Tag: OSHA

OSHA Top 10 Cited Standards in 2024

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The Occupational Safety and Health Administration (OSHA) released its preliminary data for 2024, revealing the most frequently cited standards in the workplace. While some of these standards remain constant year over year, their relevance to protecting workers cannot be overstated. As OSHA’s Director of Enforcement Programs, Scott Ketcham, pointed out, these violations have led to preventable tragedies. It is vital that employers take these citations seriously and ensure compliance with the necessary safety protocols.

OSHA Top 10 Cited Standards

In this post, we’ll explore the top 10 most cited OSHA standards, along with the associated courses offered by Safety Made Simple to help your team stay compliant, reduce risks, and improve workplace safety.

1. Fall Protection – General Requirements (1926.501)

Total Violations: 6,307
Most Cited Section: 1926.501(b)(13) – Residential construction activities 6 feet or more above lower levels shall be protected by guardrail systems, safety net systems, or personal fall arrest systems.

Safety Made Simple Training Courses:
Fall Arrest and Restraint Protection
Fall Protection Introduction to Fall Arrest and Restraint
Railcar Fall Protection Training
Fall Protection Working at Heights

For the 14th consecutive year, Fall Protection remains the most frequently cited violation. Fall-related injuries are one of the leading causes of workplace fatalities. Our Fall Protection Training courses cover the necessary precautions and safety systems required to prevent falls and protect employees working at heights.

2. Hazard Communication (1910.1200)

Total Violations: 2,888
Most Cited Section: 1910.1200(e)(1) – Employers must develop, implement, and maintain a written hazard communication program.

Safety Made Simple Training Courses:
Hazard Communications Safety Data Sheets
Hazard Communication Labels and Pictograms

With chemicals present in nearly every industry, proper hazard communication is essential. These Hazard Communication courses help employers ensure that workers understand the chemicals they are working with and have access to the necessary Safety Data Sheets (SDS) and labels.

3. Ladders (1926.1053)

Total Violations: 2,573
Most Cited Section: 1926.1053(b)(1) – When portable ladders are used for access to an upper landing surface, the ladder must extend at least 3 feet above the upper landing surface.

Safety Made Simple Training Courses:
Three Point Rule Preventing Slips and Falls
Portable Ladders

Ladders are ubiquitous in construction and other industries, but improper use can lead to serious accidents. Our Ladder Safety courses provide essential training on safe ladder practices, including how to inspect and use ladders properly to avoid falls and injuries.

4. Respiratory Protection (1910.134)

Total Violations: 2,470
Most Cited Section: 1910.134(e)(1) – Employers must provide a medical evaluation to determine employees’ ability to use a respirator.

Safety Made Simple Training Courses:
Air Purifying Respirators
Particulate Respirators

Respiratory hazards are a common issue in industries like construction and manufacturing. Our Respiratory Protection courses cover the essentials of selecting, maintaining, and using respirators to ensure employees are properly protected from airborne contaminants.

5. Lockout/Tagout (1910.147)

Total Violations: 2,443
Most Cited Section: 1910.147(c)(4) – Energy control procedure must be established for servicing and maintenance.

Safety Made Simple Training Courses:
Lockout Tagout When in Doubt, Lock and Tag it Out
Lockout Tagout the Basics
Lockout Tagout Complex Procedures

Lockout/Tagout procedures are crucial to prevent machinery from being accidentally energized during maintenance. Our Lockout/Tagout Safety courses teach employees how to properly isolate hazardous energy and prevent accidents during service or repair.

6. Scaffolding (1926.451)

Total Violations: 1,873
Most Cited Section: 1926.451(g)(1) – Employees on scaffolds more than 10 feet above a lower level must be protected from falling.

Safety Made Simple Training Courses:
Scaffolding Safety

Scaffolding is a common and necessary tool in construction, but it poses risks if not properly assembled and used. Our Scaffolding Safety course covers safe practices for erecting, using, and inspecting scaffolding to ensure workers are protected at heights.

7. Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102)

Total Violations: 1,814
Most Cited Section: 1926.102(a)(1) – Employers must ensure that affected employees use appropriate eye or face protection.

