OSHA Top Ten Citations 2019 (predictions)

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As the year is rapidly coming to an end, OSHA, Cal/OSHA will be preparing their list of the Top Citations issued.  Once the stats are published, most of the various industry “safety” sources will publish these lists.  Prior to these reports being released, I’d like to share my predictions for the “Top 10” violative conditions cited for 2019.

 (Fed OSHA)

  • Fall protection
  • Machine guarding.
  • Respiratory protection.
  • Control of Hazardous Energy (Lock-out/Tag-out).
  •      Powered industrial trucks (Forklifts).
  • Scaffolds
  • Ladders.
  • Electrical
  • Hazard communication.
  • Training

Accidents reported and investigated / reported by OSHA (Fed) will likely involve falls, stuck-by, electrical shock and engulfment.

My predictions for Cal/OSHA are the following and likely in this order:

  1. Injury, Illness Prevention Program (IIPP) §3203 General Industry
  2. Injury, Illness Prevention Program (IIPP) §1509 Construction Industry
  3. Heat Injury Illness Program (HIIP) §3395
  4. Fire Extinguisher §6151
  5. Powered Industrial Truck – Operator Training §3668
  6. OSHA 300 Log §14300.32
  7. OSHA 300 Log §14300.40
  8. Hazardous Communication (HAZCOM) §5194
  9. Control of Hazardous Energy (LO/TO) §3314
  10. Machine Guarding [various]

Cal/OSHA reported-citied accidents will be mostly fall related, confined space entry and a few involving electric shock.

I have so much faith in my predictions, I will go one step further and identify the actually citation number issued for each area noted in my prediction.

  1. IIPP  §3203 General Industry
    1. §3203(a) failed to have an effective program
    1. §3203(b)(1) – failure to maintain inspection records
    1. §3203(a)(4)- no procedures for identifying and evaluating work place hazards including scheduled periodic inspections to identify unsafe conditions and work practices.
    1. §3203(a)(7) – Failure to provide training
  • IIPP §1509 Construction Industry
    • §1509(a) failure to have an effective program
    • §1509(b) failure to have a written code of safe practices
    • §1509(c) failure to “post”, provide and or make available the CoSP. 
    • §1509(d) failure to conduct “periodic” meeting (no documentation)
    • §1509(e) failure to conduct “toolbox” or “tailgate” safety meetings, or equivalent, with their crews at least every 10 working days to emphasize safety. (no documentation)
  • HIIP §3395 (No program or program not updated)
    • §3395 (e) No or failure to make available High-heat procedures.
    • §3395 (e) (5) No or failure to document a “Pre-shift meeting” addressing heat procedures.
    • §3395 (h) (1) No or not updated training (heat procedures).
  • Fire Extinguisher §6151
  • Powered Industrial Truck – Operator Training §3668
    • Only drivers authorized by the employer and trained in the safe operations of industrial trucks or industrial tow tractors pursuant to Section 3668 shall be permitted to operate such vehicles.
    • §3668(t)(7) Drivers shall check [“inspect”] the vehicle at the beginning of each shift, and if it is found to be unsafe, the matter shall be reported immediately……
  • OSHA 300 log §14300.32
    • §14300.32(a)(1) verify that the entries are complete and accurate
    • §14300.32(a)(3) certify the annual summary
  • OSHA 300 Log §14300.40
    • §14300.40(a) failure to provide to OSHA 300 logs within 4 hours
  • HAZCOM §5194 Hazardous Communication
  • §5194(e)(1) Failure to develop and implement a written hazard communication program
  • §5194(e)(1)(A) Failure to maintain a list of the hazardous substances
  • §5194(h) (1) Failure to provide employees with information/training of hazardous substances in the workplace.
  • LO/TO §3314 Control of Hazardous Energy
    • §3314(g) Failure to develop a hazardous energy control procedure
    • §3314(g)(2)(A) Failure to develop separate procedural steps for each machine/equipment
  • Machine Guarding [various]
    • §4051(a) Failure to Projecting shaft ends
    • §4070(a) Failure to protect moving parts
    • §4075(a) Failure to rears, sprockets and sprocket chain drains
    • §4084(b)

[ref: 4310(a)(1) Failure to guide saw or knife blade

>ü  §4207(a)91) Failure to prevent entry of hands or fingers into the point of operation

  • §3328(d) Failure to ensure that machinery and equipment is restrained so as to prevent walking or moving

I ask that you keep these predictions handy and review them in January when the various safety journals, blogs and other sources publish the official annual stats.  Some of you will be surprise by just how accurate my predictions are.  Though the order may be a little off, the subject matter (items cited) will be spot on.  

Before you ask, no I’m not psychic nor do I have a crystal ball.  Those that have been in the business of safety-compliance awhile will attest that these predictions are likely spot on.  The fact of the matter is all of these are on the list of “Top Ten” year after year after year.

Reviewing these “findings” (OSHA Top Ten) can be useful to employers as a basic “what to look for” when inspecting their workplace, ensuring these violations (citations issued) are not an issue.

Keeping in the mind the ultimate goal is to provide a safe and healthy workplace. Most we agree, if your workplace (conditions and employees) is compliant, it will likely result in a safe workplace, safe working conditions, more so than the if the workplace has compliance issues.

Being “compliant” is also business smart.  Considering nearly every “Program Inspection” result in a multitude of citations of what most safety people deem as “low hanging findings” that could easily be avoided [portable fire extinguisher lacking a month inspection, fire extinguishers (access) blocked, first aid supplies expired, the mandatory posting missing or “incomplete”, no or inadequate training records, no or inadequate inspections / recordkeeping, no or inadequate and signage postings and OSHA 300 Log violations] that are costly in fines.

Please keep my predictions handy and review them in January when the various safety journals, blogs and other sources publish the official annual stats.  Though the order may be a little off, the subject matter (items cited) will be spot on. 

“Are you in compliance or are you complacent?”

If you wish to be in compliant, call and schedule a comprehensive inspection of your facility / workplace.

For questions, information and comments, please feel free to email me at: paulandersenCHST@aol.com or call (888) OSHA-PRO

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