By Phil Molé, MPH
Every year, OSHA releases its Top 10 most frequently cited standards. And every year, the list barely changes. OSHA enforcement officers are finding the same issues and workers typically get hurt by the same hazards. It’s time to shift the conversation.
In what follows, you’ll learn why focusing on the “new” list every year isn’t really productive. And you will discover why the deeper lessons don’t come from what’s different about the list, but from why the stays mostly the same.
The 2025 OSHA Top 10: A Familiar Pattern
According to OSHA, these were the most frequently cited standards across inspections in fiscal year 2025 between October 1, 2024 and September 30, 2025:
- Fall Protection – General Requirements
- Hazard Communication (HazCom)
- Ladders
- Lockout/Tagout (Control of Hazardous Energy)
- Respiratory Protection
- Scaffolding
- Fall Protection Training
- Powered Industrial Trucks
- Eye and Face Protection
- Machine Guarding
If this list feels familiar, it should. For example, fall protection has held the top spot for over a decade, and HazCom has come in at #2 almost every year for at least the last 10 years. The rest of the entries are just a slightly reshuffled roster of the same violations seen in previous years.
Think of it in terms of this analogy. Have you ever played a game of cards and asked someone to shuffle, only to get the deck back and find just a few cards rotated? The rest of the deck is pretty much in the same order. The OSHA Top 10 list is just like this.
EHS professionals have been following these OSHA Top 10 lists for many years now, and every year, there is a strong sense of déjà vu. It’s also why discussing this Top 10 List is less illustrious than it used to be. For example, each year at the annual National Safety Council (NSC) Safety Congress & Expo, safety professionals were standing by, ready to furiously post the new list on social media as soon as it was announced. Now, there is not as much upside in scrambling to be first to confirm that the list is basically the same as the previous year.
However, there is an imperative for understanding why the OSHA Top 10 doesn’t seem to change much. By doing this, you might find insights to break the cycle, instead of just documenting its annual recurrence.
What the Top 10 OSHA List Actually Tells You
It’s easy to read OSHA’s annual Top 10 list as a compliance checklist, or as a tip off about what kinds of issues you should be looking for, so you don’t get violations, too. But both of those readings miss the point.
OSHA doesn’t publish the Top 10 to shame companies. They publish the list to highlight where systems are breaking down before incidents happen. The fact that we keep seeing almost the same list year after year means that employers are not making the progress they should be making at identifying and addressing risks.
What are employers most often getting wrong? When you look closer at the data, patterns emerge:
- Four of the top risks are tied to falls (protection, ladders, scaffolding, training)
- Training and communication failures show up repeatedly
- Employers are still inconsistent at applying basic controls, like machine guarding and PPE
On one level, you can say that these kinds of issues occur frequently because the associated regulations are widely applicable. For example, most workplaces use PITs of some kind, and most workplaces need to conduct training. On another level, you can say that the numbers game may provide context for the repeated failures but doesn’t fully explain them because all these aspects of EHS management are, or should be, fundamental.
And when fundamentals fail, it’s rarely because teams don’t care. It’s because they can’t see risk clearly or act fast enough on it. That, in turn, often stems from being stuck in a reactive safety management cycle. EHS teams often lack efficient ways of completing core tasks like incident investigations, inspections, audits, chemical management, ergonomics assessments, and contractor management, which means that to-do lists never get any shorter.
Compliance Is the Starting Line, Not the Finish Line
One of the consequences of being stuck in a reactive safety management cycle is an overemphasis on regulatory compliance. And yes, it’s a little ironic because this is a regulatory topic. However, we are doing so to make a key point that regulatory compliance alone isn’t sufficient for effective EHS risk management.
It’s not that regulations are irrelevant to compliance. The whole reason that OSHA and other agencies issue regulations is to address common, urgent hazards and risks. These regulations set a baseline for workplace safety. Even so, regulations cannot possibly address all the possible risks that may exist in a specific workplace. They can’t account for every variable, every environment, or management decision happening on the ground.
And regulations aren’t built to keep pace with how quickly work is changing, the impact of technology, new pressures on productivity, or the accumulation of new knowledge about best practices. Risk evolves faster than regulations ever will.
The reality is:
- Not every hazard is addressed by a regulatory standard, and in many workplaces, most are not.
- Not all scenarios map onto a rule.
- Not every risk is visible during an enforcement inspection.