Safety Made Simple Training Courses:
PPE Basics
PPE Eye and Face Protection
Food Safety PPE

Eye and face protection is essential when workers are exposed to flying particles, chemicals, or other hazards. Our Eye and Face Protection courses teach how to select, use, and maintain appropriate PPE to safeguard employees’ vision and facial safety.

8. Powered Industrial Trucks (1910.178)

Total Violations: 2,248
Most Cited Section: 1910.178(l)(1) – Employers must ensure the safe operation of powered industrial trucks.

Safety Made Simple Training Courses:
Forklift Safety
Rough Terrain Forklifts

Forklifts and powered industrial trucks are commonly used in material handling but can be dangerous if operators are not trained properly. Our Forklift Safety courses help ensure safe operation and compliance with OSHA standards.

9. Fall Protection – Training Requirements (1926.503)

Total Violations: 2,050
Most Cited Section: 1926.503(a)(1) – Employers must provide a training program for employees who might be exposed to fall hazards.

Safety Made Simple Training Courses:
Fall Arrest and Restraint Protection
Fall Protection Introduction to Fall Arrest and Restraint
Railcar Fall Protection Training
Fall Protection Working at Heights

Training is key to preventing falls. Our Fall Protection Training courses ensure that workers are fully equipped with the knowledge and skills to recognize fall hazards and use fall protection systems effectively.

10. Machine Guarding (1910.212)

Total Violations: 1,541
Most Cited Section: 1910.212(a)(1) – Machines must be properly guarded to protect operators and other employees from hazards.

Safety Made Simple Training Courses:
Machine Guarding

Machine guarding is essential to prevent injuries from rotating parts, ingoing nip points, and flying objects. Our Machine Guarding Safety course provides in-depth training on the importance of machine safeguards and how to implement them correctly.

The OSHA Top 10 list of cited violations underscores the ongoing challenges in workplace safety. By ensuring compliance with these standards and implementing thorough training programs, employers can significantly reduce workplace accidents and injuries. At Safety Made Simple, we provide online and in person training courses that cover these key areas and more, helping your team stay safe and compliant with OSHA regulations. Check out our courses today to ensure that your workplace remains a safe environment for everyone.

Hot Work – Don’t Play with Fire: Essential Safety Precautions

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In the grain handling industry, the phrase “hot work” can evoke a sense of anxiety among elevator managers, safety leaders, property insurers, and employees. Hot work, which includes activities like brazing, cutting, grinding, soldering, and welding, has been the cause of numerous fires and grain dust explosions. The heat generated from these activities can ignite combustible dust on surfaces and in suspension, resulting in smoldering fires, flash fires, and potentially catastrophic explosions. This post will explore the necessary precautions related to hot work, as required under OSHA Welding, Cutting, and Brazing Standard 1910.252 and OSHA Grain Handling Standard 1910.272.

Permit Authorization

OSHA’s Grain Handling Standard requires a hot work permit for all hot work performed within or near grain handling and storage areas. However, there are exceptions, such as when the employer or a representative is present during the hot work, or when the work takes place in welding shops or designated hot work areas outside the grain handling structures. Many companies opt to issue hot work permits for all work in or near grain handling areas as a best practice. It is essential to take a conservative approach to hot work in these environments.

A hot work permit includes details such as the work’s location, the nature of the task, and the name of the person performing the work. The permit requires the signature of an authorized person (e.g., a supervisor or fire safety officer), signifying that they have examined the area and confirmed all necessary precautions are in place before proceeding with the work.

Required Precautions

Hot work permits reflect the minimum safety precautions required under OSHA’s Welding, Cutting, and Brazing Standard 1910.252 (a) and are also referenced in the Grain Handling Standard. The precautions listed on the permit must be implemented before any hot work is allowed. These precautions are divided into several sections, including requirements for the area within 35 feet of hot work, equipment conditions, and fire watch considerations. Some of the common precautions include:

  • Ensuring that sprinklers and hose streams are operational.
  • Ensuring hot work equipment is in good condition (e.g., welding leads, torches).
  • Ensuring fire extinguishers, hoses, and other firefighting tools are operable.
  • Removing or covering combustible materials, including grain dust and oily deposits.
  • Ensuring that explosive atmospheres are eliminated.
  • Covering floors and walls with fire blankets or damp sand.
  • Protecting ducts, conveyors, bucket elevators, and other equipment that may carry sparks to distant combustible materials.

