1. OSHA Update “The Top 10” Doug Fletcher, CIH, CSP
Fletcher Safety Consulting, Inc.
Fletcher Safety Solutions, Inc.
Midwest Safety Cooperative

2. OSHA’s Top 10 – “Most Frequently Cited”
Fall Protection
Hazard Communication
Scaffolding
Respiratory Protection
Lockout/Tagout
Ladders
Powered Industrial Trucks
Machine Guarding
Fall Protection Training
Electrical – Wiring Methods

3. “Why do I care?”
Many of these are leading causes of death & serious injury…………
All of these things would typically be classified as “Serious”……….
$12,934
OSHA programming is designed to “find and fix” these items…….
Falls, OHPL, Scaffolds (OSHA’s drive-by program)
Falls = any elevated work, including roofs, ladders, training, lifts, etc.
Haz Com, LOTO, PITs on every General Industry inspection
LOTO and Machine Guarding are inseparable and are always inspected together
The Respiratory Protection citations listed “Do Not” require OSHA to establish that an over-exposure has occurred………..this is easy stuff for IH’s.
Electrical Wiring Methods – not an emphasis program. Just “low hanging fruit”…..

4. 1. Fall Protection – General Requirements
6,887 total violations (Federal Programs)
(b)(13) - Residential construction >= 6 feet above lower level shall be protected by guardrails, safety nets, or PFAS.
(b)(1) – Unprotected side or edge >= 6 feet above lower level shall be protected by guardrails, safety nets, or PFAS.
(b)(10) – Residential; low-sloped roofs……warning lines combined with guardrails, safety nets, PFAS, or monitor.
(b)(11) – Steep roofs – no warning lines. Requires guardrails, nets, or PFAS.
(b)(4)(i) – Holes & skylights; PFAS, covers, guardrails………..

5. 2. Hazard Communication
4,652 total violations (Federal Programs)
(e)(1) – Develop, implement, and maintain a “written” hazard communication program.
(h)(1) – “Effective” information and training at the time of initial assignment, and whenever a new chemical hazard is introduced into work area. May cover categories of hazards (flammables, corrosives, etc).
(g)(8) – Readily accessible, Safety Data Sheets (SDSs), during each shift.
(g)(1) – Employers shall have an SDS in the workplace for each hazardous chemical which they use.
(h)(3)(iv) – Training should include explanation of labels, SDSs, and how to obtain and use the appropriate hazard information.

6. 3. Scaffolding 1926.451 3,697 total violations (Federal Programs)
(g)(1) - > 10 feet above lower level shall be protected from falling.
(e)(1) – Scaffold access
(b)(1) – Each platform on all working levels shall be fully planked or decked between the uprights.
(g)(1)(vii) – PFAS or guardrails, unless otherwise specified.
(c)(2) – Supported scaffold poles, legs, frames, uprights shall bear on base plates and mud sills or other adequate, firm foundation.

7. 4. Respiratory Protection
3,381 total violations (Federal Programs)
(e)(1) – The Er shall provide a medical evaluation to determine employee’s ability to use a respirator before the employee is fit-tested or required to use..
(c)(1) - …the employer shall establish and implement a written RP Program…
(f)(2) – Er shall ensure that employee using a tight-fitting facepiece respirator is fit tested prior to initial use……………..
(c)(2)(i) – voluntary use respirators………..Appendix D information.
(d)(1)(iii) – The employer shall select a NIOSH-certified respirator.

8. 5. Lockout Tagout 1910.147 3,131 total violations (Federal Programs)
(c)(4)(i) – Procedures shall be developed, documented and utilized for the control of potentially hazardous energy.
(c)(6)(i) – The Er shall conduct a periodic inspection of the energy control procedures at least annually……
(c)(1) – Er shall establish a program consisting of energy control procedures, training, and periodic inspections……
(c)(7)(i) – The Er shall provide training….Authorized Employees.
(d) – Affected employees shall be notified of the application and removal of lockout devices or tagout devices.

9. 6. Ladders 1926.1053 2,567 total violations (Federal Programs)
(b)(1) – When portable ladders are used for access the side rails shall extend at least 3 feet above the upper landing surface……….
(b)(4) – Ladders shall be used only for the purpose for which they were designed.
(b)(13) – The top or top step of a step ladder should not be used as a step.
(b)(16) – Portable ladders with structural defects shall be marked “Do Not Use” and shall be withdrawn from service.
(b)(6) – Ladders shall be used only on stable and level surfaces uless secured to prevent accidental displacement.

10. 7. Powered Industrial Trucks
2,349 total violations (Federal Programs)
(l)(1)(i) – Er shall ensure that each operator is competent to operate…
(l)(4)((iii) – Evaluation every three (3) years…
(p)(1) – If truck is in need of repair, defective, or in ANY WAY unsafe, the truck shall be taken out of service until restored to safe conditions.
(l)(6) – The employer shall certify that each operator has been trained and evaluated.
(q)(7) – Industrial trucks shall be examined before being placed in service…and shall not be placed in service if the exam is failed…………Such examination shall be made at least daily.

11. 8. Machine Guarding 1910.212 2,109 total violations (Federal Programs)
(a)(1) – One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area…….
(a)(3)(ii) – The point of operation of machines whose operation exposes an employee to injury, shall be guarded.
(b) – Machines designed for a fixed location shall be securely anchored to prevent walking or moving.
(a)(2) – Guards shall be affixed to the machine where possible and secured elsewhere if not possible,
(a)(5) – Fan blades, < 7 feet above the floor, shall be guarded. The guard shall have openings no larger than ½ inch.

12. 9. Fall Protection - Training
1,724 total violations (Federal Programs)
(a)(1) – The Er shall provide training to each Ee who might be exposed to fall hazards. “Recognize and minimize” hazards……
(b)(1) – The Er shall verify compliance with (a) by preparing a written certification record.
(a)(2) – The Er shall assure that each Ee has been trained by a competent person.
(c)(3) – Inadequacies in an affected Ee’s knowledge or use of fall protection systems or equipment indicate that the Ee has not retained the requisite understanding or skill…
(a)(2)(iii) – including, the use and operation of guardrail systems, PFAS, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection to be used.

13. 10. Electrical – Wiring Methods
1,530 total violations (Federal Programs)
(g)(iv)(A) – Flexible cords may not be substituted for the fixed wiring of a structure.
(g)(2)(iii) – Flexible cords may be used only in continuous lengths without splice or tap. Hard-service cord >= #14 or larger may be repaired if spliced so that the splice retains the insulation, outer sheath properties of cord…
(b)(1)(ii) – Unused openings in cabinets, boxes, and fittings shall be effectively closed.
(b)(2)(i) – All pull boxes, J-boxes and fittings shall have covers identified for the purpose (no cardboard….)
(b)(1)(i) – Conductors entering cutout boxes, cabinets, or fittings shall be protected from abrasion, and openings through which conductors enter shall be effectively closed.