In fact, some of the most serious incidents come from the gaps in between regulatory requirements. The key is to move beyond compliance, toward a proactive safety management system focused on identifying and controlling risks. But how can you do that?
The Real Risk: Over Reliance on Lagging Indicators
One of the most central ways to break out of the reactive safety management cycle is to shift from a primary focus on lagging indicators to a balanced set of metrics with well-chosen leading indicators.
To understand why, you first need a better understanding of the difference between leading and lagging indicators, and the difference between effective and ineffective leading indicators on the other.
Lagging indicators tell you what has already happened. Leading indicators help you prevent what hasn’t happened yet.
It’s important to understand that not all leading indicators are equally effective. OSHA has provided SMART principles for selecting good leading metrics, which translate to:
Specific: Does the leading indicator spell out details on the actions you’ll be taking to improve safety? Details are critical and you won’t likely be able to use leading indicators successfully without that level of specificity.
Measurable: You need to be able to measure and track your leading indicators to assess their impact.
Accountable: Think of “accountable” as a synonym for “relevant” here. In fact, think of relevance as the engine of accountability. If you don’t select leading indicators that influence safety outcomes, you’re not going to get the results you’re hoping to see.
Reasonable: Is it feasible to complete the actions your leading indicators say you’ll complete? If not, there’s no point in selecting them.
Timely: Can you measure your leading indicator often enough, with regularity, to spot important trends?
Based on these criteria, you can think about examples of leading metrics that would check all the boxes. One leading indicator would be potential for severe injury and fatality (PSIF) risks. Rates of severe injuries and fatalities have fallen only slightly in comparison to declining rates for all other injuries, which is a good indication that despite the earnest efforts of safety professionals, many significant risks go unaddressed.
Further, it can be very hard to pinpoint these PSIF risks within incident data because only 20% or less of all incidents have associated PSIF risk, and those risks often exist in the records of less severe incidents like near misses/close calls.
If you could identify and track PSIFs easily, taking subjectivity and time burdens out of the equation, you could track PSIF risk trends over time, and confirm that your safety program is identifying and controlling the most significant workplace risks. In other words, the leading indicator would be as accountable as can be, it would be timely, it would be measurable, and it would be specific. However, it would not necessarily be reasonable because in the absence of tools, it would be very difficult to assess and track PSIF risks. More recently, though, purpose-built AI-powered PSIF detection.
Putting it another way, the biggest challenge for most organizations isn’t knowing OSHA requirements. Instead, it’s struggling with:
- Identifying hazards before an inspection, or an incident
- Connecting data across sites, teams, and systems
- Turning insights into action quickly
That gap between knowing and doing is where risk lives. That’s where more incident management software that enables robust tracking of leading indicators can help. Go further and investigate the ways that EHS software with advanced dashboards and reporting can help you access the metrics you most need to see, including data on incident trends, operational risk assessments, and PSIFs and associated avoided costs for addressing them. With the ability to access these key data points in real time, you can finally start getting ahead of risks.
You Don’t Just Need More Training. You Need Better Training.
EHS professionals generally know that training is important. It would be hard not to know that because more than 100 OSHA standards, including HazCom, and powered industrial truck (PIT) regulations, contain specific training requirements. Most EHS teams also do plenty of training and can document that it gets done, even if there are often issues, like lower completion rates and gaps in knowing which employees should receive specific types of training.
But OSHA’s Top 10 makes one thing clear: More of the same isn’t moving the needle. The same violations recur every year, showing that training isn’t slowing them down. Not only that, but many of these violations also directly involve training deficiencies, which confirms that companies are not doing enough to improve their training programs.
EHS teams need to treat training as just one more regulatory homework assignment and tap into its transformative power on safety management systems. Training is one of the most fundamental ways you can ensure that employees understand workplace risks, whether or not they are associated with specific regulatory requirements.
Here are some of the major ways that training is central to safety management, over and above regulatory compliance.
#1: Training Reduces Rates of Injuries and Illnesses
When employees understand how to identify hazards, properly use safety equipment, and follow safe procedures, the likelihood of injuries, illnesses, and lost-time incidents drops significantly. A workforce trained in hazard awareness becomes a proactive first line of defense in preventing accidents.
#2: Training Strengthens Safety Culture
Training reinforces the idea that safety is a shared responsibility. Through learning, employees contribute to a culture where safe behavior is expected, recognized, and encouraged, not just enforced. This collective commitment helps prevent complacency and encourages continuous improvement in safety practices. And it is a recognized hallmark of effective safety management systems identified in international standards, such as ISO 45001.
