OSHA’s Top 10 Most Frequently Cited Standards for FY 2022

OSHA’s Top 10 Most Frequently Cited Standards for FY 2022

Let’s take a look at each standard and OSHA’s guidelines and requirements.

Every year around fall, OSHA announces its top 10 most cited standards for the fiscal year. Fiscal Year 2022’s (FY22) standards were once again announced at the National Safety Council (NSC) Safety Congress & Expo, this year taking place in sunny San Diego. OSHA’s Directorate of Enforcement Program’s Deputy Director Patrick Kapust spoke to a packed room about each violation at a session called “OSHA’s Top Ten Violations,” moderated by NSC’s Associate Editor of Safety+Health magazine Kevin Druley.

The violations for FY22 shared at the session used preliminary data from October 1, 2021, to September 6, 2022. This data was not final at the time of the announcement in September.

If you’ve been following the coverage of OSHA’s top 10 most cited standards over the past few years, you’ll notice some change to the order of violations, but not much to the violations listed. Let’s take a look at what the top 10 violations for FY22 are.

  1. Fall Protection, general requirements - 5,260 violations
  2. Hazard Communication Standard, general requirements - 2,424 violations
  3. Respiratory Protection, general industry - 2,185 violations
  4. Ladders, construction - 2,143 violations
  5. Scaffolding, general requirements, construction - 2,058 violations
  6. Control of Hazardous Energy (Lockout/Tagout), general requirements - 1,977 violations
  7. Powered Industrial Trucks, general requirements - 1,749 violations
  8. Fall Protection - Training Requirements - 1,556 violations
  9. Eye and Face Protection - 1,401 violations
  10. Machinery and Machine Guard, general requirements - 1,370 violations

Machinery and Machine Guard

Ranking number 10 again for the second year is machinery and machine guarding violations. Since the announcement of the fiscal year 2021 (FY21) violations, the number under this standard has increased. In FY21, OSHA’s preliminary data showed that 1,113 violations were issued for this standard. Over 200 additional violations were issued in the following fiscal year, for a total of 1,370.

Machinery and machine guarding are meant to protect workers from machine hazards. There are many types of machine guarding that employers can use, but the four general types are “fixed, interlocked, adjustable and self-adjusting.”

Although the OSHA standard on machinery and machine guarding, 1910.212, specifies many types of machines that typically require guarding, like power presses, portable power tools, guillotine cutters and jointers, it does not provide a complete list. Workers may be exposed to multiple hazards through working with or around machines, some from “rotating parts” or “sparks.”

Eye and Face Protection

This fiscal year, eye and face protection violations dropped, ending ninth on the list instead of the previous fiscal year’s ranking as eighth. In FY22, 1,401 violations were issued for eye and face protection. Almost the same number of violations were issued for FY21, according to preliminary data.

The eye and face protection standard, 1926.102, requires employers to ensure that workers use protection when exposed to certain hazards, including “flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.”

These hazards expose workers to potential eye and face injuries, including blindness.

When workers are in an area with potential flying objects, employers need to provide side protection for the eyes, OSHA says. Employers with workers who wear prescription glasses need to take this into account as well, ensuring that the worker’s prescription is included in the eye protection or that their glasses can be worn under the eye protection. The standard also outlines requirements for eye and face protection in regard to comfort, fit and ability to be cleaned.

OSHA notes that protection needs to “comply” with one of three listed American National Standards Institute (ANSI) standards—Occupational and Educational Personal Eye and Face Protection Devices (ANSI/ISEA Z87.1-2010 or ANSI Z87.1-2003) and Practice for Occupational and Educational Eye and Face Protection (ANSI Z87.1-1989 (R-1998)).

Fall Protection – Training Requirements

In 2020, 645 workers lost their lives after a fall to a lower level, according to the Bureau of Labor Statistics. In FY22, 1,556 violations were issued for OSHA’s standard on fall protection, 1926.503, down only 110 from the previous fiscal year.

