osha’s top 10 citations & the american institute of ... · questions related to specific...

Safety Environmental Engineering, Inc.38 N. Main Street

Keedysville, MD 21756 (301) 432-3949

OSHA’s Top 10 Citations & How to Avoid Them

Continuing Education CreditsInforma Exhibitions is a registered and/or recognized education provider with The American Institute of Architects Continuing Education Systems. Attendees can earn credit upon completion of this program provided you sign in with appropriate license number on forms provided at the seminar room check-in tables. Electronic Certificates of Completion for all attendees will be available 7-8 weeks post show.

This course is registered with AIA CES for continuing professional education. As such, it does not include content that may be deemed or construed to be an approval or endorsement by the AIA of any material of construction or any method or manner of handling, using, distributing, or dealing in any material or product.

Questions related to specific materials, methods and services will be addressed at the conclusion of this presentation.

Copyright MaterialsThis presentation is protected by US and International copyright laws. Reproduction, distribution, display and use of the presentation without permission of the speaker is prohibited.

© 2015/2016 by SEE, Inc. and Matt Murphy. All rights reserved. No parts of this publication may be reproduced, distributed, or transmitted in any form or by any means, including photocopying, recording, or other electronic or mechanical methods, without the prior written permission of Matt Murphy, President and Owner of SEE, Inc.

Learning Objectives

Upon completing this program, the participant should be able to:

1. Recognize the top ten OSHA construction violations

2. Determine how to recognize hazards

3. Identify where to find the referenced regulations

4. Summarize easy remedies for these violations

Top 10 OSHA Citations FY2013Top 10 OSHA Citations in Construction

1. Duty to have Fall Protection2. General Requirements of Scaffolds3. Ladders4. Training Requirements for Fall Protection5. Hazard Communication6. Eye and Face Protection7. Head Protection8. Aerial Lifts9. Specific Excavation Requirements10.General Safety and Health Provisions

Top 10 OSHA Citations FY2014Top 10 OSHA Citations in Construction

1. Fall Protection in Construction (1926.501)2. Hazard Communication (1910.1200)3. Scaffolding in Construction (1926.451)4. Respiratory Protection (1910.134)5. Powered Industrial Trucks (1910.178)6. Lockout/Tagout (1910.147)7. Ladders in Construction (1926.1053)8. Electrical – Wiring Methods (1910.305)9. Machine Guarding (1910.212)10. Electrical – General Requirements (1910.303)

Changes between FY13 and FY14

New to the List in FY14:• Respiratory Protection (1910.134)• Powered Industrial Trucks (1910.178)• Lockout/Tagout (1910.147)• Electrical – Wiring Methods (1910.305)• Machine Guarding (1910.212)

Changes between FY13 and FY14

Removed from List between FY13 and FY14• Training Requirements for Fall Protection• Hazard Communication• Eye and Face Protection• Head Protection• Aerial Lifts• Specific Excavation Requirements

Top 10 Serious Violations FY14

A “serious” violation is one in which there is substantial probability that death or serious physical harm could result. Carries penalty up to $7,000 per serious violation.

What is wrong with these pictures??

#1 Fall Protection in Construction

• Workers exposed to a fall hazard 6 ft. (1.8 m) or more above lower levels must be protected by conventional fall protection (i.e., guardrail systems, safety net systems or PFAS).

Fall Protection in Construction

For the Fourth Year in a Row – Fall Protection is the #1 Cited OSHA Construction Violation!• 6 feet is the trigger height for when fall

protection is required for construction sites.• There is a 10 foot trigger height when working

off of scaffolding. • There is no trigger height for fall protection

systems when working off of ladders.

Fall Protection in Construction

• Falls are the leading cause of serious and fatal injuries in residential construction.

• 49% of all residential construction fatalities are from falls.

• Nearly 2 out of every 5 fatalities caused by falling from roofs.

• The risk of falling can be minimized or eliminated by following safe work practices and with the use of fall protection systems.

• Violations related to fall hazards comprise 3 out of the 10 most frequently cited OSHA standards.

Fall Protection in Construction When is Fall Protection Required?

• Floor openings greater than 2” square• Open sided stairs, landings above 6’• Window sills less than 39’’• Working at heights above 6’• On scaffolding over 10’• Stairs and stairways• Wall openings

Conventional Fall Protection• Where workers on a construction site are exposed to

vertical drops of 6 feet or more, OSHA requires that employers provide fall protection in one of three ways before work begins:– Conventional Fall Protection (i.e., personal fall arrest

system, guardrails, safety nets)– Other Work Methods (i.e., working from ladders,

scaffolding, aerial lifts)– Alternative Fall Protection (i.e., controlled access zones,

warning line systems)

Fall Protection Rescue Plan• Describes the steps taken to rescue a

fallen worker, even if they are wearing a PFAS.

