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OSHA announced 2019’s Top 10 Violations a few weeks ago with little change in the list from last year. The control of hazardous energy (lockout/tagout) and respiratory protection traded spots on the list, but all other topics remained where they were.

Take what you will from the list’s incredible consistency. Some see OSHA focused on the same particular infractions, while others translate the annual list as employer’s refusal to address the same safety concerns year to year.

OSHA’s Top 10 Violations for 2019

1.  Fall protection general requirements for Construction (29 CFR 1926.501)

2.  Hazard communication standard for General Industry (29 CFR 1910.1200)

3.  Scaffolding general requirements for Construction (29 CFR 1926.451)

4.  Control of hazardous energy/LOTO for General Industry (29 CFR 1910.147)

5.  Respiratory protection for General Industry (29 CFR 1910.134)

6.  Ladders for Construction (29 CFR 1926.1053)

7.  Powered industrial trucks for General Industry (29 CFR 1910.178)

8.  Fall protection—Training Requirements (29 CFR 1926.503)

9.  Machinery & machine guarding for General Industry (29 CFR 1910.212)

10. Personal Protective & Lifesaving Equipment—Eye and Face Protection (29 CFR 1926.102)

As I have noted before, this list helps safety professionals, particularly facility managers, target areas for improvement and review. Given the growing number of PPE citations and the fact that fall protection topics are listed twice on this list, all of us should be reviewing those areas of our safety policies and evaluating the instructional efficacy of our educational programs.  

Most importantly, as lockout/tagout climbs the list (#5 last year, #4 this year), all EHS professional should stop and take notice of the implications of failures regarding this particular standard (29 CFR 1910.147). Have your authorized, affected and other workers received LOTO training recently and are your LOTO procedures current? How confident are you in your facility’s understanding of the Minor Service Exception? Don’t worry, EI has a team of LOTO experts that can fill in the gaps in your hazardous energy program.

Again, the reason these Top 10 OSHA Violations persist year-to-year is that the majority of facilities in America believe that their policies are sufficient and their safety programs are up-to-date. Before joining that club of companies that discover they are mistaken (via inspection or injury), consider contacting The EI Group and allowing our EHS experts to assist you.  Our safety professionals offer decades of experience addressing all OSHA standards and look forward to fortifying your program via mock OSHA audits, program assessments and wide-ranging training topics committed to protecting your workers.

If you have questions about any of OSHA’s Top 10 Violations and what we can do to address specific concerns at your facility, please contact me at (919) 459-5252 or jpoole@ei1.com.