Training workers on fall protection is one of many ways to reduce the number of workplace fatalities from falls. Under the standard, employers must educate workers through a training program, which has to include hazard identification, procedures for mitigating them and fall protection and fall arrest systems, among other requirements.

After training, the employer must have a written certification record proving the employee finished the training, with dates and signatures required. There is no expiration on the training, but retraining may be required if the employee proves they are unfamiliar with the elements in the training or if changes lead to the training or specific fall equipment becoming “obsolete.”

Powered Industrial Trucks

Climbing its way in the ranks this year is violations under OSHA’s Powered Industrial Trucks standard. Last fiscal year, this violation ranked ninth. This year, it’s the seventh, with 1,749 violations being issued.

Powered industrial trucks, or forklifts, are used in a variety of industries and settings. In the U.S. alone, it’s estimated that there are over 1.5 million forklift operators. With so many workers using and being around this equipment, it’s important to know how to keep them safe. Here are just a few ways employers can mitigate risks.

Training. Make sure your worker is qualified to work. Forklift operators must complete training and evaluations as outlined in OSHA standard 1910.178. These trainings include formal instruction, practical training and an evaluation.

Inspections. Inspections must be performed on a daily, pre-shift basis, according to OSHA. Checklists for these inspections are often provided by the manufacturer. If an item is found to malfunction or be inoperable, the forklift should be removed from service and sent to be fixed.

Safe Environments. Hazards like blind corners or items blocking the path can result in an incident. Forklifts can also be too big for the area they’re designed to work in. In this case, employers should take precautions to purchase the correct size forklift.

Control of Hazardous Energy (Lockout/Tagout)

The violation to rank number six on the list this year is control of hazardous energy (lockout/tagout). This also ranked sixth in FY21, but OSHA reported nearly 300 additional violations for FY22 (1,698 vs 1,977), according to preliminary data.

When employees are servicing equipment or machines, the energy from these machines needs to be controlled. If a machine turns on while someone is fixing or servicing it, it can lead to an injury, like a cut, fracture, amputation or death. How do you avoid injuries like these? OSHA’s standard on controlling hazardous energy (lockout/tagout) 1910.147 lists many requirements. Just a few are addressed below.

  1. An energy control program should involve “energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, start up or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source, and rendered inoperative,” OSHA says.
  2. Another requirement under the standard is lockout/tagout (LOTO). In section (c)(2) of the standard, OSHA requires lockout to be used “if an energy isolating device is capable of being locked out.” Tagout can be used if the lockout-capable device will still “provide full employee protection” with tagout and if a device cannot be locked out. Employers should also train workers in LOTO. Retraining may also be necessary in some cases.

Scaffolding

Coming in at number five on the list, and one of two violations on the list for construction, is scaffolding. Although this violation placed fourth last fiscal year, more violations were issued in FY22, 2,058 this year versus 1,948 last year.

According to OSHA, in 2020, 52 workers lost their lives after they fell from scaffolding. No matter what industry you’re working in, ensuring standards for scaffolding are followed is essential to worker safety. OSHA standard 29 CFR 1926.451 explains some of the requirements.

According to the standard, “each scaffold and scaffold component must support without failure its own weight and at least 4 times the maximum intended load applied or transmitted to it.” The design of the scaffolding needs to incorporate this weight requirement. In addition, the platform must be “at least 18 inches wide,” and a guardrail or personal fall arrest system must be provided to keep workers safe, OSHA says. There are circumstances where guardrails are not required, such as when the distance between the platform edge and “the face of the work” are less than 14 inches, according to the standard.

Ladders

Moving down the list this fiscal year is violations for ladders. This is also the top violation in the construction industry for F22. In FY21, preliminary data showed that 2,026 violations were issued under this standard, 29 CFR 1926.1053. In FY22, OSHA estimates that 2,143 violations were issued.

