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2018 BISC Summer Meeting 2018 BISC Summer Meeting

2018 BISC Summer Meeting - PowerPoint Presentation

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2018 BISC Summer Meeting - PPT Presentation

Top 10 OSHA Violations Agenda What to expect when OSHA shows up What your options are if you receive OSHA citations OSHAs 2017 top 10 most frequently cited violations What to Expect When OSHA Shows Up ID: 711290

osha 1910 top 1926 1910 osha 1926 top employer violations hazards protection employees cited fall standard equipment machine ladders www gov https

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Slide1

2018 BISC Summer Meeting

Top 10 OSHA Violations Slide2

Agenda

What to expect when OSHA shows

up

What

your options are if you receive OSHA

citations

OSHA’s

2017 top 10 most frequently

cited

violationsSlide3

What to Expect When OSHA Shows UpSlide4

The Inspection Selection

Generally, priority of accomplishment and assigning

Certified Safety and Health Official (CSHO)

resources for inspection are categorized below:

Priority

Category

First

Imminent Danger

Second

Fatality/Catastrophe

Third

Complaints/Referrals

Fourth

Programmed InspectionsSlide5

Opening Conference

Compliance officers are required to begin inspection with

an “opening

conference,” to present credentials and explain the inspection procedure

.

Recommendations-

Restrict admittance until appropriate Management is on site

Determine the reason for the inspection

Limit the scope of the inspectionSlide6

Walk-Around Inspection

Purpose

T

he

compliance officer

will

walk through the portions of the workplace covered by the inspection, inspecting for hazards that could lead to employee injury or illness

.

Recommendations

Stay with inspector throughout the walk-around

Take

notes on all observations the inspector

makes

Departments

or equipment

inspected

Time

spent in various

areas

Individuals

who were interviewed

If OSHA requests a copy of a record or document, make copies to keep with your OSHA inspection file

Correct or repair any small violations immediately Slide7

Closing Conference

Inspectors are required to conduct a “closing conference” within a few weeks.

Use the closing conference to explain your company’s commitment to safety and established safety program

Factored into establishing penalty amounts

Be conservative when establishing timelines for correcting alleged violations if askedSlide8

OSHA Citations

Key Points

OSHA has 6 months from the date of first notice of the alleged violation to issue a citation.

When you receive an OSHA Notice, you must post it (or a copy of it) at or near the place where each violation occurred to make employees aware of the hazards to which they may be exposed. The OSHA Notice must remain posted for 3 working days or until the hazard is abated, whichever is longer.

Citation Types & Maximum Penalties

Other-Than-Serious:

$

12,934 per

violation

Serious:

$

12,934 per

violation

Posting Requirements:

$

12,934 per

violation

Failure to Abate:

$12,471 per day beyond the abatement

date

Willful:

$129,336 per

violation

Repeated:

$129,336 per violationSlide9

Options if You Receive OSHA CitationsSlide10

Informal Conference

Within 15 working days of receipt of an OSHA citation, you may request an informal conference in order to:

Obtain a better

explanation

of the cited violations

Obtain a more complete understanding of the specific standards that apply

Discuss

ways

to correct violations

Discuss concerns with the abatement dates

Discuss concerns

with employee safety

practices

Negotiate and enter into an informal settlement agreementSlide11

Employer Options

As an employer who has been cited, you may chose one of the following options with or without a prior held informal conference:

Agree to the citation and Notification of Penalty

Correct

the condition by the date set in the citation

Pay the penalty if one is

proposed

Disagree with the citation and Notice of Penalty

Contest

in writing (Notice of Intent to Contest) within 15 working days from the

date a citation is received to

any or all of the following:

Citation

Proposed penalty

Abatement date.Slide12

OSHA's 2017 Top 10 Most Frequently Cited ViolationsSlide13

Violation Types

2017 Top 10 Citations

(Federal

OSHA)

1. Fall Protection

6. Ladders

2. Hazard Communication

7.

Powered Industrial Trucks

3. Scaffolding

8. Machinery

and Machine Guarding

4. Respiratory Protection

9.

Fall Protection – Training Requirements

5. Control of

Hazardous Energy (LOTO)

10. Electrical, Wiring

Methods, Components and Equipment

Source: OSHASlide14

#1 Fall Protection

Falls are among the most common causes of serious work related injuries and deaths. Employers must set up the work place to prevent employees from falling off of overhead platforms, elevated work stations or into holes in the floor and walls

.

