Fall Protection and Hazard Communication Top OSHA’s List of Common Citations
by Jen Clark
Full Implementation of Hazard Communication Standards Expected in 2016
Three years ago, the Occupational Safety and Health Administration (OSHA) aligned its Hazard Communication Standard (HCS) with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Once fully implemented in 2016, OSHA expects the changes will impact over five million facilities and over 40 million workers.
HazCom 2012 provides a common approach to classifying chemicals and communicating hazard information on labels and safety data sheets (SDS). The definitions of hazard were changed to provide specific criteria for classification of health and physical hazards and for the classification of mixtures. Chemical manufacturers and importers now are required to provide a harmonized label that has six standardized elements for classified hazards, including product identifier, manufacturer contact information, hazard pictograms, signal word (DANGER or WARNING), hazard statements and precautionary statements.
SDSs, previously known as Material Safety Data Sheets, remain the backbone of HCS. Employers must ensure they are readily accessible to employees. The major change here is a required, standardized 16-section format, which include identification; hazard(s) identification; composition/ingredient information; first-aid measures; firefighting measures; accidental release measures; handling and storage; exposure control/personal protection; physical and chemical properties; stability and reactivity; toxicological information; ecological information; disposal considerations; transport information; regulatory information; and other information. To be compliant, an SDS needs all 16 sections; however, OSHA will not enforce sections 12-15, which fall outside of its jurisdiction.
For more information on complying with the standards, visit www.osha.gov/dsg/hazcom.
According to a recent Occupational Safety and Health Administration (OSHA) report, "Adding Inequality to Injury: The Costs of Failing to Protect Workers on the Job," the Bureau of Labor Statistics (BLS) found "approximately 4,500 workers are killed on the job each year ... and that employers record nearly three million serious occupational injuries and illnesses annually." These records are mandated by a nearly 40-year-old legal obligation to provide safe workplaces.
The Occupational Safety and Health Act of 1970 required employers to provide workplaces "free from recognized hazards that are causing or likely to cause death or serious physical harm." OSHA inspectors cite thousands of companies for unsafe working conditions every year, usually resulting in costly fines. OSHA annually provides a list of the Top 10 violations for the fiscal year during the National Safety Council Congress and Expo, which took place in San Diego, California, last September. For the fourth year in a row, OSHA’s Fall Protection Standard (1926.501) was the agency’s most frequently cited violation (6,143 violations), followed by hazard communication (5,161 violations) and scaffolding (4,029 violations).
For owners and managers, knowing about these violations can help them assess their companies’ risk potential, which could help avoid business disruption, citations and/or fines.
1. Fall Protection
OSHA requires that fall protection be provided at elevations of 4' in general industry workplaces, 5' in shipyards, 6' in the construction industry and 8' in longshoring operations. In addition, fall protection should be provided when working over dangerous equipment and machinery, regardless of the fall distance. Appropriate fall protection gear can include railings, personal fall arrest systems or warning lines.
2. Hazard Communication
In 2012, OSHA revised its Hazard Communication Standard, aligning it with the United Nations’ global chemical labeling system. It will be fully implemented in 2016, with the goals of reducing confusion about chemical hazards in the workplace, facilitating safety training and improving understanding of hazards. Employers should identify and evaluate all chemical hazards in the workplace and then make that information readily available to all employees through safety data sheets. Keeping an up-to-date list is just as important as having one. Training also is a key component of the HazCom standard (see sidebar for more information).
Established guidelines help protect employees who are working on or near elevated, temporary work platforms at heights of 10' or more. OSHA noted that a big problem is people using scaffolding as ladders and ladders as scaffolding, assuming one could work for the other. Other problems include holes in platforms, not having an adequate point of access, lack of fall protection and not having a competent person assigned to select and direct employees, asses the weather, train employees, inspect scaffolding and determine if scaffolding is structurally sound.
4. Respiratory Protection
Air quality or breathing hazards – such as dust, fumes, gases, mist, sprays and vapors – may require the use of respiratory protection either with a respirator or dusk mask. Respirators protect the user in one of two basic ways – by removing contaminants from the air or supplying clean air from another source. Employers must have a written program to show how they are implementing various parts of the standard.
5. Powered Industrial Trucks
Powered industrial trucks, commonly called forklifts or lift trucks, are used in many industries, primarily to move materials. Employers must ensure that each powered industrial truck operator is trained and competent to operate a powered industrial truck safely. No one under the age of 18 is allowed to operate a forklift. Training must be provided for each type of equipment the company operates.
According to OSHA, nearly 200 workplace deaths occur each year because hazardous energy hasn’t been controlled during routine maintenance or machine servicing. Proper lockout procedures help prevent the accidental startup of machinery. There are nine steps to a general lockout/tagout procedure.
- Prepare for shutdown
- Notify others
- Shut down the equipment
- Isolate the equipment
- Lockout/tagout the equipment
- Release stored energy
- Verify isolation
- Perform service
- Release from lockout/tagout
Similar to the fall protection standard, ladders only should be used for what they are designed for and must extend 3' above the upper landing surface. OSHA prohibits ladder use as a walking platform or lifting device. Ladders also must be in good shape.
8. Electrical: Wiring
Dangers such as electric shock, arc flash, electrocution, fires and explosions are possible. To help avoid potential violations, inspect wiring and insulation, plus take steps to ensure proper grounding of electrical equipment.
9. Machine Guarding
Guard the machinery to help protect operators and others from hazards, such as rotating parts, flying chips, sparks and other dangers. OSHA uses the 1910.212 standard to cite employers for lack of guarding on several types of equipment.
10. Electrical: Systems Design
Stay in compliance and avoid workplace injuries by following factory instructions when designing, installing and using electrical equipment. Using equipment in the workplace that only has been labeled or listed for home use is an OSHA violation.