• Sample Procedures Include:▫ Ensuring the plan can safely rescue

a suspended worker within 3-4 minutes of falling.

▫ Contacting appropriate emergency personnel

▫ Using ladders or other methods to rescue worker

Calculating Fall Distances Calculating Fall Distances

• Regulations require that a worker cannot free fall more than 6 feet.

• How far a worker will fall depends on a variety of factors, which include but is not limited to:▫ Body size of worker▫ Fit of harness, to allow for stretch▫ Type of lanyard (rip-stitch or self-retracting)▫ Safety factors

#2 Hazard CommunicationThe three major areas of change with GHS are in hazard classification, labels, and safety data sheets.

• Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result.

• Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.

• Safety Data Sheets: Will now have a specified 16-section format.

Hazard Communication

• Develop a written hazard communication program that details how workers will be protected from hazardous material exposure.

• Use engineering controls, safe work practices, and appropriate personal protective equipment (PPE) to minimize worker exposure to hazardous materials and chemicals.

• Train workers on the globally harmonized system (GHS) pictograms and hazards associated with the chemicals used.

Hazard Communication• Follow manufacturer’s instructions

on handling, use and storage of hazardous chemicals.

• Ensure Safety Data Sheets are maintained and readily available for all hazardous materials used on the jobsite.

• Ensure that all containers are clearly labeled with product identity and hazard information.

• Provide an eyewash station.

Hazard Communication

Under the revised GHS labels will require the following:

• Pictogram: a symbol plus other graphic elements, to convey specific information about the hazards of a chemical. There are nine pictograms under the GHS.

• Signal words: The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards.

• Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard.

• Precautionary Statement: a phrase that describes measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical.

Hazard Communication Hazard Communication

Important Tips/Practices to Avoid Citations• Label all secondary containers immediately! • Utilize one system for the classification of

hazardous chemicals (i.e., NFPA or GHS).• Utilize an online Safety Data Sheet (SDS) system

that tracks and stores all files. • Collect Chemical Information Lists from

Subcontractors on Jobsites and verify that they have SDS on-file.

#3 Scaffolding• Provide safe access to get on and off of scaffolds

(i.e., use ladders)

• Erect Scaffolds on firm, drained, and level foundation. Use mud sills to prevent the scaffold from sinking. Do not use blocks, bricks, or scraps to stabilize the scaffold base.

• Fully plank a scaffold to provide a full work platform. Must be a scaffold grade and have no visible defects.

• When working from scaffolds there is a 10 foot trigger height for when fall protection is required.

• Workers can work up to 10’ without the use of guardrails or personal fall arrest systems.

Scaffolding

• Bureau of Labor Statistics' data reported 54 fatalities occurred in 2009 from scaffolds.

• 72% of workers injured in scaffold accidents attributed the accident either to the planking or support giving way, or to the employee slipping or being struck by a falling object.

• One of OSHA’s most frequently cited violations, #3.

Scaffolding

• Workers must be trained to recognize and work properly so as not to expose themselves to the following hazards while working in, on or around a scaffold:▫ Falls from the scaffold. ▫ Struck by falling materials, tools, debris, etc.▫ Electrocution from overhead electrical lines.▫ Scaffold collapse. ▫ Bad planking giving way.

Scaffolding

Common Hazards on Jobsites associated with Scaffolding:• No guardrails on scaffolds.• Defective wood planks and inadequate planking

overhang.• Unsafe access to scaffold.• Cross bracing not adequate.• Inadequate footings.• Bridging of scaffolds. • Working within 10 feet of overhead power lines

(discuss in greater detail)

ScaffoldingTraining Requirements• All employees must be trained prior to working

on scaffolds.• Qualified person must conduct the training and

include the following:▫ Electrical Hazards▫ Fall Protection▫ Falling Object Protection▫ Proper Use▫ Material Handling▫ Load-carrying Capacities

Scaffolding

Basic Requirements:• Scaffolding that is 10 ft. or higher must be

equipped with guardrails.• A competent person must supervise the set-up

and take down of all scaffolding.• Walls that support exterior scaffold must be

capable of supporting, without failure, the weight of the scaffold and four times the maximum intended load on the scaffolding.

• Scaffolding must be fully planked, and planks must be secured so they cannot move.

