It's that time of year again when the Occupational Health and Safety Administration (OSHA) releases their list of the top 10 most frequently cited standards, and this year's list is without any surprise newcomers. For the last seven (fiscal) years, this list has largely gone unchanged, with the order shifting slightly in the back end from year to year. Here is the list of fiscal year (10/1/13 - 9/30/14) 2014's most cited standards:
- Fall Protection (1926.501)
- Hazard Communication (1910.1200)
- Scaffolding (1926.451)
- Respiratory Protection (1910.134)
- Powered Industrial Trucks (1910.178)
- Lockout/Tagout (1910.147)
- Ladders (1926.1053)
- Electrical - Wiring Methods (1910.305)
- Machine Guarding (1910.21)
- Electrical - General Requirements (1910.303)
As I mentioned above, these same ten standards have made up this list for the past seven years. The order does not change dramatically from year to year either, especially at the top of the list. For instance, the four most frequently cited standards have been the same for the past six years, with some fluctuation in the order.
So why are these lists comprised of the same ten standards year in and year out?
Well, there are a few factors that contribute to the OSHA Top 10 essentially being a carbon copy from the year before. The first reason is simply because they are fundamental, commonplace, and can be applied to almost any facility or operation, regardless of industry. The Hazard Communication, Lockout/Tagout, and Electrical standards are great examples of this. Severity and frequency of associated injury is another reason why we see some of these standards continually make the list. The Fall Protection, Machine Guarding, Ladders and Scaffolding standards are examples of how injury frequency and severity contribute to recurrent citations. Lastly, certain standards are continually present on these lists due to education issues. The best example of this would be the Respiratory Protection standard, which is frequently cited for lack or absence of training as well as the improper use of the equipment. There are many factors that ultimately determine these annual lists, but generally speaking, these are the most influential.
Now that we've identified that there is an obvious trend in the focus of OSHA citations, where do we go from here?
The answer is simple: Use this information to improve the overall safety program at your facility or work site. This annual list isn't created by OSHA for the purpose of advising you on how to avoid giving them your money, although it is a nice benefit if the information is processed correctly. OSHA publishes these lists to identify where they find the most frequent gaps. So, with that in mind, take this list and go over each of these programs (if applicable of course) in your facility and see if you can find a way to improve on them. Once you've identified your own gaps, make the changes so that your workers leave as healthy each day as they came in and so you won't be cutting OSHA a substantial check for fine penalties. I'm sure that money could be put to much better use elsewhere.