#3: Training Improves Safety Training Performance and Engagement
Engagement in training, especially when it is tailored, interactive, and accessible, empowers workers to feel more confident and competent. Organizations that invest in training often see improvements in productivity, morale, and overall performance.
As a result, employees are more likely to want to participate in key safety management tasks, which means you’ll have more consistent feedback on hazards and potential safety improvements from the frontline workers who know workplace risks better than anyone else.
#4: Training Supports Leadership and Accountability
Training isn’t just for frontline workers. Managers and supervisors benefit from understanding their role in safety leadership, risk assessment, incident investigation, and communication, all of which strengthens organizational safety outcomes.
#5: Training Ensures You’re Actually Doing What You Should
You can think of this as an overarching benefit that intersects with the others discussed above. For example, you can’t help your employees understand workplace risks or play key roles in safety unless you train them.
Further, you won’t be able to build and sustain an effective safety culture long-term. This is because workplace safety policies are about doing things right, while culture is about doing things right every time. Lack of awareness about safety and health risks and the perception that management doesn’t prioritize safety are two of the most common reasons that workplaces fail to establish healthy safety cultures. And in both cases, better training is the cure.
To get the results you need from training and start reversing the patterns of the same risks associated with OSHA’s Top 10 repeating year after year, you need the right training program first.
Today’s EHS training needs to go beyond compliance checklists and static sessions. You need a nice, full library of ready-to-deploy course modules, covering core topics like HazCom, PIT training, personal protective equipment (PPE), and working at heights.
But you also need a modern learning management system (LMS), so you have the tools to manage, deliver, and track training programs from one centralized system. Benefits like these are the reason that software analyst Verdantix, in its recent guide, , concluded that LMSs have a key role to play in “managing all aspects of training, development, and continuous learning.”
With a true LMS, you’ll get:
- A library of engaging, expert-designed courses covering OSHA and broader EHS topics
- Support for multiple languages and learning styles
- Tools for tracking completion and performance
- Analytics to spot training gaps and compliance risks
- Customization capabilities to tailor content to unique workplace hazards and roles
Key Takeaways: Moving From Recurring Violations to Predictable Prevention
The OSHA Top 10 list shouldn’t be treated as a laundry list of violations to try to avoid and certainly shouldn’t be treated as an exhaustive list of EHS risks. The list’s real value is as a call to action to work smarter at prevention. It should be a wake-up call that reactive safety management approaches aren’t working, and that organizations need to move beyond a pure compliance focus and build a proactive safety culture.
This means:
- Seeing risk sooner before it becomes a citation, or worse. Incident management software with AI PSIF detection features can help here, and so can operational risk software with AI-powered review of job safety analysis (JSA) descriptions, identification of hazards, and recommendation of controls.
- Connecting safety data across your organization. Dashboards and reports can consolidate the metrics that matter most to you, including incident and operational risk data, and help you access it from anywhere.
- Leveling up your training program by getting a true LMS along with a library of courses.
- Summing it all up: Acting faster, with confidence, on what matters most. By seeing risks sooner, accessing key data from anywhere, and improving workplace training, you’ll be able to finally shift to a prevention-focused approach.
Remember, safety isn’t measured based on what gets caught during an inspection. Safety is a process and it should be built into how work happens every day. Make sure you have the support you need to make that a reality.
Leverage the Power of VelocityAI
Looking to finally break the cycle of unaddressed risks memorialized in OSHA’s Top 10? Partner with us.
Vēlo, powered by VelocityAI, is human-centered AI built by EHS professionals for EHS professionals. AI PSIF Insights identify and help track PSIF risks and the avoided costs of addressing them. Vēlo also uses the human subject matter expertise baked into its algorithms to help you improve incident management, from incident descriptions to root cause analysis to selection of corrective actions.
AI features in Operational Risk also offer suggestions to improve job task descriptions, identify hazards and select effective controls. When you use VelocityEHS Advanced Dashboards and Reports, you’ll have the visibility of risk you need to make more informed decisions and escape the reactive safety management cycle, so you can build resilience.
If you’re looking to improve your training, we can help you there, too. VelocityEHS Training & Learning software helps you deliver engaging courses, track compliance in real time, and ensures every employee gets the training they need when they need it. Empower your workforce, strengthen your safety culture, and simplify compliance with a solution built for modern EHS teams.
Take the first step out of the old patterns of doing things, and old results. Set up a meeting with us today.
