Top 10 OSHA Violations and How to Avoid

Top 10 OSHA Violations and How to Avoid Them

Agenda • OSHA Violations and Penalty Structure – How Much Can the Fines Be? • Most Frequently Cited Standards in General Industry – What are the Most Common Violations? • Avoiding Common Violations – What to Do to Avoid the Most Commonly Cited Items

Violation Penalty Structure • Civil and Criminal Penalties and Fines • Criminal Penalties – Willful and Repeat Offenders – Serious Injuries and Fatalities Involved – Can Include a Monetary Fine or Jail Term or Both • Criminal Penalties – Willful Violation with a Fatality – First Conviction • Fine: $250, 000 per Individual, $500, 000 per Organization • 6 Months in Prison – Willful Violation with a Fatality – Second Conviction • Fine: $250, 000 per Individual, $500, 000 per Organization • One Year in Prison

Fines and Penalties • Civil Fines – Dependent on Severity of Violation – Increases for Repeats – Increases for Willful Violation – Subject to the egregious policy • Egregious Policy (MULTIPLIER) • Civil Penalties – Failure to Post (Up to $7, 000) • Civil Penalties – De. Minimus (None) – Other than Serious (Up to $7, 000 each) – Serious (Minimum $100 each - Up to $7, 000 each) – Willful (Minimum $5, 000 each – Up to $70, 000 each) – Repeat (Minimum $5, 000 each - Up to $70, 000 each) – Failure to Abate (Up to $7, 000 per Day per Violation)

Most Frequently Cited Items

Most Cited Item #1 • Machine Guarding Issues – 1. 2. 3. 4. 5. 29 CFR 1910. 212, 215, & 219 General Machine Guarding Violations Point of Operation Grinders – Tongue Guards Exposed Pulleys Grinders – Work Rests

Machine Guarding • Key Issues – Prevent Potential Contact with All Moving Machinery and Energy Sources • Point of Operation • Motions – Rotating – Reciprocating – Transversing • Action – – Punching Cutting Shearing Bending • Action Plan q Inventory All Machinery at the Facility q Examine Each Machine for Hazardous Motions, Actions, and Energies q Implement a Safeguard for Every Identified Hazard q Train Employees Not to Defeat Safeguards q Train Employees in Proper Operation and Service of Machinery

Most Cited Item #2 • Hazard Communication – 1. 2. 3. 4. 5. 29 CFR 1910. 1200 Hazard Communication Written Program Information and Training for New Hazards Missing Material Safety Data Sheets Missing / Incorrect Labels

Hazard Communication • Key Issues – Written Hazard Communication Program – Sharing Chemical Safety Information with Employees • • Accurate Inventories MSDS Available Training Labeling • Action Plan q. Develop a Site Specific Program q. Inventory All Chemicals q. Collect MSDS for All Identified Chemicals q. Train Employees on Chemicals and Hazards q. Ensure Correct Labeling and Storage

Most Cited Item #3 • Lockout Tagout – 29 CFR 1910. 147 1. Lockout Tagout Written Program 2. Lockout Tagout Machine Specific Procedures 3. Training 4. Periodic Inspections 5. Content / Quality of Energy Control Procedures

Lockout Tagout • Key Issues – Written Energy Control Program – Written Procedure for Each Machine, Process, or System – Readily Identifiable Lockouts Occurring – Training – Auditing and Follow-up • Action Plan q. Develop a Site Specific Program q. Develop a Specific Procedure for Each Machine or Process q. Train Employees q. Provide Appropriate Locks, Tags, Etc. q. Frequent Program Audits (Routine and Non-Routine Tasks)

Most Cited #4 • Electrical Safety – 1. 2. 3. 4. 5. 29 CFR 1910. 303, 304, & 305 Conductor Protection from Abrasion Exposed Live Parts Inadequate Grounding Missing Electrical Box Covers No Strain Relief on Flexible Cords and Cables

Electrical Safety • Key Issues – Prevent Contact with Live Electrical Parts • Guarding • Maintenance of Connectors, Covers, Boxes, Etc. • Training • Lockout Tagout Program • Labeling • Action Plan q. Examine Electrical Equipment at the Site q. Identify All Potential Exposures to Live Parts q. Repair or Replace Damaged Equipment As Soon as Identified q. Train Employees on Basic Safe Practices

