The Occupational Safety and Health Administration (OSHA) and the National Safety Council (NSC) have long stood as watchdogs for American businesses when it comes to safety regulations and guidance. Combined, OSHA and the NSC form quite the tag team – the former charged with setting and enforcing key safety mandates for businesses and the latter, in part of its work as the nation’s leading nonprofit safety advocate, hammering home the message through evidence-based best practices and statistics showcasing the effectiveness of safety initiatives and legislation.
OSHA’s Annual Top 10 Violations List
Every year, though, whether due to careless mistakes or workplaces skirting their safety standard adherence duties, OSHA violations occur. These breaches to safety rules are chronicled and announced by OSHA annually in order for workplaces to understand key areas to focus on to keep workers safer. OSHA typically releases a preliminary "Top 10” list of the most frequently cited safety violations for that fiscal year (FY) as part of NSC’s annual Safety Congress and Expo.
One of the most troubling aspects of this list is the fact that, almost without fail over the past several years, the same violations come up again and again – many of them even in the same order, listed from the most to least common. This suggests that, for all the strides being made every day in the field of safety and regulatory oversight, many of the most common challenges have yet to be conquered.
Recapping Prior Year OSHA Violation Lists
Take the 2016, 2017, 2018, and 2019 OSHA violation lists as examples. The top five most common violations were identical: fall protection, hazard communication, scaffolding, respiratory protection and lockout/tagout. Many of the following five violations were also the same, just moving up or down in prevalence on the list. It’s a telling benchmark that these top hazards are still a concern year over year, despite OSHA’s push to communicate and regulate, as well as the shared goal of increased safety for today’s workplaces and equipment manufacturers.
Top 10 OSHA Violations for FY 2022
On September 20, 2022, OSHA announced its preliminary ‘Top 10’ list of the most frequently cited workplace safety violations for FY 2022. This year, the list was presented through the NSC Safety Congress and Expo, in person once again in San Diego, CA. Patrick Kapust, deputy director of OSHA’s Directorate of Enforcement Programs, presented the preliminary data and Kevin Druley, NSC Safety+Health associate editor, moderated the session.
Although multiple standards swapped positions, the top 10 violations from FY 2021 to FY 2022 did not change in their composition.
Here's a summary of the 2022 top violations – and some of the safety communication steps you can take to keep people in your workplace or who use your equipment safer. It is important to remember that this list is preliminary for 2022, and only includes data through September 6, 2022, an in depth look will be provided with more statistics from OSHA in December later this year.
Violation #1: Fall Protection – General Requirements
For the 12th consecutive year, fall protection has topped the annual hazard list, with 5,260 safety violations. The OSHA standard 1926.501 outlines fall protection system requirements, designed to protect employees on walking or working surfaces with an unprotected side or edge 6 feet off the ground or higher.
Clarion Safety Solution: Injuries that occur as a result of slips and falls are among the most common in the country, not just at the workplace. Safety warnings can inform workers, guests and contractors of potential unsafe slip and fall hazards, and reinforce and remind employees about proper safety procedures and personal protective equipment (PPE) requirements. Clarion Safety has the trip hazard signs and slip, trip and fall labels you need to send the right message in clear, concise ways.
Violation #2: Hazard Communication
This violation moved up this year from 5th place up to 2nd, with 2,424 violations so far in 2022. When potentially harmful chemicals and/or substances are present, it’s the job of business owners and product manufacturers to make this fact apparent. Effective as of 2012, the 1910.1200 OSHA standard has been updated to correspond with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). And, OSHA’s intention is to continue to align its Hazard Communication Standard with GHS as it evolves. GHS establishes a common way of communicating chemical hazard information including the use of a very standardized approach to the content and structure of safety labels pertaining to chemical products.
Clarion Safety Solution: It isn't enough to merely reference that chemicals are nearby; GHS graphical symbols help with quick, easy comprehension in a standardized manner. Clarion Safety has you covered with the GHS labels you need, with pictograms covering hazards and meanings like carcinogens, flammables, irritants, gases under pressure, explosives, skin corrosion/burns, oxidizers and aquatic toxicity. We can also meet your chemical safety labeling and signage needs.
Violation #3: Respiratory Protection
At high elevations or in environments where air quality is less than stellar, employers must utilize respiratory protection systems that reduce the risk of inhaling fumes, smoke and mists. OSHA standard 1910.134 outlines these requirements in more detail.
Clarion Safety Solution: Use personal protective equipment (PPE) signs to provide permanent visual reinforcement of your facility’s safety training policies requiring PPE, like respirators. Browse our PPE reinforcement signs now.
Violation #4: Ladders
Ladders: they're so common in work environments, there’s an entire month devoted to promoting how to use them properly – in addition to more general fall prevention awareness campaigns – given that ladders are often developed differently depending on their function. OSHA standard 1926.1053 outlines what some of these general safety requirements include.