OSHA’s standard for ladders outlines numerous requirements and proper ways to use ladders, such as:

  • Do not overload the ladder beyond its weight capacity
  • There should be no hazards, like “oil, grease and other slipping hazards,” on the ladder.
  • Any defects on a portable ladder need to be addressed. The ladder should be taken out of service and labeled so workers know to not use it.
  • When climbing up or down the ladder, the worker must face the ladder and hold the ladder with “at least one hand.”

The standard also outlines requirements for different types of ladders. For example, “non-self-supporting ladders shall be used at an angle such that the horizontal distance from the top support to the foot of the ladder is approximately one-quarter of the working length of the ladder.”

Respiratory Protection

Third on the list this fiscal year is respiratory protection. From FY21 to FY22, OSHA saw a decrease of over 300 violations, 2,527 versus 2,185, respectively. With this decrease came a change in rank from second to third.

There are many factors that must be taken into account when selecting the proper respiratory protection for workers. Depending on the hazards, your employees may need an air-purifying respirator or an atmosphere-supplying respirator to keep them safe. But how do you know what kind of respirator is the best given your work environment? To find this out, OSHA says you will need to:

  • “Conduct an exposure assessment to determine the type and amount of hazardous exposure
  • Take into account the factors that can influence respirator selection such as job-site and worker characteristics
  • Understand the assigned protection factors
  • Know the various kinds of respirators and their relevant characteristics.”

The agency also provides a guide on its website to help you select the right respiratory protection. In order to use the program, employers will need to know their work environment’s oxygen percentage and contaminates, as well as some concentrations of specific contaminates.

Hazard Communication Standard

Violations of the Hazard Communication Standard have drastically increased in the past fiscal year, rising from fifth place in 2021 to second in FY22. A total of 1,947 violations were issued in FY21. This fiscal year, 2,424 violations were handed out by OSHA, a difference of over 400 violations.

With an increase in violations, understanding what the Hazard Communication (HazCom) standard requires of businesses and chemical manufacturers is essential. The standard, 1910.1200, includes a myriad of information pertaining to hazard classification, a HazCom program, labels, worker training and trade secrets. It also includes specifics on Safety Data Sheets, or SDSs.

Even if you don’t work in an industry with chemicals, you may remember SDSs from a chemistry class. SDSs provide information on chemicals, including hazard identification, first aid measures, storage information and transport information. OSHA’s HazCom standard outlines the requirements for SDSs in the workplace. Under the standard, SDSs are required by employers and companies for each chemical that is used, produced or imported. Each SDS must also include the required 16 sections and be available in English.

When changes to chemicals occur, manufacturers must update the SDS accordingly. It’s imperative to maintain up-to-date SDSs as one with old information may not be accurate, potentially leading to employee harm.

Fall Protection

Finally, placing number one on the list for the 12th year in a row is fall protection. Although the number of violations in this standard has been slowly decreasing in the past years—down from 5,424 violations in fiscal year 2020 to 5,295 in FY21 to 5,260 this year—it's still ranked number one.

In 2020, the Bureau of Labor Statistics reported 49,250 incidents of nonfatal falls to a lower level. there are many steps employers can take to keep workers safe from falls. According to OSHA, employers can make sure all holes are guarded, to use guard rails and toe-boards for an “elevated open sided platform, floor or runway” and when there is a hazard for falling in or on a machine or equipment and to use safety equipment like a “safety harness and line, safety nets, stair railings and hand rails.”

In addition, the agency “requires employers to:

  • Provide working conditions that are free of known dangers.
  • Keep floors in work areas in a clean and, so far as possible, a dry condition.
  • Select and provide required personal protective equipment at no cost to workers.
  • Train workers about job hazards in a language that they can understand.”

In a press release, NSC president and CEO Lorraine Martin said, “OSHA’s annual Top 10 list helps define trends so safety professionals can find the appropriate solutions…Despite advancements in workplace safety, we continue to see the same types of violations each year. It’s more important than ever employers seek education and resources to keep their workers safe.”

This article originally appeared in the December 1, 2022 issue of Occupational Health & Safety.

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