Employee fatalities in the workplace are one of the worst situations employers can encounter while running a business. In just Fiscal Year 2019 alone, over 5,000 workers died on the job, averaging out to more than 100 fatalities per week, or fifteen cases per day. To combat these stark numbers and better protect employees on the jobsite, the Occupational Safety and Health Administration (OSHA) strictly enforces citations for safety violations that could lead to these fatalities. As part of a recent EHS Daily Advisor webinar, Reese Fortin, the HSE Safety Manager at Sundt Construction, broke down the top ten OSHA citations from FY 2020 and offered some prevention strategies to avoid them in the coming year. 

Fall Protection 

Falls are the number one killer of construction workers, and failure to provide fall protection was the most cited OSHA violation in 2020. Fortin cited that in FY 2019, about 20% of worker fatalities in private industry were employees in construction. 

To avoid these deaths and to comply with OSHA’s fall protection standards, Fortin recommended consulting with professionals and assessing building designs to figure out where the fall exposures are for the workers and end users. Employers should craft a site-specific fall protection plan, that lays out specific details such as where employees are going to tie off, and where guardrails are going to be. Lastly, Fortin suggested having a fall protection permit, and focusing specifically on fall protection during inspection, in order to plan for potential falls in risky areas. 

Fortin said there is a hierarchy of controls when it comes to fall protection, starting with elimination. To avoid falls, employers should coordinate the design with the architect, prefabricate in a controlled work environment, and work at ground level instead of at height. The next step is substitution, involving a change in the sequence of activities or an adjustment in the project schedule. This is followed by engineering controls, which involves establishing an edge protection system, guardrails, and safety nets, and then administrative controls, involving restriction of access and setting up warning line systems. The last step is issuing personal protective equipment (PPE), such as fall restraints and fall arrest systems. 

Hazard Communication Standard 

Businesses in every industry should have a hazard communication standard with a written HazCom program that meets OSHA’s requirements. There should be a safety data sheet (SDS) inventory for hazardous chemicals, which must be easily accessible. All containers should be labeled, especially those containing chemicals, including water. Finally, there should be training for all affected personnel, including globally harmonized system (GHS) training for everyone, so that there is standardization across the board for chemicals and their uses. 

Respiratory Protection 

Fortin said that there is no better way to avoid a citation involving respiratory protection than just being prepared for the next emergency, such as another pandemic, or even a wildfire. Employers should assess their workplace and processes to see what respiratory hazards may arise, and then procure and provide protection from the exposures. They should also implement training for personnel that includes how to put on, use, and take off all the respiratory equipment available to their employees. 

Scaffolding and Ladders 

When using scaffolding at a jobsite, employers should be conducting daily inspections by a competent person. There should also be waivers signed by those using it, and proper supports or mudsills. Employers need to provide safe access to the scaffolding, such as gates or drop-down ladders. They should also limit the storage of materials or debris on the scaffolding, and be as neat and tidy as possible, to avoid any accidents. 

As for ladders, they cause 100 workplace fatalities each year on average, due to slipping, employees overreaching, defective equipment, and improper ladder selection for the given task, according to Fortin. Ladders should be secured, and portable ones should be extended three feet above the landing they lean on. Fortin recommended consulting with a ladder professional to provide ladders that lessen user error and are best for the jobs they are intended for. Businesses should also train workers on ladder safe practices, ensure regular inspections from a competent person, and use a “ladders last” policy, which means prioritizing all other platform options before ladders. 

Control of Hazardous Energy 

Companies working with any kind of hazardous energy should plan for shutdowns and execute those plans immediately when needed. There should be a written lock-out, tag-out, try-out program, training for affected personnel, and specific procedures for equipment, especially in manufacturing plants.

Powered Industrial Trucks 

To avoid powered industrial truck citations, operators must be certified and evaluated to make sure that they are competent and compliant with standards. Employers must conduct daily, documented truck inspections, which OSHA will ask to look at. They also must provide regular and routine truck maintenance by a qualified, trained, and experienced mechanic. Most importantly, seatbelts are required for all personnel inside the vehicles. 

Fall Protection Training 

Citations for incompetent fall protection training are important to note as well as fall protection citations, said Fortin. Employers should have a competent person training and supervising the workplace, and all personnel should be aware of the dangers of falls. 

Eye and Face Protection 

Businesses must have a written policy for eye and face protection in order to avoid citations. If employees wear prescription lenses, employers are required to protect their workers with Z87 rated protective glasses or some form of polycarbonate lenses, which are specifically tailored to the employee’s vision. These kinds of glasses can be difficult to come by, but Fortin said they can be given by a regular eye doctor if possible, or at SafeVision or Walmart. 

Machinery and Machine Guarding 

Finally, Fortin pointed out how many people are guilty of throwing away instruction manuals after buying a new piece of equipment or technology. However, employers must keep operator and owner manuals on hand for employee reference and training. Regular inspections of shops and facilities are crucial. Guards are required at points of operation, pinch points, and at other areas where there are rotating parts, flying chips, and sparks. Lastly, employers must train shop and tool managers on the manufacturer’s guarding requirements.

For more information or assistance with your Environmental and Health & Safety regulatory compliance needs, contact Ralph Carito at Total Environmental & Safety, LLC (Total) at rcarito@TotalEnviron.com or 908-442-8599. 

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