Clarion Safety Solution: Ascending steps or rungs come with risk, even when a few inches off the ground. You can communicate these potential dangers with Clarion Safety’s slip, trip, and fall safety signs.
Violation #5: Scaffolding
This OSHA standard,1926.451, relates to general safety requirements for scaffolding. Employers are required to protect construction workers from falls and falling objects while working on or near scaffolding – temporary structures composed of polls and planks – at a 10 foot height or higher.
Violation #6: Lockout/Tagout
OSHA standard 1910.147 refers to injury risks that exist through the use of power equipment, such as scroll saws or other machinery that use voltage. It requires employers to establish a program and utilize procedures for affixing appropriate lockout/tagout devices to energy isolating devices, and to disable machines or equipment to prevent unexpected energization, start up or release of stored energy in order to prevent injuries. You'll notice this 1910 standard as a recurring theme in the violations list over the years, and the 2022 iteration was no different. This year, lockout/tagout accounted for 1,977 violations.
Clarion Safety Solution: Devastating injuries can occur from electrical hazards. Proper identification of the nature of electrical hazards and specific avoidance procedures with warnings that give the viewer more information are key to making products and workplaces safer. Clarion Safety has the lockout/tagout safety labels, signs and tags – as well as electrical safety labels, signs and tags – needed to keep people safe.
Violation #7: Powered Industrial Trucks
From platform lift trucks to forklifts and those built for over-the-road hauling, OSHA standard 1910.178 covers the safety requirements for these hulking pieces of machinery. Issues cited in the findings from OSHA included training on the specific type of truck being used, the use and evaluation of refresher training every three years, and operating a truck in need of repair or service.
Clarion Safety Solution: It isn't just the people using powered industrial trucks and forklifts that need protection but the people around them. Clarion Safety has the forklift safety labels and signs you need to protect workers, visitors, and subcontractors from forklift traffic accidents and injuries.
Violation #8: Fall Protection - Training Requirements
This violation was new to the violations list in 2017. It seems this year that employers are still struggling to provide the proper training materials and programs for employees as it relates to fall protection.
Clarion Safety Solution: Support your fall prevention program and reinforce training on proper safety procedures with safety labels and signs. Clarion Safety offers a variety of trip hazard signs and slip, trip and fall labels – and we can create unlimited custom options in line with your specific program or hazards.
Violation #9: Eye and Face Protection
2018 was the first year that this violation “Personal Protective and Lifesaving Equipment - Eye and Face Protection” made the list. It returned in 2020, 2021 and again in 2022 with 1,401 violations. OSHA standard 1926.102 requires that employers ensure that their employees use appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.
Clarion Safety Solution: Use safety labels and signs to remind employees about the hazards at hand and the proper PPE required. Clarion Safety offers a variety of PPE labels and PPE reinforcement signs that offer important visual reminders of your company’s safety policies regarding safety glasses and face protection.
Violation #10: Machine Guarding
The OSHA standard,1910.212, covers general requirements for machine guards to protect the operator and other employees in the machine area from potential hazards that can occur during a machine’s operation or maintenance, such as in-running nip points, rotating parts, flying chips, and sparks.
Clarion Safety Solution: Post safety labels and signs to warn of potential hazards if guards, interlock switches or other safety devices are circumvented. Well-designed safety labels and signs are your critical communication tools to reinforce training, serving as a final reminder regarding the importance of the safety devices installed on your products or in your facilities. From emergency stop legend plates to guard switch light curtain labels to accident prevention and equipment safety signs, we can meet all your warning needs.
Repeat Violators Under Higher Scrutiny
Released September 15, 2022, in a close time frame to the top 10 list, was the Department of Labor’s announcement to strengthen the enforcement and compliance to OSHA’s Severe Violator Enforcement Program. This change broadens the scope to which offending employers can fall under the parameters, with the first modifications since 2010. Specifically, OSHA’s updated criteria will include:
1. Program placement for employers with citations for at least two willful or repeated violations or who receive failure-to-abate notices based on the presence of high-gravity serious violations.
2. Follow up or referral inspections made one year – but not longer than two years after the final order.
3. Potential removal from the Severe Violator Enforcement Program three years after the date of receiving verification that the employer has abated all of the program related hazards. This used to allow removal three years after the final order date.
4. Employers will now have an opportunity to reduce time spent in the program to two years if they consent to an enhanced settlement agreement that includes use of a safety and health management system dictated by OSHA.
Paired with OSHA’s top 10 violations list that seems to remain unchanging in its make-up, employers should be careful to study why these repeat violations keep happening with equipment and in workplaces.
Helping to Reduce Risks
Clarion Safety has the label, sign and tag products that can help your warnings, instructions and workplace policies get noticed and heeded. We also offer a range of complementary services, including comprehensive machinery safety and risk assessment solutions . Let us know how we can help with your project!