top 10 osha violations and how to avoid them. agenda osha violations and penalty structure –how...
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Top 10 OSHA Violationsand 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– DeMinimus (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
0 500 1000 1500 2000 2500 3000 3500 4000
Hazardous Materials
Means of Egress
Industrial Trucks
Walking / Working Surfaces
First Aid - Fire Protection
Personal Protection
Electrical Safety
Lockout Tagout
Hazard Communication
Machine Guarding
Most Cited Item #1
• Machine Guarding Issues– 29 CFR 1910.212, 215, & 219
1. General Machine Guarding Violations
2. Point of Operation
3. Grinders – Tongue Guards
4. Exposed Pulleys
5. 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 Inventory All Machinery at
the Facility Examine Each Machine for
Hazardous Motions, Actions, and Energies
Implement a Safeguard for Every Identified Hazard
Train Employees Not to Defeat Safeguards
Train Employees in Proper Operation and Service of Machinery
Most Cited Item #2
• Hazard Communication– 29 CFR 1910.1200
1. Hazard Communication Written Program
2. Information and Training
3. Training for New Hazards
4. Missing Material Safety Data Sheets
5. Missing / Incorrect Labels
Hazard Communication
• Key Issues– Written Hazard
Communication Program
– Sharing Chemical Safety Information with Employees
• Accurate Inventories• MSDS Available• Training• Labeling
• Action PlanDevelop a Site
Specific ProgramInventory All
ChemicalsCollect MSDS for All
Identified ChemicalsTrain Employees on
Chemicals and Hazards
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 PlanDevelop a Site
Specific ProgramDevelop a Specific
Procedure for Each Machine or Process
Train EmployeesProvide Appropriate
Locks, Tags, Etc.Frequent Program
Audits (Routine and Non-Routine Tasks)
Most Cited #4
• Electrical Safety– 29 CFR 1910.303, 304, & 305
1. Conductor Protection from Abrasion
2. Exposed Live Parts
3. Inadequate Grounding
4. Missing Electrical Box Covers
5. 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 PlanExamine Electrical
Equipment at the SiteIdentify All Potential
Exposures to Live Parts
Repair or Replace Damaged Equipment As Soon as Identified
Train Employees on Basic Safe Practices
Most Cited #5
• Personal Protection– 29 CFR 1910.132, 133, & 134
1. Eye and Face Protection
2. General PPE
3. Hazard Assessments
4. Written Respiratory Protection Program
5. 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 Examine Each Job Task to
Identify Hazards Engineer Out Hazards if
Possible Develop PPE Assessments Certify PPE Assessments Supply PPE for Hazards as
Appropriate Respiratory Protection
Programs Train Employees
Most Cited #6
• First Aid and Fire Protection– 29 CFR 1910.151 & 157
1. Eye and Body Flushing Facilities
2. Fire Extinguisher Training
3. 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 Identify Potential Chemical
Hazards to Eyes and Provide Flushing Facilities
Devise a Program to Provide First Aid and Provider Protection When Needed
Set Up PM Schedules and Checklists for Fire Protection and Other Life Safety Equipment
Train Employees
Most Cited #7
• Walking and Working Surfaces– 29 CFR 1910.22, 23, &24
1. Open Sided Floors and Platforms
2. General Housekeeping
3. Wet Floors
4. Stair and Platform Railings
5. Floor Holes
Walking / Working Surfaces
• Key Issues– Protect Employees
from Falls Off Edges– Prevent Slips, Trips,
and Falls
• Action PlanExamine Walking and
Working Surfaces at the Site
Correct Any Potential Hazards Identified
Conduct Regular Housekeeping Inspections and Correct Deficiencies
Most Cited #8
• Industrial Trucks– 29 CFR 1910.176 & 178
1. Operator Competency and Training
2. Truck Operating Condition
3. Secured Storage
Industrial Trucks
• Key Issues– Operator Training and
Certification– Forklift Operating
Conditions and Safety Equipment
– Handling Large, Heavy, and Awkward Loads
• Action PlanIdentify Employees
Who Drive Industrial trucks
Train Employees – Include Hands-on Demonstration and Certification of Skills
Monitor Driving and Load Handling and Correct Behaviors as Needed
Most Cited #9
• Means of Egress– 29 CFR 1910.36, 37, & 38
1. Obstructed Exit Pathways
2. Exit Pathways not Clearly Marked
3. Exit Pathways not Marked
4. Emergency Action Plans
5. 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 PlanDevelop a
Comprehensive Emergency Response Plan with Identified Exit Pathways
Train EmployeesPractice (Have a Drill
Periodically)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 PlanIdentify Areas Where
Specialty Chemicals are Being Used
Examine Specific OSHA Requirements
Train EmployeesConduct Routine
Housekeeping Inspections
Other Standards to Evaluate
• Permit Required Confined Space Entry
• Hearing Conservation• Welding, Cutting, and
Brazing• Hand and 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
Questions?
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