Most Frequently Cited 08-09 Standards
By Lisa Brownson, Safety Source Consultants, LTD OSHA has published its most frequently cited standards
in fiscal year 2009 (October 1, 2008 through September 30, 2009). It may be worthwhile to see whether you’re up to speed on these regulations. I’ve reviewed some of them here, and you can see the full list at
osha.gov. At the top of the list is 29 CFR 1926.451, the General Requirements for scaffolding. It covers scaffold capacity, platform construction, criteria for supported and suspen- sion scaffolds, access, the clearance between scaffolds and power lines, fall protection, and falling object pro- tection. Violations such as absent guardrails, climbing cross braces, or work platforms that are not fully planked, would fall under this standard. In the number two position, and at the top of the list for highest penalties assessed, is 1926.501, Duty to have fall protection. In addition to the conventional fall protection systems (guardrails, safety nets, and personal fall arrest), this standard describes other fall protection options avail- able to those performing specific types of work. Roofers on low slope roofs, for example, may use a warning line system and a safety monitoring system. Failure to provide fall protection, or allowing the use of the wrong type of protection, would be covered under this standard. Fall protection made the list a second time, at number ten. Fall protection-training re- quirements, 1926.503, mandates training for each employee who might be exposed to fall hazards, and de- scribes the content of that training. Written
certification showing who was trained, date of training, and the signature of the instructor or the employer must be maintained. If there are changes in the workplace or the type of fall protection used, or an em- ployee’s performance indi- cates a need, refresher train- ing must be done.
24 | CONSTRUCTION CONTRACTOR 1ST QUARTER 2010 Number three involves 1910.1200, the Hazard Commu-
nication standard, which requires employers to acquaint employees with chemical hazards in the workplace through training, labeling, and making available Material Safety Data Sheets. Unlabeled containers and missing MSDS’s are common violations under the haz com standard. At fourth place is 1910.134, the Respiratory Protection standard. It covers requirements related to selection of respirators, medical evaluations, fit tests, proper use and cleaning of respirators, and employee training. Remember that, even if your employee is using respirators on a vol- untary basis, you must ensure that s/he is “medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user.” (1910.134(c)(2)(ii)) Filtering face pieces, or dust masks, are an exception to this rule. Ladders, 1926.1053, is in sixth place. The standard cov-
ers portable and fixed ladder capacity, safety devices, and use. Portable ladder violations could include failure to use the ladder on a stable and level surface, extension ladder side rails that do not extend at least 3 feet above an upper landing surface, and using the top or top step of a steplad- der.
Powered Industrial Trucks, 1910.178, is listed at num-
ber seven. The standard covers the safety requirements for a wide range of equipment, including rough terrain and other fork trucks. Operators must be trained in truck- and workplace-related topics using formal instruction, practical training, and evaluation of the operator’s per- formance. Re-evaluation of operators’ performance is re- quired every three years, with refresher training mandated if there are changes to the type of equipment operated or to workplace conditions, or if an operator’s performance indicates a need. This is another standard that requires written training certification. You will find extensive compliance assistance for these
and many other areas at
osha.gov. For the full “most fre- quently cited” list, as well as the standards for which OSHA assessed the highest penalties, please visit www.
osha.gov/dcsp/compliance_assistance/frequent_stan- dards.html. Lisa Brownson, CSP, is President of Safety Source Con- sultants, Ltd. You may contact her at (315) 373-5709 or via e-mail at
lbrownson@twcny.rr.com.
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