Standard:

1926.501

Total

Violations:

7,281

Top 5 Sections Cited

1.

1926.501(b)(13):

"Residential construction"

2.

1926.501(b)(1)

:

"Unprotected sides and edges"

3.

1926.501(b)(10)

:

"Roofing work on Low-slope roofs"

4.

1926.501(b)(11)

:

"Roofing work on Steep roofs"

5.

1926.501(b)(4)(i)

:

“Each employee on walking/working surfaces shall be protected from falling”Slide15

Fall Protection

Employer

Responsibilities

Keep floors in work areas in a clean and, so far as possible, a dry condition.

Guard every floor hole into which a worker can accidentally walk.

Provide a guard rail and toe-board around every elevated open sided platform, floor or runway.

Regardless of height, if a worker can fall into or onto dangerous machines or equipment, employers must provide guardrails and toe-boards to prevent workers from falling and getting injured.Slide16

#2 Hazard Communication

In order to ensure chemical safety in the workplace, information about the identities and hazards of the chemicals must be available and understandable to

workers.

Standard

:

1910.1200

Total

Violations:

4,877

Top 5 Sections Cited

1.

1910.1200(

e

)(1)

:

“Written program”

2.

1910.1200(h)(1)

:

“Training on chemicals being used”

3.

1910.1200(g)(8)

:

“Maintain SDS"

4.

1910.1200(g)(

1

)

:

" Chemical manufactures & importers shall obtain or develop SDS."

5.

1910.1200(h)(3)(iv)

:

“Training on programs, labels, SDS and other information”Slide17

Hazard Communication

Employer Responsibilities

All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers.

Obtain and update SDS log as new chemicals are

introduced.

No

longer MSDS

Employees must be trained on

specific chemicals

they will be using.

All containers must be properly labeled in accordance with the GHS standard.Slide18

# 3 Scaffolding

The OSHA standard sets performance-based criteria to protect employees from scaffold-related hazards such as falls, falling objects, structural instability, electrocution, or overloading.

Standard

:

1926.451

Total

Violations:

3,776

Top 5 Sections Cited

1.

1926.451(

g

)(1)

:

“Employees more than 10 feet shall be protected from falling”

2.

1926.451(

e

)(1)

:

“Cross braces shall not be used as a means of access”

3.

1926.451(b)(1)

:

“All working levels of scaffolds shall be fully planked or decked"

4.

1926.451(g)(1)(vii)

:

"Use of personal fall arrest systems or guardrail systems"

5.

1926.451(c)(2)

:

“Supported scaffold poles shall bear on adequate firm foundation”Slide19

Scaffolding

Employer Responsibilities

Scaffolds cannot be erected, dismantled, moved or altered unless approved by a competent person.

Scaffolding must be inspected prior to use.Slide20

# 4 Respiratory Protection

Respirators protect workers against insufficient oxygen environments, harmful dusts, fogs, smokes, mists, gases, vapors, and sprays

.

Standard

:

1910.134

Total

Violations:

3,339

Top 5 Sections Cited

1.

1910.134(e)(1)

:

“Medical evaluation prior to use”

2. 1910.134(c)(1):

“Establish a written respiratory protection program”

3.

1910.134(f)(2)

:

“Fit testing”

4.

1910.134(c)(2)(i)

:

"Voluntary use of a respirator - Appendix D"

5.

1910.134(d)(1)(ii)

:

“The employer shall select a NIOSH-certified respirator”Slide21

Respiratory Protection

Employer Responsibilities

Use engineering controls where feasible to control the atmospheric hazard.

Provide an appropriate respirator. (Air monitoring may be needed)

Ensure the use of an appropriate respirator.

Institute a respiratory protection program that complies with the rest of the standard.

Ensure employees that voluntarily use a tight fitting respirator or dust mask have been provided information in Appendix D.Slide22

# 5 Control of Hazardous Energy (LOTO)

Workers servicing or maintaining machines or equipment may be seriously injured or killed if hazardous energy is not properly controlled. Injuries resulting from

failure

to control hazardous energy during maintenance activities can be serious or fatal. Injuries may include electrocution, burns, crushing, cutting, lacerating, amputating, or fracturing body parts, and others

.

Standard:

1910.147

Total Violations:

3,036

Top 5 Sections Cited

1.

1910.147(c)(4)(i)

:

“Machine specific procedures”

2.

1910.147(c)(6)(i):

“Periodic inspection of the energy control procedure at least annually”

3.