ScaffoldingBasic Requirements:• Scaffolds must be capable of supporting its own

weight and at least 4 times the anticipated load.• Expected load includes:

Workers Equipment Tools Materials

Scaffolding

Unsafe Practices to Avoid:• No guardrails on scaffolds.• Defective wood planks and inadequate planking

overhang.• Unsafe access to scaffold.• Cross bracing inadequate.• Workers not wearing hard-hats.• Scaffold placed too close to overhead power

lines.• Inadequate footings, etc.

Scaffolding

• Competent person inspects scaffolds for visible defects before each shift and after any alterations

• Defective parts must be immediately repaired

Scaffolding

#4 Respiratory Protection

Most Common Citation Scenarios:• Not using effective engineering and

administrative controls before using respirators. ▫ Not controlling respiratory hazards (dust) by wet

cutting, ventilation, etc. • Wearing the wrong respirator for the job and

hazard.▫ Wearing filtering facepiece (dust mask) when half-

mask respirator was required to protect worker.

Respiratory Protection• Engineering controls, such as ventilation and

substitution of less toxic materials should be the first line of protection against respirable hazards.

• Additionally, work-practice controls such as wet-cutting methods should be used before employees don respirators.

Respiratory Protection

• Protective devices used to protect against harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors.

• Employees may chose to voluntarily use N95 filtering facepieces (dust masks) without triggering the employer to comply with full respiratory protection standard.

Respiratory Protection ProgramTABLE OF CONTENTS 1. Purpose 2. Scope and Application 3. Responsibilities

– Program Administrator, Supervisors, Workers4. Program Elements

– Selection Procedures: Program Administration, Change Schedules, Medical Evaluation, Fit Testing, Respirator Use, Air Quality, Cleaning, Maintenance, Change Schedules, and Storage, Training

5. Program Evaluation 6. Documentation and Recordkeeping

Respiratory Protection Fit-Testing• Required when employees are mandated to wear air

purifying respirators. ▫ Prior to being allowed to wear any respirator with a tight

fitting facepiece.▫ Annually.▫ When there are changes in the employee’s physical condition

that could affect respiratory fit (e.g., obvious change in body weight, facial scarring, etc.).

▫ Employees will be fit tested with the make, model, and size of respirator that they will actually wear.

▫ Employees will be provided with several models and sizes of respirators so that they may find an optimal fit.

• Employees will be trained prior to using a respirator in the workplace.

• The training must be comprehensive, understandable and recur annually, and more often if necessary.

• As with any employee, supervisors must be trained prior to using a respirator in the workplace; they also should be trained prior to supervising workers who must wear respirators if the supervisors themselves do not use a respirator.

Respiratory Protection Training

#5 Powered Industrial Trucks

• (Forklifts)▫ You must be 18 years or older to operate a

forklift.

• Hazards associated with use:▫ Employee not trained on forklift

safety.▫ Employee not familiar with the

specific forklift vehicle.▫ Operation of forklift in unsafe

manner.▫ Operation of forklift with defect

or missing parts.

Powered Industrial Trucks

• How forklift differs from a car/truck:▫ Usually steers from the rear, rather than the front, making it

swing wide

▫ Carries heavy loads, often in tight places and rough terrain

▫ Can have reduced visibility

▫ Can have a high center of gravity making it susceptible to turnover

▫ Controls are different and more complicated

▫ Heavier than most cars and trucks


• Operator manual must be kept on the forklift at all times.


• Employees must be trained on:▫ Truck-related topics▫ Workplace-related topics▫ Standard requirements▫ Trainees must be supervised by a competent person and

not endanger others▫ Formal instruction▫ Practical training▫ Evaluation of performance


• Seatbelts are required on all forklifts manufactured since 1992.▫ Can be retrofitted on older

models.• Seatbelt use is required

when provided.


• Never lift workers on forks unless you are using an approved work platform with railings.

Powered Industrial Trucks #6 Lockout / Tagout

• OSHA has very prescriptive regulations for General Industry found in 1910.147.

• In construction, standards apply to circuits and equipment/tools.

• Since most servicing and maintenance of tools and equipment is considered general industry, this training will cover all regulations to ensure comprehension and compliance.

Lockout / Tagout

An energy isolation device is a physical device that prevents the transmission or release of energy. Examples include: Electrical disconnects Circuit breakers Lockable valves Blanks or blinds Blocks/pins under suspended objects

Lockout / Tagout• Lockout must be used when performing

servicing or maintenance on equipment whenever:▫ A machine guard is removed or bypassed; or▫ Any part of the body is placed into an area where

injury could result if the equipment were to startunexpectedly or stored energy were to bereleased.

