OSHA Compliance Employer Checklists for Top 10 Citations

Each year the Occupational Safety and Health Administration publishes the top 10 most frequently cited standards of the previous fiscal year both for the general and construction industry. By understanding what OSHA's Compliance Safety and Health Officers (CSHO) are finding when conducting inspections, you can learn how to prevent or avoid similar citations. This article provides useful brief checklists to help employers prevent violations of the top 10 citations for Fiscal Year 2019 (Oct. 1, 2018, to Sept. 30, 2019).

For a better understanding, attend the webinar 'Analyzing OSHA's Most Cited Workplace Safety Violations FY 2020.' The program will also discuss strategies for training front-line supervisors and managers on safety conditions, employee practices and regulatory compliance.

Citations

Rank	Title	Standard
1	Fall protection - General requirements	1926.501
2	Hazard communication	1910.1200
3	Scaffolding	1926.451
4	Respiratory protection	1910.134
5	Lockout/Tagout	1910.147
6	Ladders	1926.1053
7	Powered industrial trucks	1910.178
8	Fall protection - Training requirements	1926.503
9	Machine guarding	1910.212
10	Eye and face protection	1926.102

Citation #1
Fall protection, construction (29 CFR 1926.501)

Each worker constructing a leading edge 6 feet or more above a lower level must be protected by guardrail systems, safety net systems, or personal fall arrest systems. 29 CFR 1926.501(b)(2)(i).

	Yes	No
Are all our floor holes guarded using either a railing, toe board or floor hole cover?
Are all our elevated open sided platform, floor or runway guarded with a guard rail and toe-board?
Are we providing workers with guardrails and toe boards to prevent workers who work at a certain height to protect them from falling into or onto dangerous machines or equipment?
Do we provide our workers relevant protection the job requires such as safety harness and line, safety nets, stair railings and hand rails?
Are our working conditions free of known dangers?
Are our floors in work areas as clean as possible? Are they in dry condition?
Are we providing personal protective equipment at no cost to workers?
Have we provided training to workers about job hazards in a language they can understand?

Some causes of fall protection violations:
Wet surfaces, uneven surfaces, inadequate lighting, ladders that have been improperly set up, ladders with structural defects, crowded workspaces, dangerous weather conditions, etc.

Citation #2
Hazard communication standard, general industry (29 CFR 1910.1200)

This section requires chemical manufacturers or importers to classify the hazards of chemicals which they produce or import, and all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets, and information and training. In addition, this section requires distributors to transmit the required information to employers. (Employers who do not produce or import chemicals need only focus on those parts of this rule that deal with establishing a workplace program and communicating information to their workers.) 1910.1200(b)(1)

The standard requires all employers with hazardous chemicals in their workplaces to

• Maintain a master list of hazardous chemicals used within the facility
• Create a written hazard communication program
• Properly label dangerous chemicals
• Make Safety Data Sheets (SDS) readily accessible
• Provide comprehensive employee training



	Yes	No
Is a written copy of the updated Hazard Communication Program available to all employees?
Is our SDS available to all our employees and contractors for each chemical on-site?
Do we have a system in place to inform outside contractors about chemicals at our site?
Are we ensuring that all our employees receive the required hazard communication training?
Are all our primary chemical containers having the required hazard labelling?
Are we labelling all our secondary chemical containers?

Citation #3
Scaffolding, general requirements, construction (29 CFR 1926.451)

In the following table, OSHA's scaffolding standard number is specified alongside the key questions employers must check.

	Yes	No
Have we ensured that the required fall protection or fall arrest systems are in place? (1926.451(g)(1)
Do our guardrails have the required height? 1926.451(g)(4)(ii)
Are our crossbracing at the proper height?1926.451(g)(4)(xv))
Have we installed midrails aright? 1926.451(g)(4)
Are our footings strong enough? 1926.451(c)(2)
Are our scaffold platforms fully planked or decked? 1926.451(b)
Are our scaffolds fully supported? 1926.451(c)(1)
Are our scaffolds capable of bearing the necessary weight? 1926.451(a)(1) and (3)
Are we training each employee who work on our scaffold on the hazards and the procedures to control the hazards? 1926.454
Do we conduct inspections as often as needed? 1926.451(f)(3)
When erecting and dismantling supported scaffolds, are we ensuring that a competent person determines the feasibility of providing a safe means of access and fall protection for these operations? 1926.451(e)(9) & (g)(2)

Citation # 4
Control of hazardous energy (lockout/tagout), general industry (29 CFR 1910.147)

Energy sources such as electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other sources in machines and equipment can be hazardous to workers. Sometimes these machines or equipment may startup or release stored energy unexpectedly during a service or maintenance and cause a serious injury or death to workers.

	Yes	No
Have we identified each hazardous machine in our facility or facilities?
Do we have written lockout/tagout procedures in place for each machine?
Are our employees complying with the maintenance and service protocol?
Are we making sure that any equipment, machinery, or parts of machinery are protected from unexpectedly releasing stored energy automatically, or because of human error?
Are we eliminating all possible causes for injury (burns, laceration, contusions, punctures, electrocution, crushing, etc.) or death from the hazards while completing the maintenance tasks?
Are our employees having the correct locks and/or tags?
Are we training each worker to ensure that they know, understand, and are able to follow the applicable provisions of the hazardous energy control procedures?