1910.147(c)(1)

:

“Energy control program”

4.

1910.147(c)(7)(i)

:

"Training requirements"

5.

1910.147(d)

:

“Notification of removal”Slide23

Lock Out Tag Out (LOTO)

Employer Responsibilities

Develop, implement, and enforce an energy control program.

Ensure that electrical boxes are labeled with which machines they correspond to.

Create and update machine specific LOTO procedures as necessary.

Provide effective training as mandated for all employees covered by the standard.

Comply with additional energy control provisions in the OSHA standards.Slide24

# 6 Ladders

Falls are the leading cause of death in construction and every year falls from ladders make up nearly a third of those deaths. These deaths are preventable. Falls from ladders can be prevented and lives can be saved by following the safe work

practices.

Standard:

1926.1053

Total Violations:

2,799

Top 5 Sections Cited

1.

1926.1053(b)(1):

“Portable ladder side rails shall extend at least 3 feet above the upper landing”

2.

1926.1053(b)(4):

“Ladders shall be used only for the purpose for which they were designed”

3. 1926.1053(b)(13):

“The top or top step of a stepladder shall not be used as a step”

4. 1926.1053(b)(16):

"Defective ladders"

5.

1926.1053(b)(6):

“Ladders shall be used only on stable and level surfaces unless secured”

Top 5 Sections (General Industry)

1. 1910.23(b)(8):

Used only for the purposes for which they were designed

2. 1910.23(b)(9)

:

Ladders are inspected before initial use in each work shift, and more frequently as necessary

3. 1910.23(b)(10):

Structural or other defects is immediately removed from service

4. 1910.23(c)(4):

Used only on stable and level surfaces unless they are secured

5. 1910.23(c)(8):

The cap and top step of a stepladder are not used as stepsSlide25

Ladders

Employer

Responsibilities

Maintain and store the ladder according to the manufacturer’s instructions.

Ladders should be thoroughly inspected prior to use.

All damaged/unusable ladders must be marked “Do Not Use” or be disposed of.

Employers must train all employees to recognize hazards related to ladders and stairways, and instruct them to minimize these hazards.Slide26

# 7 Powered Industrial Trucks

Powered industrial trucks, commonly called forklifts or lift trucks, are used in many industries, primarily to move materials. They can also be used to raise, lower, or remove large objects or a number of smaller objects on pallets or in boxes, crates, or other containers. Powered industrial trucks can either be ridden by the operator or controlled by a walking

operator.

Standard

:

1910.178

Total

Violations:

2,434

Top 5 Sections Cited

1.

1910.178(l)(1)(i):

“Ensure that each powered industrial truck operator is competent”

2.

1910.178(l)(4)(iii):

“An evaluation shall be conducted at least once every three years”

3. 1910.178(p)(1):

“If a defect is found, the truck shall be taken out of service until it has been restored”

4. 1910.178(l)(6):

"Certification"

5.

1910.178(q)(7):

“Pre-use inspections”Slide27

Powered Industrial Trucks

Employer Responsibilities

It is a violation of Federal law for anyone UNDER 18 years of age to operate a forklift or for anyone OVER 18 years of age who is not properly trained and certified to do so.

Operators must complete a documented pre-shift/use inspection.

All operators must be certified to operate each type of powered industrial truck they will use.

All certified forklift operators must be evaluated at least every 3 years.

Modifications or additions that affect capacity or safe operation shall not be performed without prior written approval from the forklift truck manufacturer. Capacity, operation, and maintenance instruction plates, tags, or decals shall be changed accordingly.Slide28

#8 Machinery and Machine Guarding

The purpose of machine guarding is to protect the machine operator and other employees in the work area from hazards created by ingoing nip points, rotating parts, flying chips and sparks. Some examples of this are barrier guards, light curtains, two-hand operating devices, etc.

Standard:

1910.212

Total Violations:

2,115

Top 5 Sections Cited

1.

1910.212(a)(1):

“One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards”

2.

1910.212(a)(3)(ii):

“Point of operation guard”

3. 1910.212(b):

“Machines designed for a fixed location shall be securely anchored”

4. 1910.212(a)(2):

“General requirements"

5.

1910.212(a)(5):

“Exposure of blades. The guard shall have openings no larger than one-half (1/2) inch”Slide29

Machinery

and Machine Guarding

Employer Responsibilities

Any machine part, function, or process that may cause injury must be safeguarded. When the operation of a machine or accidental contact can injure the operator or others in the vicinity, the hazards must be eliminated or controlled.

