Each year the Occupational Safety and Health Administration releases the Top 10 Most Cited Violations of safety and health standards. OSHA's 5 top offenders are repeats from the year before, and the year before that. It’s no surprise that OSHA’s becoming less tolerant and more strict with tougher enforcement and increased fines. In 2017, OSHA conducted nearly 76,000 workplace inspections – that’s more than double from the previous year.
Nearly 4,600 people die each year doing their jobs, and some 3 million are injured.
There’s a good reason for this. Nearly 4,600 people die each year doing their jobs, and some 3 million are injured. The No. 1 killer – falls. With OSHA fines on the rise, the cost could be hefty. But the price to pay for repeated violations is only one aspect – there’s the safety of your crew, schedule delays, reputation and higher insurance costs. OSHA violations not only put your workers’ safety at risk and cost you money, they hurt your business.
For National Safety Stand-Down week, JOBSITE is publishing stories on each of the top 5 most violated citations, how to identify and prevent them. In addition, The Procore Safety Qualified Program is offering free courses, each centered around the top 5 OSHA violations: 1) Fall Protection, 2) Hazard Communication, 3) Scaffolding, 4) Respiratory Protection and 5) Lockout/Tagout.
We’re kicking off the articles with the top two offenders: Fall Protection and Hazard Communication. Take a look:
The top 10 list is a good starting point when doing your own safety and health audit.
Topping the list, as it has for seven years is Duty to Have Fall Protection, with the most violations cited in construction. Inadequate fall protection led to 384 construction workers dying on the job in 2016.
Human beings have gravity figured out by the time they’ve mastered walking. Toddlers know, more or less, how far they can bend over before falling down, and by the time they're six they have a pretty good understanding (mostly from trial and error) that if they step into thin air, they'll fall, often with serious consequences.
By the time they're adults you'd expect them to recognize more and more complex forms of fall hazards, and then either avoid them, or do something to make them non hazardous. The statistics though, tell a different story.
What's a construction employer to do?
Actively identify each fall risk on each job, communicate the risks to employees and use administrative, engineering or personal protective methods to eliminate those risks. Here are some starting points.
Residential Tops the Most Cited List
The most cited standard related to fall protection in 2017 was 1926.501(b)(13) which requires each employee working in residential construction to have protection from falls provided by "guardrail systems, safety net systems, or personal fall arrest systems." Employers can use alternate forms of protection when standard forms are infeasible, or they create greater hazards, but the burden of proof is on them.
Walking and Working on Protected Surfaces
The second most-cited standard of the fall protection standards is "unprotected sides and edges," standard 1926.501(b)(1). Employees must have guardrail systems, safety net systems, or personal fall arrest systems when the unprotected sides or edges of walking or working surfaces are six feet or more above a lower level.
Roofing on Low-Sloped Roofs
The third most-cited fall protection standard was 1926.501(b)(10). Employees working on low-sloped roofs with unprotected sides or edges that are six feet or more above another level should be protected by guardrail systems, safety net systems, or personal fall protection systems. Violators also were cited for not using alternative protections with warning line systems like safety guardrail systems, safety net systems, personal fall arrest or safety monitoring systems. The only time you should consider using a safety monitoring system alone is when the roof is 50 feet or less wide.
Roofing on Steep Roofs
This standard, 1926.501(b)(11), requires protecting each employee by using guardrail systems on steep roofs with unprotected sides or edges that are six feet or more above lower levels.
The fifth most-cited fall protection standard is 1926.501(b)(4)(i) which requires personal fall arrest systems, covers, or guardrail systems around holes in walking and working surfaces, including skylight holes. It's often convenient to ignore placing railings around stairway openings since it makes it easier to move materials through the openings. But, even on a two story structure, it's deadly when someone falls through a stairway opening.
Here's an overlooked tip for avoiding deaths and injuries from falls; constantly look for new hazards. Construction sites are dynamic, and as soon as one hazard closes, another often opens up. Constant diligence and heavily communicating fall protection requirements can keep awareness at high levels.
Holding the number two spot in 2017 is Hazard Communication, most violated across all industries.
Surprisingly, the most cited infraction of the standard is the one requiring a hazard communication plan in the first place. So, if you don't have a written plan that's been implemented and maintained at each workplace, then getting one done could actually prevent all other citations on this standard.
The premise behind the hazard communication standard is that employees have a right to know the toxic substances and chemical hazards they could encounter while working. They also need to know the protective things they can do to prevent adverse effects of working with those substances. Here are the steps to comply with the standard.
1. Get a copy of the rule.
2. Understand the requirements.
3. Name the people responsible for implementing, activating and maintaining your plan.
4. Inventory the chemicals.
5. Confirm containers are labeled.
6. Get a material safety data sheet for each chemical.
7. Put your plan in writing (there are some sample templates here but be sure to evaluate them for relevance to your work and adapt them as needed).
8. Make MSDSs available to workers.
9. Train workers.
10. Schedule regular maintenance.
11. Set up procedures for evaluating how effective the plan is.
Multi Employer Job Site
Construction is in a unique position because there are usually multiple business entities working on one project. For the prime contractor that means making sure hazard communication happens across the entire jobsite, and that it includes all hazardous materials used on the project.
When Consumer Products are Unsafe
While construction workers might work with many consumer products like cleaners and degreasers, those substances generally don't require you to communicate the potential hazards they present. However, if the workers will use those substances longer, and more often than what a typical consumer would use them, then workers have higher exposure. That should prompt you to make sure you communicate their hazards and required protective measures.
Not All MSDSs Required
Sometimes manufacturers create material safety data sheets for substances that aren't hazardous. They do that to identify chemical properties, set safe use guidelines, point out incompatibilities and reference safe storage and handling practices. If the substance is nonhazardous it will say so at the top of the MSDS, and you don't need to communicate with employees about it or maintain the MSDS on file.
If your workplace is in one of the 28 states having a state OSHA plan, follow their guidelines when developing your hazard communication plan.
Be sure to sign up for Procore’s Qualified Safety Courses. The live-action, engaging sessions, offered free of charge, will get you up to speed and give you the tools you need to stay safe and injury free. Click here to register.