The great British statesman Winston Churchill once said, “When the situation was manageable it was neglected, and now that it is thoroughly out of hand we apply too late the remedies which then might have effected a cure. Want of foresight, unwillingness to act when action would be simple and effective, lack of clear thinking, confusion of counsel until the emergency comes, until self-preservation strikes its jarring gong–these are the features which constitute the endless repetition of history.” While he was not referring to OSHA standards violations, the wisdom of learning from others’ past mistakes could certainly be applied to the citations issued each year from OSHA.

OSHA publishes the Most Frequently Cited Standards each year to inform the public of the most violated standards from the previous fiscal year (FY) (October 1^st to September 30^th). This data shows the most frequently cited standards from General Industry, Construction, and Maritime regulations as well as a combined chart showing the largest numbers of citations across all industries.

In FY 2020, and as for many previous years, the lack of fall protection in residential construction tops the list with 5,424 serious violations. Hazard Communication had the second largest total with 3,199 violations followed closely by Respiratory Protection violations with 2,649 issued citations. Just these top three citations account for more than 46% of the total citations issued.

Some other interesting points within the Top Ten Citations are:

• Five out of the top ten (50%) citations were violations of Construction Standards (29 CFR 1926).
• 53% of the total Construction violations were fall protection related.
• 100% of the FY 2020 Top Ten were also in the Top Ten list for FY 2019.

When we analyze General Industry violations during this same period, we see that Hazard Communication has claimed the top spot with 1,053 serious violations, followed by Machine Guarding – Type of Guarding Methods, with 849 citations.

Additionally, regarding General Industry violations:

• 29% of the top five violations in General Industry were related to Hazard Communication.
• 44% of the total number of citations were related to Hazard Communication.
• There were 2,649 violations (more than 10% of the total violations) that were related to respirators and respiratory protection. Respiratory protection violations also represent the largest movement in the Top Ten by moving from #5 in FY 2019 to #3 in FY 2020.

For those of you that analyze the OSHA citation data each year, it will not surprise you to hear that the same violations show up nearly every year in the top ten within their respective industries. I cannot help but hear those words of Winston Churchill ringing in my head whenever these statistics are updated.

One only has to look at the data to see that the message is not reaching many employers. OSHA also issued 152 “Willful” Fall Protection violations in FY 2020 which accounts for 50% of the total “Willful” violations. These citations alone should send chills down anyone’s spine, but we cannot even calculate the true number of times that employees were working at heights without adequate fall protection.

With this in mind, OSHA has announced that the eighth annual National Stand-Down to Prevent Falls in Construction is scheduled for May 3-7, 2021. According to OSHA.gov, “A Safety Stand-Down is a voluntary event for employers to talk directly to employees about safety. Any workplace can hold a stand-down by taking a break to focus on 'Fall Hazards' and reinforcing the importance of 'Fall Prevention'.” Their site offers many resources to assist employers including fact sheets, posters, fall protection training materials in English and Spanish, and links to other safety related sites such as those from ASSP, NIOSH, and others.

My advice to all managers and supervisors alike is to take an honest look at the Top Ten violations and ask yourself, “Are we controlling these hazards to be best of our ability?” If the answer does not come easily or the answer is, “No,” it is time to determine what the organization can do to better protect their greatest assets, their employees.

Not sure how to get started? The upcoming National Stand-Down is a great opportunity to spread the word with your employees. If fall protection is not your major hazard or you want further information on other safety topics, check out our policyholder resources at MEMIC.com, sign up to receive the Safety Net Blog email each week, and subscribe to the MEMIC Safety Experts Podcast.

Posted ByStephen Badger, CSP, OHST, WCP®