Top Ten OSHA Violations in 2022

If you’re a safety professional on social media, it would be hard to not notice that your newsfeed blows up this time of year with OSHA’s top ten most-cited violations list.  It’s like clockwork.  And yet, there is one thing that is probably LESS surprising than these articles showing up in your feed: the fact that fall protection once again tops the list.  First off, let’s look at the citations:

1. Fall Protection – General Requirements (1926.501): 5,260 violations
2. Hazard Communication (1910.1200): 2,424 violations
3. Respiratory Protection (1910.134): 2,185 violations
4. Ladders (1926.1053): 2,143 violations
5. Scaffolding (1926.451): 2,058 violations
6. Lockout/Tagout (1910.147): 1,977 violations
7. Powered Industrial Trucks (1910.178): 1,749 violations
8. Fall Protection – Training Requirements (1926.503): 1,556 violations
9. Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102): 1,401 violations
10. Machine Guarding (1910.212): 1,370 violations.

The data and statistics OSHA collects is where this information comes from. It’s important to note that the official listing for 2022 will be published in April of 2023. This information was pre-released during the National Safety Council’s Safety Congress. Now to get back to the stats.

For twelve years running, “Fall Protection – General Requirements” has been the top violated regulation.  In fact, every single one of the top ten this year was also on the list last year – though perhaps in different spots.  So, what does that mean?  This means that whether by choice, carelessness, or ignorance, we keep getting the same things wrong. This means new people enter the workforce who aren’t being properly trained.  It means tigers can’t change their stripes – in other words, bad actors continue to be bad actors. It means things like schedule and competition to bid the lowest price continue to push companies away from working safely.

It could also mean that these are the more complicated regulations; these are the ones that people try to get right, but still fall short on.  It could mean that these are the topics that compliance officers are focused on, either because they’re the most dangerous violations, because companies so often get them wrong, or because they’re the most visible and high profile.

Regardless of the reasons, the fact remains that companies are violating these top 10 regulations in great numbers.  And remember, these are just the ones that happened to be seen by a compliance officer, on jobs that happened to be inspected.  There are a whole host of other violations occurring daily that do not get cited because there is nobody around to cite them.

Breaking Down the List

It would be impossible to get into just what employers are getting wrong in each of these categories because they cover such a broad range of topics. However, here are some questions that you can ask to help you avoid these issues.

Fall Protection General Requirements

• Do your people have fall protection?
• Is it effective (in other words, have fall distances been calculated, does it fit properly, has it been inspected)?
• Is there a rescue plan?

There are so many possible items here, but the fact is, you need to plan your fall protection, or you will most likely get something wrong.

Hazard Communication

• Do you have all the necessary Safety Data Sheets (SDS) available?
• Are your hazardous materials properly labeled?
• Are your people trained?
• Do you have a Hazcom/GHS program?

Respiratory Protection

• Have your people been properly fit tested?
• Are they clean shaven?
• Are they wearing respiratory protection where necessary and in the proper manner?
• Is it the appropriate protection?
• Are they medically cleared?
• Have they been trained?

Ladders

• Are the ladders in good condition?
• Have they been inspected?
• Are they set up properly?
• Do have the proper ladder safety systems installed?
• Are they long enough?
• Have your people been trained?
• Are they climbing them and/or working from them properly?

Scaffolding

• Is your scaffolding erected properly?
• Are there mixed components that shouldn’t be?
• Are they fully planked/properly planked?
• Are they secured where necessary?
• Are the rails correct?
• Is access correct?
• Are they erected/dismantled under the guidance of a Competent Person?
• Are your users trained?
• Are they loaded properly?

Lockout/Tagout

• Do you have a program/procedure?
• Is it being followed?
• Does each individual have their own personal lock with their own personal key?
• Do you have a procedure for lock removal?
• Is your procedure periodically observed/reviewed/updated?
• Are your people trained?

Powered Industrial Trucks

• Are all your operators properly trained?
• Are they observed and evaluated at least every three years?
• Are they retrained when performance indicates a necessity?
• Are they properly operating the machines – proper speed, facing the right direction depending on load, raising/lowering the forks only when stopped, and taking proper precautions while charging or changing tanks?
• Are the information placards visible? Are machines being inspected?

Fall Protection – Training

This one speaks for itself. 

• Are your people properly trained in fall protection including when to use it, how to inspect it, what the rescue plan is, how to properly wear it and proper storage?

Personal Protective Equipment

• Do your workers wear the proper PPE when required?
• Are they wearing it correctly?
• Do they know how to care for the equipment so as not to compromise the protection it provides?

Machine Guarding

• Are your machines properly protected?
• Are guards bypassed?
• Are workers properly trained on how the guards work?
• Are guards properly maintained?

Conclusion

If we are seeing the same citations year after year, at the very least it gives companies a good foundation for determining what items they should be looking at. But they also need to understand what the rules and regulations require of them. 

The key to ensuring you don’t become a data point on this list is to employ a safety professional, or contract a third-party, that fully understands the regulations to spearhead your compliance efforts.  Periodically have that employee or third-party audit your facility, job sites, and processes.  But, more importantly than anything else, once you’ve been notified of an issue, address it. 

Too often, violations are found during safety audits that go unfixed. 

If that’s the case, a serious violation could end up being the best-case scenario because you’ve opened yourself up to the possibility of a willful violation and/or, more importantly, an employee injury or fatality.   Use this information to make sure that you’re not the one who is cited for, or worse yet, causing an injury because of, any of these common citations.

Contact one of our experts to get help becoming compliant with fall protection.