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Top 10 Most Cited Violations in 2011

Top 10 Most Cited Violations in 2011

OSHA's fiscal year ends Sept. 30 so the recent results for fiscal year 2011 are for the period of Oct. 1, 2010 through Sept. 30, 2011. Each year, this list seems to include the same violations. The standards may change violations' positions on the list but the basic violation makeup goes unchanged.

OSHA encourages employers to use this list to improve their safety program. The list for all industries is:

  1. Fall protection
  2. Scaffolding
  3. Hazard Communication
  4. Respiratory Protection
  5. Lockout/Tagout
  6. Electrical – Wiring Methods
  7. Powered Industrial Trucks
  8. Ladders
  9. Electrical-General Requirements
  10. Machine Guarding

The National Safety Council reports in its December 2011 Safety+Health publication that the total number of violations for all the standards listed above was 34,796. OSHA's top 10 proposed monetary penalties for the fiscal year ranged from $1.94 million to a Phenix City, Ala., lumber company to $487,000 to a Batesville, Miss., corporation.

As far as dental laboratories, there were 31 dental facilities in SIC code 8072 visited in FY 2011. The proposed monetary penalties ranged from $10,530 to $250. The most active states for inspections were Washington and Minnesota. The top five standards cited were:

  1. Hazard Communication
  2. Electrical - Wiring methods
  3. Eye and Face Protection
  4. Bloodborne Pathogens
  5. Emergency equipment

As OSHA suggests, you should look at the top 10 standards cited in all industries and ensure that you're complying with them. Also look at the five standards that are the most common for dental laboratories and survey your facility to make sure that you're complying with those standards. Here's a brief description of each of the five standards common to dental laboratories:

  • Hazard communication is Standard 1910.1200. This standard addresses chemical hazards-both those chemicals produced in the workplace and those imported into the workplace. It also governs the communication of those hazards to workers. The communication involves training upon hire, when new chemicals enter the workplace, when duties change that involve chemicals. Availability of MSDSs to workers and labeling of products are also a part of this standard so make sure you comply with these requirements.
  • Electrical - wiring methods is Standard 1910.305. This standard covers the grounding of electrical equipment, wiring and insulation. It includes temporary wiring and splicing, such as flexible cords and cables. Get rid of those extension cords and make sure all wiring is in good repair. Also make sure electrical outlets within 6 feet of a water source (10 feet if you're in Minnesota) are grounded with GFI.
  • Eye and face protection is Standard 1910.133. This standard requires that employers ensure that each affected employee uses 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. Do a hazard analysis to determine the hazards present in your workplace that require use of personal protective equipment.
  • Bloodborne pathogens standards is Standard 1910.1030. This standard requires that employers identify risk areas where there could be exposure to potentially infectious items. For a dental laboratory this is the handling of impressions and other items that have been in a patient's mouth. You must identify the risk areas, train workers on the risks, and provide the appropriate protection such as disinfection, use of personal protective equipment, and decontamination of areas where risk could occur. Also, this includes the offering of the Hepatitis B vaccine to Category I workers.
  • Emergency action plans is Standard 1910.38. This standard requires an employer to have an emergency action plan whenever an OSHA standard requires one. Emergency actions can include emergencies such as fire, medical, eye injury, weather, flood, earthquake, workplace violence, spills and first aid. You should evaluate the types of emergencies that could occur and have a plan to handle each one.

As you begin this New Year, take a good look at your health and safety program and enhance it where needed.  Begin by looking at those minor injuries that many of you say are just going to happen.  I always cringe when I hear that statement!  Do everything you can to assess why the minor cut or burn happened and change the work practice so workers aren’t injured.  It’s the right thing to do for your workers but also the right thing to do to keep your workers’ compensation premiums down.  Happy New Year and hopefully it’ll be a safe and prosperous one for us all. 

Author Information
Mary Borg
Borg is the co-founder and president of SafeLink Consulting Inc. Since 1991, she has actively participated as a presenter and on-site instructor to audiences of dentists, dental hygienists, dental assistants, and dental laboratory technicians throughout the US. Prior to founding SafeLink Consulting , Borg held senior level management positions in mortgage banking, banking and the family entertainment business. Her positions included responsibility for facilities management, human resources, risk management, crisis and disaster recovery and health and safety.