Lockout / Tagout• Inspect tools before each use to ensure guards

are in place.

• Tag tools as defective and DO NOT USE if guards are removed or tampered with.

Lockout / Tagout

• Lockout is NOT required for plug connected equipment if the equipment or tool can be unplugged. The person performing work on the piece of

equipment must unplug the equipment before beginning work.

The plug must be under the exclusive control of the person performing the work.

Basic Lockout Sequence

2 - Bring equipment to a complete stop

3 - Turn off energy isolation devices listed in written procedure

4 - Place lockout adaptors on energy isolation devices IF REQUIRED

5 - Affix a multi-lock hasp to each energy isolation device

6 - Place lock on each energy isolation device

7 - Verify that e-stops have been released

8 - Verify zero energy state

9 - Maintain key to locks

10 - Complete the work

1 - Notify employees in area that the equipment will be locked out

Construction Specific Requirements

• Concrete and Masonry Construction:▫ No employee shall be permitted to enter storage

facilities unless the ejection system has been shut down, locked out, and tagged to indicate that the ejection system is not to be operated.

Lockout / Tagout


• No employee shall be permitted to perform maintenance or repair activity on equipment (such as compressors mixers, screens or pumps used for concrete and masonry construction activities) where the inadvertent operation of the equipment could occur and cause injury, unless all potentially hazardous energy sources have been locked out and tagged.

Lockout / Tagout


• Controls that are to be deactivated during the course of work on energized or deenergized equipment or circuits shall be tagged.

Lockout / Tagout

Concrete Trowels

• Powered and rotating type concrete troweling machines that are manually guided shall be equipped with a control switch that will automatically shut off the power whenever the hands of the operator are removed from the equipment handles.

Lockout / Tagout• Set the ladder at a 4 to 1 pitch.• Secure ladders near the top or at the bottom to

prevent them from moving or slipping.• Extend ladders at least 3 ft. above the landing to

provide a handhold or for balance. • Inspect ladder before use for any defects.

#7 Ladders

• Face the ladder when climbing up/down• Maintain min. 3 points of contact (feet

and 1 hand)• Keep body centered on ladder • Rule of thumb – do not let your belt buckle

go past either side rail of ladder. You will be overreaching.

• Do not carry anything that may cause loss of balance

• Consider using rope to raise/lower material

• Do not stand on top 2 rungs of stepladder

Ladders• Inspection of Ladders:▫ Missing or loose rungs▫ Damaged or worn non-slip feet▫ Loose nails, screws, bolts, rivets▫ Loose or faulty spreaders, locks▫ Rot, decay of wooden ladders▫ Cracked, split, worn or broken rails, braces, steps▫ Twisted or distorted ladders▫ Missing identification or safety labels▫ Do not paint ladders since defects may be concealed

Ladders

• Unsafe Practices – what to look for:▫ Ladders placed in high traffic areas▫ Overreaching when working from a ladder▫ Standing on the top 2 rungs of a stepladder ▫ Using a ladder that is too short or too long▫ Carrying materials that may cause loss of

balance▫ Are ladders secured? Placed on stable/level

ground?▫ Ladders have any missing rungs, rivets/bolts

or warped in any way?

Ladders• Keep manufactured and job-

made ladders in good condition and free of defects.

• Ensure that job-made wooden ladders can support at least four times the maximum intended load.

• They should have spliced side rails at an angle so that the horizontal distance from the top support to the foot of the ladder is 1/8th the working length of the ladder. Photo Courtesy: Associated Builders and Contractors-

Central Texas Chapter

Ladders

• Remove damaged or defective ladders and tag as DO NOT USE.

Ladders

• Do not stand on the top 2 rungs of a stepladder

Ladders

#8 & #10 Electrical

#8 Electrical Wiring#10 Electrical General Requirements

We will combine since many of the requirements overlap, and are contained in the same OSHA standards.

#8 & #10 Electrical

Clearance Distances• Where there is access to live electrical parts

(i.e., circuit breaker panels, temporary power poles, etc.) you must keep a 30 inch zone around the access area. ▫ Do not store anything within 30 inches of the

front of electrical cabinets or temporary power poles.