These precautions must be clearly marked on the permit, and the responsible person must confirm their implementation.

Fire Watch Requirements

OSHA’s standards for fire watch specify that fire watchers must be present whenever hot work is performed in locations where fires could develop. Specifically, a fire watch is required when:

  • Combustible materials are within 35 feet of the work area.
  • Combustible materials are more than 35 feet away but can easily be ignited by sparks.
  • There are floor or wall openings within 35 feet that could expose combustible material to sparks.
  • Combustible materials are adjacent to metal partitions, walls, or ceilings, where conduction or radiation could cause ignition.

Many companies go beyond the OSHA minimum and require a fire watch whenever hot work is conducted. Fire watch personnel must be trained in using fire-extinguishing equipment and know how to initiate evacuation procedures if necessary. OSHA mandates that fire watch be maintained during and for at least 30 minutes after the completion of the hot work to detect and extinguish potential smoldering fires. However, many grain handling facilities and insurance providers recommend extending the fire watch period to monitor for up to several hours after the work is completed, as grain dust can smolder for a long time after the visible heat has dissipated.

Hot work poses significant fire hazards in grain handling facilities. While OSHA standards set the minimum requirements, these guidelines should not be seen as a ceiling. Given the extreme risks associated with grain dust, it’s vital to adopt a conservative and proactive approach. Going above and beyond the minimum requirements is essential to protect employees, contractors, and the facility. Remember: don’t play with fire—take the necessary precautions, issue hot work permits, ensure proper fire watch, and continuously monitor for hazards.

OSHA Inspections “The Playbook”

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If you are concerned about an inspection from the Occupational Safety and Health Administration (OSHA), there is good news.  OSHA Instruction CPL 02-01-004 is OSHA’s playbook when it comes to inspecting grain handling facilities.  This article will focus on several critical areas that will likely be included in the inspection process as well as “best practice” recommendations for compliance. 

Background

The standard for grain handling facilities, 29 CFR 1910.272 was promulgated on December 31st, 1987, and became effective March 30th, 1988.  Although the final rule applies to all grain handling facilities, it is not a true “vertical” standard since it is not intended to address all hazards found in these types of work environments. Therefore, be advised that other standards contained in 29 CFR Part 1910 for general industry and 29 CFR Part 1917 for marine terminals continue to apply to grain handling facilities.  29 CFR 1910.272, however, does take precedence inside grain handling facilities over other provisions in 29 CFR 1910 and 29 CFR 1917 for the specific hazards the grain standard addresses. 

Emergency Action Plans

29 CFR 1910.272 requires that an emergency action plan be in writing except for employers with 10 or less employees.  Employers with 10 or less employees will still have to comply with the 29 CFR 1910.38 (Emergency Action Plans) requirements and be able to substantiate that the plan is being communicated orally in an effective manner. All employees, including truck drivers, sales and office personnel, seasonal employees, and part-time employees must be included in determining the total number of employees at the workplace.  It is a recommended “best practice” that grain handlers develop a written emergency plan, regardless of the number of employees and train all employees routinely on the procedures within the plan. 

Training

In addition to the applicable training requirements outlined in 29 CFR 1910 General Industry, such as hazard communication, walking/working surfaces, lockout tagout etc., employees are required to be trained in the recognition and prevention of hazards associated with grain handling facilities, especially those hazards associated with their own work tasks.  Certified Health and Safety Officials (CSHOs) will verify that employees are trained in all aspects of their job tasks including bin entry and not to introduce ignition sources through the use of electric tools, welding, cutting, use of open flames or smoking in hazardous areas.  The standard does not require that training records be kept, however this is a recommended “best practice”.  The CSHO will substantiate training adequacy by reviewing the employer’s training records, if offered by the employee, or by interviewing a sample of employees.