Guards must not create potential hazards and must be attached to the machine where possible.

If guards cannot be attached to the machine, attach elsewhere.Slide30

#9 Fall Protection – Training Requirements

The employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards.

Standard

:

1926.503

Total

Violations:

1,891

Top 5 Sections Cited

1.

1926.503(a)(1)

:

“Training”

2. 1926.503(b)(1):

“Training

Records

3.

1926.503(

a

)(

2

)

:

The employer shall assure that each employee has been trained, as necessary, by a competent person

4.

1926.50

3

(c)(3)

:

“Employee Knowledge"

5.

1926.50

3

(a)(2)(ii)

“Failure

to use fall protection”

Top Sections (General Industry)

1.

1910.30(a)(1)

:

Before any employee is exposed to a fall hazard, the employer must provide training for each employee

2. 1910.30(a)(2)

:

The employer must ensure that each employee is trained by a qualified person.

3. 1910.30(a)(3):

The employer must train each employee in at least the following topics:

Nature of the fall hazards in the work area

Procedures to be followed to minimize those hazards

Procedures for using personal fall protection systems

Correct use of personal fall protection systemsSlide31

Fall Protection – Training Requirements

Employer Responsibilities

PLAN ahead to get the job done safely.

PROVIDE the right equipment.

TRAIN everyone to use the equipment safely.

Three simple steps to preventing falls.Slide32

# 10 Electrical, Wiring Methods, Components & Equipment

Electricity has long been recognized as a serious workplace hazard. OSHA's electrical standards are designed to protect employees exposed to dangers such as electric shock, electrocution, fires, and explosions

.

Standard

:

1910.305

Total Violations:

1.564

Top 5 Sections Cited

1.

19

10.305

(g)(1)(iv)(A):

“Substitute

for fix wiring”

2.

1910.305(g)(2)(ii):

“Strain relief”

3. 1910.305(b)(1)(ii):

“Openings not closed”

4. 1910.305(b)(2)(

i

):

“Covers and canopies”

5.

1910.305(b)(1)(

i

):

“Protection from cuts when entering boxes”Slide33

Electrical, Wiring Methods, Components & Equipment

Employer Responsibilities

Educating employees on potential electrical hazard risks such as: contact with power lines, lack of ground-fault protection, equipment not used in matter prescribed, and improper use of extension and flexible cords.

Visually inspect all electrical equipment before use. Remove from service any equipment with frayed cords, missing ground prongs, cracked tool casings, etc. Apply a warning tag to any defective tool and do not use it until the problem has been corrected.

Use double-insulated tools and equipment, distinctively marked.

Use tools and equipment according to the instructions included in their listing, labeling or certification.Slide34

References

https://www.osha.gov/dte/grant_materials/fy10/sh-20853-10/osha_inspections.pdf

https://www.osha.gov/Top_Ten_Standards.html

https://www.osha.gov/SLTC/fallprotection/index.html

https://www.osha.gov/dsg/hazcom/index.html

https://www.bnl.gov/esh/shsd/pdf/scaffolds_c.pdf

https://www.osha.gov/SLTC/etools/respiratory/index.html

https://www.osha.gov/OshDoc/data_General_Facts/factsheet-lockout-tagout.pdf

https://www.osha.gov/Publications/OSHA3625.pdf

https://www.osha.gov/Publications/ladders/osha3124.html

https://www.osha.gov/pls/imis/industryprofile.html?p_msg=Please%20enter%20an%208-character%20Standard%20number%20or%20ALL%20to%20continue

.

https://www.osha.gov/SLTC/machineguarding/index.html

http://www.ehstoday.com/safety/ehs_imp_78870

https://www.osha.gov/SLTC/fallprotection/Slide35

Final Thoughts – What to do now?

Create a hazard assessment for each job task and take appropriate measures to eliminate the hazard using engineering or work practice controls, or, when not feasible, protect your employees from the known hazard through use of PPE.

Train your employees on hazards identified and other required OSHA topics.

Be prepared for OSHA to show up and know your rights when they do.

If you receive citation(s), be sure to abate the found safety hazard ASAP.

Remember to request an informal conference within 15 days of receiving citationsSlide36

Questions?

For additional questions or help

with your insurance program:

Contact:

Michelle Wiltgen

AVP & National Marketing Manager

Office: 800-929-1500 x1213

Cell: 440-821-1961

Email: michelle.wiltgen@natl.com