OSHA Publishes Top 10 List of Most Frequently Cited Standards for 2020

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On March 2, OSHA announced its Top 10 Most Frequently Cited Standards for 2020.

The annual Top 10 List offers valuable insights for safety professionals as to what Standards and enforcement priorities OSHA is currently pursuing and is likely to prioritize during the coming year. It also gives employers a glimpse into the areas of occupational safety and health they should be focused on as they seek to improve performance of their own workplace EHS programs and minimize the risk for non-compliance.

OSHA’s Top 10 List for 2020 features all the usual suspects, being largely unchanged compared to previous years’ lists. However, there’s been a few movers since last year’s list that point to some telling changes in OSHA’s enforcement focus.

OSHA's Top 10 List for 2020

Here’s OSHA’s Top 10 List of Most Frequently Cited Standards for 2020, and the numbers of citations issued:

  1. Fall Protection – General Requirements (1926.501): 5,424
  2. Hazard Communication (1910.1200): 3,199
  3. Respiratory Protection (1910.134): 2,649
  4. Scaffolding (1926.451): 2,538
  5. Ladders (1926.1053): 2,129
  6. Lockout/Tagout (1910.147): 2,065
  7. Powered Industrial Trucks (1910.178): 1,932
  8. Fall Protection – Training Requirements (1926.503): 1,621
  9. Personal Protective and Life Saving Equipment – Eye and Face Protection (1926.102): 1,369
  10. Machine Guarding (1910.212): 1,313

Changes for 2020

For comparison, here is OSHA’s Top 10 List of Most Frequently Cited Standards for 2019

  1. Fall Protection - General Requirements (1926.501): 6,010
  2. Hazard Communication (1910.1200): 3,671
  3. Scaffolding - General Requirements (1926.451): 2,813
  4. Control of Hazardous Energy - Lockout/Tagout (1910.147): 2,606
  5. Respiratory Protection (1910.134): 2,450
  6. Ladders (1926.1053): 2,345
  7. Powered Industrial Trucks (1910.178): 2,093
  8. Fall Protection – Training Requirements (1926.503): 1,773
  9. Machine Guarding– General Requirement (1910.212): 1,743
  10. Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102): 1,411

Overall, the 2020 list is pretty similar to last year, but we can see that Respiratory Protection Standard violations moved up from fifth in 2019 to third in 2020. OSHA has likely been more focused on respiratory protection due to the COVID-19 pandemic which resulted in the increased use of N95 and other respirators in workplaces across the US, particularly in health care and related establishments.

Control of Hazardous Energy (Lockout/Tagout) citations fell slightly from fifth in 2019 to sixth in 2020, while citations for Ladders Standards rose from sixth in 2019 to fifth in 2020.

One thing that hasn’t changed is OSHA’s Hazard Communication Standard (HazCom) ranking second on the Top 10 List for its eighth year in-a-row (2012-2020). This isn’t totally unexpected considering how many workplaces use hazardous chemicals and how vital HazCom is to worker safety, but it’s surprising because OSHA’s HazCom requirements have been essentially unchanged since 2015 when the Agency’s transition to GHS Revision 3 was completed. Still, employers continue to struggle with compliance and OSHA’s recently proposed alignment with GHS Revision 7 suggests the challenges and uncertainty for employers when it comes to compliance will only increase.

Key Takeaways

You can see that both individual and total numbers of citations issued in 2020 have dropped slightly across the board compared to the previous year (2019). The reduced enforcement activity is likely due to year-over-year reductions in total numbers of inspections performed, as well as a continued drop in the number of OSHA inspectors employed in the field.

A 2019 report from the National Employment Law Project (NELP) shows that in 2010, U.S. OSHA employed 1,016 inspectors, virtually the same number it had three decades earlier. This is despite the increase in sheer number and breadth of workplace health and safety standards implemented since the Agency was founded, as well as 30 years of growth in the American labor force. By 2016, the agency was down to 952 inspectors, and by Jan. 1, 2019, it had dropped to 875. As of August 2020, that number had dropped further to 761 inspectors who are responsible for monitoring workplace health and safety compliance at millions of workplaces across the U.S.

The Changing Tide

These trends of diminished enforcement by OSHA appear to be changing direction. In response to ongoing risk of COVID-19 exposure in US workplaces, OSHA shows definite signs of reinvigorating its enforcement activities in 2021 and beyond. The Biden Administration has already taken a number of early actions on workplace safety, particularly in regard to COVID-19 risks, pointing towards stronger, more targeted enforcement.

The recent actions include President Biden’s Executive Order directing DOL and OSHA to strengthen its enforcement focus on workplace COVID-19 hazards and make a determination on publishing a COVID-19 emergency temporary standard (ETS). To supplement these efforts, OSHA recently announced its OSHA’s COVID-19 National Emphasis Program on March 15, and also indicated that despite the lapse of its March 15 deadline, the Agency will be moving forward with an ETS. In a March 15 briefing, White House Press Secretary Jen Psaki stressed the administration’s objective to protect workers, [yet] indicated no expected release date for the ETS, saying OSHA “should have the time to get it right.”

These recent actions all strongly suggest that OSHA will be increasing its number of inspectors, moving forward with more stringent workplace regulations, and getting tougher on employers for non-compliance.

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