Hot Work Permits

The standard does require that the employer issue a permit for hot work except where the employer’s representative, who would otherwise authorize the permit, is present while the hot work is being performed.  Welding shops authorized by the employer and hot work areas authorized by the employer outside of the grain handling structure are excluded from the requirements.  If a permit process is implemented, it must certify that the requirements contained in CFR 1910.252 Welding Cutting and Brazing are implemented and being followed.  If the employer elects to have a representative present instead of a permit, the employer must still follow the same requirements as if a permit were issued under CFR 1910.252.  It is a recommended “best practice” that a permit is issued each time hot work is performed in required areas.  While there is no requirement for permit retention, permits should be kept on file for a period of time that can demonstrate compliance with the standards.

Bin Entry Permits

A written bin entry permit is not required if the employer or representative who would otherwise be authorized to issue the entry permit, is present during the entire entry.  All other precautions contained within 1910.272 (g) must still be followed.  It is a recommended “best practice” that a permit process be implemented for entry into grain storage structures regardless of whether the employer or representative is present during the entire entry.  While there is not a requirement for permit retention, it is also recommended that permit documentation be kept on file for at least one year. 

The CSHO may also ask the employer to verify procedures to ensure that atmospheric testing equipment used to determine hazardous atmospheres including fumigants, oxygen deficiency, etc. are properly calibrated and maintained.  While there are no specific requirements within the standard for documenting calibration, it is a recommended “best practice” that calibration activities are documented.

Contractors

The standard requires the employer to provide specific instruction to contractors on the safety rules of the facility, including applicable provisions of the emergency action plan.  Simply providing a copy of the safety program would not ensure that the contractor has received sufficient information to take adequate precautions to prevent exposure to hazards.  It is a recommended “best practice” that employers meet with contractor employees prior to working at the facility to communicate and review safety requirements and potential hazards at the facility.  It is also a recommended “best practice” to document the subject matter discussed during the meeting, persons in attendance, hazards, and facility safety requirements discussed. 

Housekeeping

The standard requires that the employer develop and implement a written housekeeping program that establishes the frequency and methods determined to best reduce accumulations of fugitive grain dust on ledges, floors, equipment, and other exposed surfaces.  The program must also address fugitive dust accumulations in priority areas. The use of compressed air to blow dust from ledges, walls, and other areas shall only be permitted when all machinery that presents an ignition source in the area is shut down, and all other known potential ignition sources in the area are removed or controlled.  While not required, the use of a compressed air cleaning or blowdown permit is a recommended “best practice “to ensure and demonstrate compliance with the standard.

Preventive Maintenance

The standard requires regularly scheduled inspections of “at least” the mechanical and safety control equipment associated with dryers, grain stream processing equipment, dust collection equipment, and bucket elevators.  A certification record must be maintained for each inspection containing the date of inspection, name of the person who performed the inspection and the serial number, or other identifier of the equipment.  The standard does not require a specific frequency for preventive maintenance.   The CSHO will analyze the program based on the time period.  The program must be adequate for “peak” periods, such as harvest. 

This article outlined several of the critical requirements and best practices for maintaining compliance with OSHA 1910.272 Grain Handling.  Please remember that other general industry and maritime requirements contained in parts 1910 and 1917 will apply to grain handling facilities.  Please visit www.osha.gov for more information on OSHA’s playbook (CPL 02-01-004).

OSHA Compliance Inspections

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Our subject matter expert, Joe Mlynek, drafted this article for Grain Journal Magazine in the Summer of 2023.

A grain handling company recently asked me to perform a mock OSHA inspections at their facilities. The company had a policy and checklist for managing OSHA inspections but had never practiced or prepared in a simulated manner.

OSHA focuses their inspection resources on the most hazardous workplaces. There are six categories of inspections including:

1. Imminent danger situations which include hazards that could cause death or serious physical harm.

2. Severe Injuries and illnesses from workplaces that have reported a work-related fatality, inpatient hospitalization, amputation, or losses of an eye.

3. Worker complaints or allegations of hazards by employees.

4. Referrals from other federal, state, or local agencies, individuals, organizations, or the media.

5. Targeted Inspections of high hazard industries or individual workplaces that have experienced high rates of injuries or illnesses.

