Frequent Safety Violations - OSHA Penalty Avoidance Tips

Helping contractors to understand and focus on areas where jobsite hazards and citations usually and frequently occur not only gets right to the heart of the matter, but also, results in an increased level of hazard awareness for you and your workers.

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Therefore, let’s review some of these areas where jobsite and workplace violations frequently occur and offer some control measures on how to avoid these situations and comply with OSHA’s regulations. To do this, we’ll look at some of the various OSHA reports on “most frequently cited serious violations” for the following: The related Subpart section of the CFR (Code of Federal Regulations) follows each one listed.

Fall Protection (Subpart M)
Excavations (Subpart P)
Stairways and Ladders (Subpart X)

Fall Protection

The three (3) most frequently cited serious violations are:

1. Failure to protect workers from falls of 6 feet or more off unprotected sides or edges, e.g. floors and roofs 1926.501(b)(1); (b)(10); and (b)(11).

2. Failure to protect workers from falling into or through holes and openings in floors and walls 1926.501(b)(4) and (b)(14).

3. Failure to provide guardrails on runways and ramps where workers are exposed to falls of 6 feet or more to a lower level 1926.501(b)(6).

Fall Protection Control Measures:

Again, by means of performing a jobsite hazard survey, you will determine where fall hazards may exist throughout the course of the project, then implement and train your workers on the necessary protective measures prior to startup. Protective measures may include any one or a combination of the following methods: personal fall arrest system, guardrail system, safety net system, positioning device system, controlled access zone, and/or safety monitor. Which method to use depends on the type of fall hazard.

Wherever possible, use a mechanical lifting device to lift equipment or assembled items into place such as sections of roofing. This will eliminate or reduce the number of workers exposed to falls.
Working platforms such as aerial lifts or scaffolds provide better working surfaces for your workers rather than walking top plates or beams.
A hole is defined as an opening 2 inches in its smallest dimension in a floor, roof or other walking/working surface. Covers are to be placed over any holes and marked as “HOLE” or “COVER” to provide warning of the hazard.
Where fall hazards exist, limit the number of workers in the area to only those who are qualified and necessary. Also, designate an employee as the “safety monitor” where fall hazards exist. This person will observe employees and alert them of any unsafe activity and any hazards that could cause them to trip or fall.

Excavations

OSHA lists twenty one (21) areas of the standard most frequently cited as serious violations (January 1990 to April 1996), they are:

1. Protection in Excavations 1926.652(a)(1)
2. Inspections .651(k)(1)
3. Loose Rock/Soil .651(j)(2)
4. Means of Egress .651(c)(2)
5. Vehicular Traffic .651(d)
6. Inspections .651(k)(2)
7. Water Accumulation .651(h)(1)
8. Loose Rock/Soil .651(j)(1)
9. *Walkways/Guardrails .651(1)(2)
10. Falling Loads .651(e)
11. Adjacent Structures .651(I)(3)
12. *Walkways/Guardrails .651(1)(1)
13. Sloping/Benching Systems .652(b)
14. Adjacent Structures .651(I)(1)
15. Design/Protective Systems .652(c)
16. Shield Systems Requirements .652(g)(2)
17. Shield Systems/General .652(g)(1)
18. Underground Installations .651(b)(4)
19. Hazardous Atmospheres .651(g)(1)
20. Surface Encumbrances .651(a)
21. Protective Systems .652(a)(2)

* Section 1926.651(1)(2) was deleted by the Federal Register number 40730, dated August 9, 1994 (final rule Subpart M of Part 1926 -Fall Protection). Basically, these two sections are now covered under the new fall protection regulations for the construction industry found in Subpart M as noted.

As you can see from the list above, contractors continue to be cited for numerous violations of the excavation regulation. This is partly due to the fact that with most excavation projects there are many elements to consider and have a clear knowledge of such as: soil classifications, shielding/shoring systems, sloping/benching methods, the effects of water accumulation, hazardous atmospheres, protection of existing underground structures/utilities, effects of adjacent structures, adjacent vehicular traffic, employee access in and out of the excavation, inspection methods, emergency evacuation plan, etc., and the list goes on.

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