Category: OSHA

Top Cited OSHA Violations

The Occupational Safety and Health Administration (OSHA) releases a list each year of the most frequently cited violations. Knowledge of these violations can assist you in identifying and correcting similar risks in your company.

In November 2015, Congress enacted legislation requiring federal agencies adjust their civil penalties to account for inflation. OSHA citation fees increased seven-fold in 2016 and will continue to go up with annual inflationary adjustments. The increase from 2019 to 2020 was 1.8%.

If you assess your safety program with an emphasis on correcting these commonly cited hazards, and you will be safer and save money in penalty fees!

Here are a few tips for mitigating some of the most frequently cited hazards associated with 3 of OSHA’s Top 10 citations. For the complete list, please watch my webinar presentation.

↘  Fall Protection

Falls continue to be the leading cause of death in the construction industry accounting for over 33% of fatalities. Almost two-thirds of fall accidents are from roofs, ladders, and scaffolds.

The construction industry is a unique place to work, with jobsite conditions changing from day-to-day or even hour-to-hour. Fall exposures are frequent and varied. This safety challenge can be met with success if we pay attention to OSHA’s requirements under the “Fall Protection Standard (1926 Subpart M)”, “Scaffolds (1926 Subpart L),” and “Stairways and Ladders (1926 Subpart X)”.

Additional information and resources for Fall Protection can be found here:

https://www.osha.gov/SLTC/fallprotection/

↘ Eye and Face Protection

Conduct a hazard assessment and identify those work tasks that require eye and face protection to guard employees from hazards like flying particles, chemicals, or optical radiation. Your assessment must include evaluation of exposures to both the employee performing the task or job, as well as other employees that might be working in the same area. These assessments will help you choose the correct eye and/or face protection to help prevent eye and face injuries. Keep in mind, normal prescription eyewear does not provide protection from impact or penetration hazards. To provide appropriate protection, prescription eye wear must be manufactured per the requirements of the “American National Standards Institute, ANSI Z87.1”. Otherwise, you could provide “wear-over” type eye protection.

Eye and face protection requirements are addressed in OSHA’s Construction Industry under the “Personal Protective and Lifesaving Equipment Standard, 1926 Subpart E”, which can be found here:

https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.102

https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.133

↘  Hazard Communication

The Hazard Communication Standard (HCS) helps employers classify and identify chemical hazards and controls for safe use. It’s basically chemical safety in the workplace. Employers need to ensure that their employees understand the hazards presented by the chemicals they’re using, AND most importantly, what measures must be taken to prevent injury while using these chemicals.

Safety Data Sheets (SDS) for each chemical must be readily available to all employees and updated as needed. SDS contain important information from the manufacturer regarding the chemical hazards and safeguards.

Watch for improperly labeled or unlabeled containers. Accurate and compliant labeling will contain the following information:

  • The product identifier, i.e. the name of the chemical
  • The manufacturers’ name and address
  • A “Signal Word” to quickly ascertain the level of hazard, either “Danger” or “Warning.”
  • A “Hazard Statement” that describes the nature of the hazard(s), e.g. “causes serious eye damage”
  • A “Precautionary Statement(s)”, e.g. “wear appropriate eye protection”
  • And a “Hazard Information” pictogram(s)

A great resource for employers to ensure compliance with “OSHA’s Hazard Communication Standard” can be found here: https://www.osha.gov/dsg/hazcom/index.html

Hazard identification and control are key components of a successful safety program.  Taking a closer look at OSHA’ s annual list of their Top 10 Most Frequently Cited Violations and appropriate measures to avoid them will help you in your ongoing safety efforts.  For more information please click the links below to watch the webinar or download the slide presentation.

OSHA’s Top Ten Cited Violations of 2019 – Webinar

Webinar Slide Presentation

Returning to Work Post COVID-19

As more and more states begin to loosen their stay at home restrictions, the question many business owners have right now is, “When can we get our employees back to work, and how do we do so, safely?” Many companies were able to transition to a remote working environment and subsequently have seen their employees really step up to the plate and become very productive working from home. As a result, numerous businesses are making the decision to allow their employees continue to work from home even as regulations begin to allow a return to work. St. Louis County specifically stated that if a business has been able to efficiently operate remotely, they should consider allowing employees to continue to work from home for a little longer.

Getting back on the job

However, not all business can operate remotely and may be eager to get their employees back to work as soon as possible. First and foremost, those businesses must follow the protocol outlined in the applicable reopening guidelines as directed by their states or counties. This could include limited staff or patrons in the building, or enhanced cleaning and employee health screenings. In order to effectively follow these guidelines, employers may choose to allow employees back in waves, or stagger office hours, thus, limiting the exposure each employee has to other coworkers. This may be a great solution for the manufacturing industry where employees work closely to one another.

Safety and Sanitization

Not only may enhanced sanitization be required, it can also help ease employee’s minds when returning. Sanitizing shared or frequently used work surfaces multiple times per day will help reduce potential exposure to the virus. We recommend providing access to hand sanitizer or hand washing stations for employees. Many companies are requiring all employees who return to work, wear masks and/or gloves to help protect themselves. Though it is not a requirement, it’s recommended that if the organization is requiring employees to wear masks and gloves, those should be supplied by the company. Furthermore, management should also consider putting new policies in place for all employees returning to work, so staff is aware of these expectations and mandates prior to returning to work.

Health Screenings and Considerations

As businesses reopen, they may be required to perform daily health screenings under applicable legislation, or they may choose to do so in an effort to protect staff. These screenings can include daily health questions to confirm the employee is not exhibiting any symptoms of COVID-19 and has not been around anyone with those symptoms. It could also include taking the temperatures of staff or visitors. This may cause an issue with privacy concerns, so employers should take great caution with those administering these tests and protecting the data. Employers do have the right to refuse work to anyone who is sick with COVID-19-like symptoms.

Adjustment Period

The environment employees are returning to may look very different from the environment they left a few months ago. The dynamic in the office will be a little foreign and helping employees get back into the swing of things and adjusting to the changes, is important. Reminding and enforcing guidelines on sanitization, masks, social distancing, and health screenings can help ease concerns of employees apprehensive of returning. However, there may be employees who are simply too scared to return, and these situations should be handled carefully. Overall, employers should strive to provide peace of mind to know staff and remind them the primary concern is employee safety.

As we continue to navigate this uncharted territory as a society, we will start to learn more about what works best and create new best practices for our businesses. Below are some helpful links from the CDC and OSHA that will help you make informed decisions on how to proceed with safely opening your businesses and getting back to work. Should you have any questions, please do not hesitate to reach out to us.

https://www.osha.gov/pls/publications/publication.html#c19
https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-business-response.html
https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-small-business.html
https://www.cdc.gov/coronavirus/2019-ncov/community/general-business-faq.html
https://www.cdc.gov/coronavirus/2019-ncov/community/reopen-guidance.html

Post Your OSHA Log Summary by Feb. 1, 2016

OSHA Log SummaryIt’s that time of year again. Employers need to tabulate their annual OSHA Log Summary (OSHA Form 300A) and post it in a common area by Feb. 1, 2016.

To be an effective risk management solution, the OSHA Log Summary must list the total number of job-related injuries and illnesses that occurred in 2015. These should also be logged on your OSHA 300 Form. And don’t forget to leave the Summary posted until April 30, 2016. 

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