6. Follow-Up Inspections to verify abatement of violations cited during previous inspections.

For the purpose of the mock inspections, we simulated targeted inspections based on the local emphasis program (LEP) for grain handling facilities. LEP enforcement strategies are intended to address hazards or industries that pose a particular risk to workers.

Upon arriving at each facility, we discussed the importance of verifying the inspector’s credentials. During the opening conference I played the role of an OSHA compliance officer and indicated that the LEP targeted inspection would focus on the grain handling areas of the facility. I also requested the company provide documentation including OSHA 300 logs for the past five years, the written hazard communication program to include a safety data sheet for grain dust/whole grains, their lockout tagout program, a copy of their certification of hazard analysis for personal protective equipment, and items from OSHA instruction CPL 02-01-004 inspection of grain handling facilities. This directive instructs compliance officers to focus their attention on items including emergency action plans, training documentation, hot work permits, bin entry permits, provisions for contractors, the written housekeeping program, and preventive maintenance inspections.

Emergency action plans must be in writing except for employers with 10 or less employees. Employers with 10 or less employees will still have to comply with the 29 CFR 1910.38 (Emergency Action Plans) requirements and be able to substantiate that the plan is being communicated orally in an effective manner.

In addition to the applicable training requirements outlined in OSHA’s General Industry standards, OSHA 1910.272 also requires that employees be trained in the recognition and prevention of hazards associated with grain handling facilities, especially those hazards associated with their own work tasks. Employees must be trained in all aspects of their job tasks including bin entry and not to introduce ignition sources through the use of electric tools, welding, cutting, use of open flames, or smoking in hazardous areas. In addition, OSHA requires grain handling facilities to provide specific instruction to contractors on the safety rules of the facility, including applicable provisions of the emergency action plan.

OSHA 1910.272 also requires the employer to issue a permit for hot work except where the employer’s representative, who would otherwise authorize the permit, is present while the hot work is being performed. Welding shops authorized by the employer and hot work areas authorized by the employer outside of the grain handling structure are excluded from the requirements. If a permit process is implemented, it must certify that the requirements contained in CFR 1910.252 Welding Cutting and Brazing are implemented and followed. If the employer elects to have a representative present instead of a permit, the employer must still follow the same requirements as if a permit were issued under CFR 1910.252. 

Grain handling facilities must issue a permit for entering bins, silos, or tanks unless the employer or the employer’s representative (who would otherwise authorize the permit) is present during the entire operation. The permit must only be kept on file until completion of the entry operations.

OSHA 1910.272 requires that the employer develop and implement a written housekeeping program that establishes the frequency and methods determined to best reduce accumulations of fugitive grain dust on ledges, floors, equipment, and other exposed surfaces. The program must also address fugitive dust accumulations in priority areas.

The Grain Handling Standard requires regularly scheduled inspections of “at least” the mechanical and safety control equipment associated with dryers, grain stream processing equipment, dust collection equipment, and bucket elevators. A certification record must be maintained for each inspection containing the date of inspection, name of the person who performed the inspection and the serial number, or other identifier of the equipment.

Upon completion of the opening conference, I conducted a walk around inspection. The inspection focused on items including combustible dust housekeeping in priority areas, walking and working surfaces, hazard monitoring equipment required by the grain handling standard, machine guarding, and electrical hazards. The two company escorts were in my hip pocket the entire time. They kept detailed notes of everything I focused on and discussed during the inspection. They also took pictures of everything I took pictures of. They did a respectable job of not volunteering any information, while asking questions on items I commented on or wrote down. I could tell that they had been trained in their company’s inspection protocols.

Upon conclusion of the inspection, a closing conference was held. The management representatives did an impressive job of asking questions regarding potential violations. Noting the potential violations helps ensure that there will be no disputes at a later conference or hearing. It also allows the company time to address abatement of potential citations.

Consider performing random mock OSHA inspections at your grain handling facilities(s). Use the information covered in this article as a guide. I think you will find that they are a positive learning opportunity and good practice for the real thing. As they say, practice makes perfect, but only if you practice perfectly.