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Top 10 OSHA Violations and 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.

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Presentation Transcript
agenda
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

Violation Penalty Structure
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)

Fines and Penalties
most cited item 1
Most Cited Item #1
  • Machine Guarding Issues
    • 29 CFR 1910.212, 215, & 219
    • General Machine Guarding Violations
    • Point of Operation
    • Grinders – Tongue Guards
    • Exposed Pulleys
    • 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

Machine Guarding
most cited item 2
Most Cited Item #2
  • Hazard Communication
    • 29 CFR 1910.1200
    • Hazard Communication Written Program
    • Information and Training
    • Training for New Hazards
    • Missing Material Safety Data Sheets
    • Missing / Incorrect Labels
hazard communication
Key Issues

Written Hazard Communication Program

Sharing Chemical Safety Information with Employees

Accurate Inventories

MSDS Available

Training

Labeling

Action Plan

Develop a Site Specific Program

Inventory All Chemicals

Collect MSDS for All Identified Chemicals

Train Employees on Chemicals and Hazards

Ensure Correct Labeling and Storage

Hazard Communication
most cited item 3
Most Cited Item #3
  • Lockout Tagout
    • 29 CFR 1910.147
    • Lockout Tagout Written Program
    • Lockout Tagout Machine Specific Procedures
    • Training
    • Periodic Inspections
    • 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 Plan

Develop a Site Specific Program

Develop a Specific Procedure for Each Machine or Process

Train Employees

Provide Appropriate Locks, Tags, Etc.

Frequent Program Audits (Routine and Non-Routine Tasks)

Lockout Tagout
most cited 4
Most Cited #4
  • Electrical Safety
    • 29 CFR 1910.303, 304, & 305
    • Conductor Protection from Abrasion
    • Exposed Live Parts
    • Inadequate Grounding
    • Missing Electrical Box Covers
    • 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 Plan

Examine Electrical Equipment at the Site

Identify All Potential Exposures to Live Parts

Repair or Replace Damaged Equipment As Soon as Identified

Train Employees on Basic Safe Practices

Electrical Safety
most cited 5
Most Cited #5
  • Personal Protection
    • 29 CFR 1910.132, 133, & 134
    • Eye and Face Protection
    • General PPE
    • Hazard Assessments
    • Written Respiratory Protection Program
    • 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

Personal Protection
most cited 6
Most Cited #6
  • First Aid and Fire Protection
    • 29 CFR 1910.151 & 157
    • Eye and Body Flushing Facilities
    • Fire Extinguisher Training
    • Presence and Accessibility of Fire Extinguishers
    • Fire Extinguisher Maintenance
    • 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

First Aid and Fire Protection
most cited 7
Most Cited #7
  • Walking and Working Surfaces
    • 29 CFR 1910.22, 23, &24
    • Open Sided Floors and Platforms
    • General Housekeeping
    • Wet Floors
    • Stair and Platform Railings
    • Floor Holes
walking working surfaces
Key Issues

Protect Employees from Falls Off Edges

Prevent Slips, Trips, and Falls

Action Plan

Examine Walking and Working Surfaces at the Site

Correct Any Potential Hazards Identified

Conduct Regular Housekeeping Inspections and Correct Deficiencies

Walking / Working Surfaces
most cited 8
Most Cited #8
  • Industrial Trucks
    • 29 CFR 1910.176 & 178
    • Operator Competency and Training
    • Truck Operating Condition
    • Secured Storage
industrial trucks
Key Issues

Operator Training and Certification

Forklift Operating Conditions and Safety Equipment

Handling Large, Heavy, and Awkward Loads

Action Plan

Identify 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

Industrial Trucks
most cited 9
Most Cited #9
  • Means of Egress
    • 29 CFR 1910.36, 37, & 38
    • Obstructed Exit Pathways
    • Exit Pathways not Clearly Marked
    • Exit Pathways not Marked
    • Emergency Action Plans
    • 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 Plan

Develop a Comprehensive Emergency Response Plan with Identified Exit Pathways

Train Employees

Practice (Have a Drill Periodically)

Examine Exit Pathways and Conditions Regularly

Means of Egress
most cited 10
Most Cited #10
  • Hazardous Materials
    • 29 CFR 1910.101, 106, & 107
    • Compressed Gas Handling, Storage, and Use
    • Flammable Liquids Dispensing
    • Spray Booth Ventilation
    • Spray Areas – Electrical Wiring
    • 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 Plan

Identify Areas Where Specialty Chemicals are Being Used

Examine Specific OSHA Requirements

Train Employees

Conduct Routine Housekeeping Inspections

Hazardous Materials
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

Other Standards to Evaluate
questions

Questions?

Thanks for Coming!