Citation # 5
Respiratory protection, general industry (29 CFR 1910.134)

In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this section. 1910.134(a)(1)

	Yes	No
Do we have a written protection plan with worksite-specific procedures?
Are we providing employees with appropriate respirators certified by NIOSH and matched to the identified respiratory hazards in the workplace at no cost?
Are we doing a medical evaluation of each employee before being assigned to wear a respirator?
Are we providing training to employees on why and how to select, use, fit, maintain and store respirators?
Are we having periodic evaluation of the respiratory program to ensure it is adequately protecting employees?
Do we have a respiratory protection program in place with a program administrator who is qualified by appropriate training, or experience that is commensurate with the complexity of the program to conduct the required evaluations of program effectiveness?

Citation # 6
Ladders, construction (29 CFR 1926.1053)

OSHA's most Frequently cited serious stairway and ladder violations include:

1. Not providing a handrail or stair rail system on stairs of four or more steps [1926.1052(c)(1)].
2. Not securing a portable ladder or having it extended 3 feet (.9 m) above the upper landing before workers use it to reach an upper level [1926.1053(b)(1)].
3. Not providing a safe means to gain access to a vertical rise in elevation of 19 inches (48 cm) or more [1926.1051(a)].
4. Not providing a training program for workers on the proper construction, inspection, maintenance, care, use, and limitations of stairways and ladders [1926.1060(a)].
5. Not marking or tagging a defective ladder so that it would not be used before it has been repaired [1926.1053(b)(16)].

	Yes	No
Are we following all labels and markings on the ladders we use?
Is each of our ladders inspected before use?
Are our ladders built correctly?
Do our ladders have sufficient capacity to bear the necessary weight?
Are our ladders in dry state when in use?
Are our ladders fully secured before use?
Have we trained our workers on the safe use of ladders?

Citation # 7
Powered industrial trucks, general industry (29 CFR 1910.178)

This section contains safety requirements relating to fire protection, design, maintenance, and use of fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines. This section does not apply to compressed air or nonflammable compressed gas-operated industrial trucks, nor to farm vehicles, nor to vehicles intended primarily for earth moving or over-the-road hauling. 1910.178(a)(1)

	Yes	No
Have our P.I.T operators received formal instruction including a written and graded examination?
Have our P.I.T operators undergone (hands-on) training on the site and lift equipment specifics?
Are we conducting regular performance evaluation where the P.I.T operators demonstrate their skill and understanding of the safe driving techniques learned through the training process?

P.I.T operators must know the 6 common P.I.T hazards to be able to mitigate the risk for powered industrial truck accidents, which can result in injuries, damage, or even death. These hazards include:

1. Inadequately Secured Loads
2. Overloaded Powered Industrial Trucks
3. Poorly Selected Powered Industrial Trucks
4. Traveling or Parking on a Grade
5. Hazards that are caused by the conditions present in the work environment
6. Obvious Causes of accidents involving pedestrians

Citation # 8
Fall Protection - Training Requirements (29 CFR 1926.503)

	Yes	No
Are we providing training to workers on fall protection? 1926.503 (a)(1)
Are we providing training in a language our workers understand?
Are we keeping a written record that demonstrates proof that our workers have received proper training with a written certification record? 1926.503 (b)(1)
Are our fall protection trainers competent enough in the appropriate areas? 1926.503 (a)(2)
Are we retraining workers whose knowledge/skill of fall hazards or the correct usage of fall protection systems is inadequate? 1926.503 (c)(3)
Have we ensured that workers are instructed on proper and safe use of any protection necessary for the job, such as guardrails, controlled access zones or fall protection PPE? 1926.503 (a)(2)(iii)

Citation # 9
Machinery and Machine Guarding, general requirements (29 CFR 1910.212)

"Employee exposure to unguarded or inadequately guarded machines is prevalent in many workplaces. Consequently, workers who operate and maintain machinery suffer approximately 18,000 amputations, lacerations, crushing injuries, abrasions, and over 800 deaths per year. Amputation is one of the most severe and crippling types of injuries in the occupational workplace, and often results in permanent disability."

	Yes	No
Have we identified every piece of equipment that could expose employees to injury?
Are we having adequate guards in place for all the machines/equipment?
If evidence suggests that the safeguards are tampered or removed, are we addressing the issue promptly?
Are we sure that guards are in place for all the hazardous parts of machines and equipment?
Are we guarding our workers against electrical hazards from machines?
Are we providing the extra protection when necessary?
Are we guarding our workers against non-mechanical hazards?
Do we have a system in place for shutting down the machinery and locking/tagging out before safeguards are removed?
Have we provided safeguarding training to all operators?
Are we ensuring that equipment and employees are continually monitored?

Citation# 10
Eye and Face Protection (29 CFR 1926.102)

The employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation. 1926.102(a)(1)

	Yes	No
Does our facility have a completed and signed hazard assessment?
Are the workers using the PPE provided to them as required by the company policy or the hazard assessment?
Are all the PPE in our facility stored appropriately and are they in good condition?
Is appropriate footwear for their work area used by all workers?
Are we protecting employees working with hazardous chemicals with appropriate long sleeve uniform and or/protective apron?
Have we provided our workers with necessary gloves at no cost? Are all workers wearing them while working?
If needed, are we providing dust masks?

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