A dive into OSHA’s most cited violations of 2018

Every year the Occupational Safety and Health Administration (OSHA) puts together a list of the most cited violations per standard in the United States, for the previous (fiscal) year. In general the top 10 is very similar year to year, with just the amount of citations varying. However, last year we saw fall protection training requirements (OSHA 1926.503) enter the list at number 9. This year the top 10 also has a new entry; eye and face protection. Fall protection training requirements can also still be found in the top 10, switching places with machine guarding.

The statistics once again show that general fall protection citations (OSHA 1926.501) top the list, for the eight year in a row. What is new however is that, for the first time since 2013, there was a rise in citations for this category.

As we can see in the above graph, citations for violations of the fall protection standard had been decreasing. Rapidly in the beginning, but eventually slowing down over the years. However this past year we saw an increase of 4,7%.

The only other two citations that had an increase compared to last year (not counting the new entry to the list) are ‘Ladders’ (+ 8,3%) and ‘Fall Protection – Training Requirements’ (+ 14,7%).

Two of the entries of OSHA’s most cited top 10 are of special interest to us as they directly involve fall protection; fall protection – general requirements and fall protection – training requirements.

OSHA’s most cited standards of 2018

Entry 1: Fall Protection – General Requirements

Every standard in OSHA’s top 10 has a subsection top five. These give a little more insight into what kind of citations frequently occur.

For fall protection all cited subsections involve protecting employees working at 6 feet (1,8 m) or more above the ground or a lower level. Fall protection may be provided by installing a collective solution such as a guardrail system, a safety net system or provide in a personal fall arrest system. In some situations a system of warning lines can be applied. A fall protection expert can advise you on what fall protection measures are most suitable for your workplace.

1. Residential construction – 4570 violations (+318)
   All employees working in residential construction 1,8 meters (6 feet) or more above a lower level must be protected from falls. (1926.501(b)(13))*
2. Unprotected sides and edges – 1124 violations (+72)
   All employees on walking/working surfaces with an unprotected side or edge 1,8 meters (6 feet) above a lower level must be protected from falls. (501(b)(1))*
3. Roofing work on low-slope roofs – 593 violations (+35)
   All employees working on roofing activities on low-slope roofs with unprotected edges at 1,8 meters (6 feet) or higher must be protected from falling. (501(b)(10))*
4. Steep roofs – 427 violations (-57)
   All employees working on steep sloped roofs, with unprotected edges, 6 feet (1,8 m) or higher must be protected from falls. (501(b)(11))*
5. Holes – 116 violations (-27)
   Employees must be protected from falling through holes (including skylights) that are more than 6 feet (1,8 m) above a lower level. (1926.501(b)(4)(i))*

*The respective standards give more insight into what methods to apply to protect workers from fall.

The numbers in brackets show the difference in amount of citations compared to last year. You can see that the first three entries have more citations this year. Violations of steep roofs and holes on the other hand dropped.

Entry 8: Fall Protection – Training Requirements

Providing fall protection equipment to employees is one step in keeping them safe, but without training the equipment won’t properly protect them. You have to understand the fall hazards present in order to be able to work safely at height.

This standard covers what training employees should receive, when and by whom.

The most frequent citations occur in the following areas.

1. Training program – 1283 violations (+48)
   Employers must provide training to any employee who might be exposed to fall hazards. Training them in recognizing fall hazards and in the procedures to minimize fall risks. (503(a)(1))
2. Certification of training – 368 violations (+124)
   The employer must keep a written certification record that includes an identifier of the employee trained, the date of the training and a signature of the trainer or employer. (1926.503(b)(1))
3. Retraining – 114 violations (+52)
   If it seems as if an employee does not have enough knowledge or skills to combat hazards after training they need to be retrained. (1926.503(c)(3))
4. Training by a competent person – 85 violations (+5)
   The employer must ensure that all employees who can be exposed to falls are trained by a competent person. (1926.503(a)(2))
5. Requirements of a competent person – 46 violations (+11)
   A competent person is qualified in the use and operation of guardrail systems, personal fall arrest systems etc. (1926.503(a)(2)(iii))

All subparts of the fall protection training requirements standard show an increase in citations compared to last year.