#8 & #10 Electrical • More than 3 milliamps (ma): painful shock• More than 10 ma: muscle contraction• More than 20 ma: considered severe shock • More than 30 ma: lung paralysis - usually

temporary• More than 50 ma: possible ventricular

fibrillation (usually fatal)• 100 ma to 4 amps: certain ventricular fibrillation

(fatal)• Over 4 amps: heart paralysis; severe burns

#8 & #10 Electrical

Leading Cause of Accidents / Violations• Drilling and cutting through cables.• Using defective tools, cables and equipment.• Failure to maintain clearance distance of 10 feet.• Failure to de-energize circuits.• Failure to guard live parts.• Improper installation/use of temporary electrical

systems and equipment.• By-passing electrical protective devices.• Not using GFCI (ground fault circuit interrupters)

devices.• Missing ground prongs on extension cords.

#8 & #10 Electrical

• Electrical equipment should not be used unless the manufacturer's name or trademark is placed on the equipment and unless other markings are provided giving voltage, current, wattage, or other ratings as necessary.

• You must be able to identify and lookup who the manufacturer is, and what their requirements are.

#8 & #10 Electrical • Each service, feeder, and

branch circuit, at its disconnecting means or overcurrent device, must be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. Mark circuits so you know

what you are turning off.

#8 & #10 Electrical

• GFCI - All 120-volt, single-phase 15- and 20-ampere receptacle outlets on construction sites, which are not a part of the permanent wiring must have approved ground-fault circuit interrupters (GFCI’s) for personnel protection.

#8 & #10 Electrical

Guarding Live Parts. • Live parts of electrical

equipment 50 volts or more must be guarded and protected.

#8 & #10 Electrical

• Conductors entering boxes, cabinets, or fittings must be protected from abrasion, and openings through which conductors enter must be effectively closed.

• Unused openings in cabinets, boxes, and fittings must also be effectively closed.

#8 & #10 Electrical

• All receptacles, outlets, pull boxes, junction boxes, switches, fittings, etc. must be closed by covers securely fastened in place

#8 & #10 Electrical

• Pull boxes, junction boxes, and fittings must be provided with approved covers.

• If covers are metal they must be grounded.

• Each outlet box must have a cover, faceplate or fixture canopy.

#8 & #10 Electrical

• Don’t use frayed, worn or damaged electrical cords or cables. ▫ This includes flexible power cords (extension cords).

#8 & #10 Electrical

Flexible Cords - called “extension cords”.• Must be protected from damage. Sharp corners

and projections should be avoided. Extension cords can be passed through doorways, windows or other pinch points if protection is provided.

#8 & #10 Electrical

Flexible Cords - called “extension cords”.• Cannot be secured with staples, nails or bare wire. • Must have a ground pin. • Must be inspected regularly and removed from

service if defective.• Use heat-shrink sleeve or bonding tape to fix

damage to cords.

#8 & #10 Electrical

• Bulbs must be protected or guarded.

• No broken bulbs or empty sockets.

• Not suspended by wiring.• In wet environments use

low voltage.

#9 Guarding• Saws, drills and nail guns account for 67% of

most tool injuries. • Top dangerous tools:▫ Saws▫ Drills▫ Nail Guns▫ Jackhammer▫ Hand Grinder▫ Chainsaw

• Bypassing safety guards only increases the risk of serious injury or death.

Guarding

• When power operated tools are designed to accommodate guards, they shall be equipped with such guards when in use.

• Common tool guards are shown in next slides.

Portable Saw Guarding

• Physical guard over the saw blade.

Grinder Guarding

• Physical guard over the grinding wheel.

Miter Box Saw Guarding

• Physical guard over the saw blade.

Guard Spinning Wheels

• Physical guard from spinning wheels.

Nail Gun Safety Guarding

• Safety switch prevents unwanted discharge.

Nail Gun Safety Tip and Spring

• Safety tip/spring prevents unwanted discharge.• If any of the following are exposed to contact by

workers, you must guard:▫ Belts▫ Gears▫ Shafts▫ Pulleys▫ Sprockets▫ Spindles▫ Drums▫ Fly Wheels▫ Chains▫ Reciprocating, rotating or moving parts of equipment.

Guarding

• You can use a combination of guards to protect against hazards; examples include:▫ Barrier guards ▫ Two-handed tripping guards▫ Electronic safety devices

Guarding• The point of operation of machines whose

operation exposes an employee to injury, shall be guarded.

• The following are some of the machines which usually require point of operation guarding:▫ Shears▫ Powered Presses▫ Power Saws▫ Jointers▫ Milling Machines▫ Portable Power Tools

Guarding

THANK YOU

Safety Environmental Engineering, Inc.38 N. Main Street

Keedysville, MD 21756 (301) 432-3949

[email protected]

This concludes the Continuing Education Program.

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osha’s top 10 citations & the american institute of ... · questions related to specific...

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