Most Cited #5 • Personal Protection – 1. 2. 3. 4. 5. 29 CFR 1910. 132, 133, & 134 Eye and Face Protection General PPE Hazard Assessments Written Respiratory Protection Program Respirator Medical Evaluation

Personal Protection • Key Issues – Evaluation and Certification of Requirements – Supplying Appropriate PPE – Maintaining PPE in Good Condition – Training on Use and Limitations – Engineering Controls • Action Plan q Examine Each Job Task to Identify Hazards q Engineer Out Hazards if Possible q Develop PPE Assessments q Certify PPE Assessments q Supply PPE for Hazards as Appropriate q Respiratory Protection Programs q Train Employees

Most Cited #6 • First Aid and Fire Protection – 1. 2. 3. 29 CFR 1910. 151 & 157 Eye and Body Flushing Facilities Fire Extinguisher Training Presence and Accessibility of Fire Extinguishers 4. Fire Extinguisher Maintenance 5. First Aid Supplies and Training

First Aid and Fire Protection • Key Issues – Provide Eye and Body Water Flushing Facilities where Chemical Hazards Indicate Need – Availability of Immediate, Quality First Aid – Maintenance of Fire Protection and Life Safety Systems – Training Employees on Emergency Procedures • Action Plan 1. Identify Potential Chemical Hazards to Eyes and Provide Flushing Facilities 2. Devise a Program to Provide First Aid and Provider Protection When Needed 3. Set Up PM Schedules and Checklists for Fire Protection and Other Life Safety Equipment 4. Train Employees

Most Cited #7 • Walking and Working Surfaces – 1. 2. 3. 4. 5. 29 CFR 1910. 22, 23, &24 Open Sided Floors and Platforms General Housekeeping Wet Floors Stair and Platform Railings Floor Holes

Walking / Working Surfaces • Key Issues – Protect Employees from Falls Off Edges – Prevent Slips, Trips, and Falls • Action Plan q. Examine Walking and Working Surfaces at the Site q. Correct Any Potential Hazards Identified q. Conduct Regular Housekeeping Inspections and Correct Deficiencies

Most Cited #8 • Industrial Trucks – 1. 2. 3. 29 CFR 1910. 176 & 178 Operator Competency and Training Truck Operating Condition Secured Storage

Industrial Trucks • Key Issues – Operator Training and Certification – Forklift Operating Conditions and Safety Equipment – Handling Large, Heavy, and Awkward Loads • Action Plan q. Identify Employees Who Drive Industrial trucks q. Train Employees – Include Hands-on Demonstration and Certification of Skills q. Monitor Driving and Load Handling and Correct Behaviors as Needed

Most Cited #9 • Means of Egress – 1. 2. 3. 4. 5. 29 CFR 1910. 36, 37, & 38 Obstructed Exit Pathways not Clearly Marked Exit Pathways not Marked Emergency Action Plans Failure to Mark “Not an Exit” on Dead Ends

Means of Egress • Key Issues – Employees Must be Able to Evacuate Quickly – Posting of Exit Signs and Exit Routes – Employee Training – Hardware Issues • Door Locks • Door Swing • Door and Hall Width • Action Plan q. Develop a Comprehensive Emergency Response Plan with Identified Exit Pathways q. Train Employees q. Practice (Have a Drill Periodically) q. Examine Exit Pathways and Conditions Regularly

Most Cited #10 • Hazardous Materials – 29 CFR 1910. 101, 106, & 107 1. Compressed Gas Handling, Storage, and Use 2. Flammable Liquids Dispensing 3. Spray Booth Ventilation 4. Spray Areas – Electrical Wiring 5. Spray Areas – Combustible Residue

Hazardous Materials • Key Issues – Handling, Storage, and Disposal • • Compressed Gases Flammable Liquids Hazardous Chemicals Flammable and Combustible Painting – Housekeeping to Reduce Fire and Health Hazards • Action Plan q. Identify Areas Where Specialty Chemicals are Being Used q. Examine Specific OSHA Requirements q. Train Employees q. Conduct Routine Housekeeping Inspections

Other Standards to Evaluate • Permit Required Confined Space Entry • Hearing Conservation • Welding, Cutting, and Brazing • Hand Power Tools • Powered Platforms • HAZWOPER • Specific Chemical Standards • Laboratory Safety • Special Industry Standards – – – – – Pulp and Paper Textiles Bakery Equipment Laundry Machines Sawmills Logging Telecommunications Electric Power Generation Grain Handling

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