive, yet effective controls include some of the following: selecting low-noise emitting tools and machinery; maintaining and lubricating the oil bearings of machinery and equipment; providing a barrier between the noise source and employee (e.g., sound walls, curtains, and PPE such as ear plugs).

Administrative controls are changes in the workplace or procedures implemented to reduce or eliminate workers' exposure to noise. Examples of these controls include: operating noisy machines during shifts when fewer people are exposed; limiting the amount of time a person can spend at a noise source; providing quiet areas where workers are relieved from hazardous noise sources; and controlling noise exposure through distance. Administrative controls are often simple and inexpensive, yet effective ways of reducing noise hazards.

9. Walking and Working Surfaces

Standard: 1910.22

Number of Citations: 267

While falls consistently top OSHA's top 10 violations for the construction industry, fall hazards can certainly still occur in factories, warehouses and manufacturing plants. These areas offer numerous opportunities for trips, slips and falls, thanks to grease or oil spills, ignoring ladder safety, clutter, and uneven walking surfaces.

To keep walking and working surfaces clear from hazards, manufacturers can implement the following controls:

1. Proper housekeeping practices
2. Maintain clutter-free walkways and aisles
3. Provide proper lighting.
4. Use appropriate fall protection systems. Equip certain work areas with any needed guardrails, scaffolding, ladders or fall arrest systems and ensure any necessary PPE is available to employees.
5. Conduct training so that workers can identify fall hazards and keep themselves and others safe.

10. Process Safety Management

Standard: 1910.119 – Highly Hazardous Chemicals

Number of Citations: 265

Employees need to be able to identify any mixing, separating, stacking or storing hazards for materials, including:

• Which chemicals are reactive or able to cause a runaway reaction.
• Toxic, fire, or explosive hazards associated with your process chemicals.
• What to do during an incident or unusual process condition. Be aware of equipment operation and maintenance requirements, including:
  • Signs of corrosion, leakage, or other signs of equipment problems.
  • Who to alert when you see a problem. Know your process.
  • Follow operating, safety, and emergency procedures.
  • Keep up-to-date with changes to procedures, equipment, and chemicals.
  • Provide feedback – report all incidents and near misses.

A complete list of chemicals, toxins, and reactive materials that OSHA has classified as highly hazardous can be found in this appendix.