OSHA's Top 10 Most Cited Violations in 2007
OSHA's Top 10 Most Cited Violations in 2007
The results are in for the 10 most-cited violations for all industries for the fiscal year ending in September 2007 (referred to as the 2007 year). Richard Fairfax, director of OSHA's directorate of enforcement programs often refers to what he calls "good" violations. These violations are the violations that present the greatest hazards to workers and are found by federal OSHA compliance officers during workplace inspections. It appears that OSHA inspectors are aggressively addressing fall protection, hazard communication, machine guarding and electrical hazards. Paperwork and recordkeeping are still important, however, these others issues are more critical to worker safety. So here are the top 10:
1. Scaffolding
2. Fall Protection
3. Hazard Communication
4. Respiratory Protection
5. Lockout/Tagout
6. Powered Industrial Trucks
7. Electrical - wiring
8. Ladders
9. Machine guarding
10. Electrical
The issues on this list that most typically pertain to dental laboratories are numbers 3, 4, 5, 7, 8, 9 and 10.
Hazard Communication
This standard addresses chemical hazards and how the hazards are communicated to the workers. The most common citations under this standard in 2007 were:
* Failure to develop and maintain a written program.
* Failure to maintain training.
* Failure to have Material Safety Data Sheets for each hazardous chemical.
* Lack of employee training.
Respiratory Protection
This standard directs employers in establishing or maintaining a respiratory protection program. The most common citations under this standard in 2007 were:
* Failure to establish a program.
* Failure to provide a medical evaluation to determine the employee's ability to use a respirator.
* Failure to fit test respirators.
* Failure to provide respirators at the request of employees or permit employers to use their own respirators.
Lockout/Tagout
This standard outlines minimum performance requirements for the control of hazardous energy during machinery maintenance. The most common citations under this standard in 2007 were:
* Failure to develop, document and utilize procedures for the control of potentially hazardous energy.
* Failure to establish and implement a written program.
* Failure to provide training to ensure safe application of lockout/tagout.
* Failure to outline the scope, purpose, authorization, rules and technique for the control of hazardous energy.
Electrical Wiring
This standard covers the grounding of electrical equipment, wiring and insulation. It includes temporary wiring and splicing such as flexible cords and cables. The most common citations under this standard in 2007 were:
* Failure to effectively close conductors entering boxes, cabinets or fittings and protect from abrasion.
* Failure to provide all pull boxes, junction boxes and fittings with covers approved for the purpose.
* Failure to connect flexible cords (extension cords) to devise and fittings so strain relief is provided to prevent pull from being directly transmitted to joints or terminal screws.
* Flexible cords and cables may not be used as a substitute for the fixed wiring of a structure.
Ladders
This standard covers general requirements for all ladders. The most common citations under this standard in 2007 were:
* Failure to extend ladder side rails at least 3-feet above the upper landing surface.
* Using ladders for the purpose other than for which they were designed.
* Using the top or top step of a stepladder as a step.
* Failure to mark portable ladders with structural defects in a manner readily identifying them as defective or withdrawing them from service until repaired.
* Failure to use ladders on stable and level surfaces.
Machine Guarding
This standard covers general safety requirements for the use of machine guards. The most common citations under this standard in 2007 were:
* Failure to provide one or more methods of machine guarding.
* Failure to guard the point of operation of machine whose operation exposes an employee to injury.
* Failure to anchor fixed machinery.
* Failure to guard blades.
* Failure to affix guards to machines.
Electrical
This standard covers general safety requirements for designing electrical systems. The most common citations under this standard in 2007 were:
* Failure to install and use electrical equipment according to factory instructions.
* Failure to guard electrical equipment.
* Failure to identify disconnecting means and circuits.
* Failure to keep work spaces clear.
* Use of electrical equipment containing recognized hazards.
As far as dental laboratories, the OSHA citation information on dental laboratories indicates that hazard communication is the most frequently cited standard. OSHA inspectors are instructed to look at hazard communication practices on every inspection. It's not just paperwork. It's training and education of the workers, availability of MSDS and labeling of hazardous materials. Remember that training must occur immediately upon hire and whenever a new chemical is introduced into the workplace. We recommend that you include hazard communication training, however, in your annual refresher safety training and always document your training sessions.
Dental laboratories have also been cited for respiratory protection, which was No. 4 on the list. As stated above, the common violations are failure to fit test and have medical questionnaires complete by those workers who are required to wear respirators. Remember that if the use of respirators is voluntary, then these requirements donÃt apply unless itÃs a mask that has the inner elastomeric seal and then the medical questionnaire must be completed.
This is the second year that ladders have appeared on the top 10 list. Because there have been so many injuries and deaths from falls from ladders, OSHA inspectors are paying particular attention to ladder safety. It's not unusual for a dental laboratory to have a ladder so ensure that you are training workers who use them to use them correctly and safely. If you're not sure what the requirements are you can go to the OSHA Web site at www.osha.gov and search for 29 CFR 1926.1053.
When performing our safety surveys in dental laboratories, it's not uncommon to observe numerous electrical violations. You'll see on the list above a reference to flexible cords. These are extension cords and they can't be used for permanent wiring. Also, you need to remove multi-plug adapters and install adequate electrical sources. Ground fault interrupters at outlets in close proximity to water sources are required, i.e. model trimmers and other equipment connected to a power source near water. Also remember that workers who repair and maintain equipment must be trained annually on lockout/tagout procedures and the training must be documented.
The good news is that according to information published by the Bureau of Labor Statistics, the number of nonfatal injuries and illnesses reported in 2006 declined to 4.1 million, a reduction from the prior year. Many dental laboratories fall into the midsize establishment - between 50 and 249 workers - category where the total recordable case rate in private industry was the highest. The rate was the lowest among small establishments that employed fewer than 11 workers. So keep up the good work and ensure that your employee health and safety program provides positive results.
