Every year, the Occupational Safety and Health Administration (OSHA) announces the most frequently cited workplace violations for the year. OSHA’s newest top 10 violations span the 2021 fiscal year (Oct. 1, 2020–Sept. 30, 2021).
OSHA’s annual list includes violations from several industry segments, such as construction and general industry, with printing falling under the latter. The top 10 violations for printing were isolated from OSHA’s violation statistics. This list should be used by printing operations as a guide to ensure their safety program is addressing the most common shortcomings that are being identified by OSHA.
The list below represents the top 10 violations for the printing industry:
1. Lockout/tag-out (29 CFR 1910.147). The lockout/tag-out regulation protects employees from unexpected machine startups or hazardous releases during servicing and maintenance. Failing to lockout equipment, have a written program, and conducting annual inspections of machine-specific procedures are the most common violations.
2. Machine guarding (29 CFR 1910.212). OSHA has several standards to protect employees from exposure to hazards such as ingoing nip points, point of operation, flying sparks and chips, and other moving components. This regulation requires that physical guards be provided to protect employees from exposure and contact with the hazards associated with moving parts.
3. Powered industrial trucks (29 CFR 1910.178). Employees that operate forklifts or other industrial-powered vehicles such as pallet jacks must be initially trained, certified, and reevaluated every three years. Safety violations include improper vehicle use, lack of training, and failing to recertify operators every three years.
4. Hazard communication (29 CFR 1910.1200). OSHA’s Hazard Communication Standard (HCS) requires that information be communicated to employees about the chemical hazards they are exposed to, and protective measures to ensure their health and safety. Common citations include not having a written program, safety data sheets for all chemicals, employee training, and secondary container labels.
5. Flammable liquids (29 CFR 1910.105). The definition of flammable liquids is very broad and includes any chemical or blends of chemicals with a flashpoint below 199.4°F (or 93°C). The requirements for the classification, storage, and handling of them, such as grounding and bonding; storing in a flammable materials cabinet or specially constructed room; and the size and type container they can be stored in, depend upon the flashpoint and boiling point of the chemistry.
6. Respiratory protection (29 CFR 1910.134). If respirators, other than voluntary use of dust masks or N-95 respirators, are to be provided to employees, there are specific steps that must be followed. Failing to establish a written respiratory program was one of last year’s most common violations, followed by the failure to provide proper medical evaluations to those using respirators. Voluntary use of dust masks and N-95 respirators requires that employees be given a copy of Appendix D of the standard.
7. Walking and working surfaces (29 CFR 1910.22). OSHA’s walking and working surfaces is a broad regulation covering any area where an employee walks, stands, or works. One key requirement is that the workplace must be regularly inspected, maintained, and kept clear of tripping and hazards such as cords on the floor, sharp or protruding objects, loose boards, corrosion, leaks, spills, snow, and ice.
8. Machine guarding (29 CFR 1910.219). OSHA has several standards protecting employees from exposure to hazards from power transmission components found on equipment, including pulleys, flywheels, and drive shaft. Failure to provide a physical guard to prevent employee contact with these moving machine parts is a common violation.
9. Reporting fatalities and multiple hospitalization incidents (29 CFR 1904.39). This regulation requires employers to report to OSHA any in-patient hospitalization of an employee resulting from a work-related incident if the hospitalization occurs within 24 hours of that work-related incident; amputation; or loss of an eye. Any employee fatality resulting from a work-related incident must be reported within eight hours if the death occurs within 30 days of that work-related incident.
10. Personal protective equipment (29 CFR 1910.132). OSHA requires all employers to conduct a formal written workplace hazard assessment to determine what personal protective equipment is required to protect employees from injuries. In addition, employers are required to provide personal protective equipment and provide employee training in its proper use. Failure to conduct the assessment and certify it is a commonly overlooked requirement.
For fiscal year 2021, two new regulations that had not previously appeared in the top 10 are now listed, and those are walking and working surfaces and reporting work-related injuries and fatalities. Three regulations addressing the machine safety lockout/tag-out standard and two for machine guarding remained some of the most frequently cited standards. Having proper safety procedures, training, and documentation of the training is an important part of any safety program.
Due to the severe types of injuries associated with equipment such as amputations, crushing, and broken bones, the violations for not meeting the requirements for lockout/tag-out and machine guarding remain common. For lockout/tag-out, the lack of a written program, energy control procedures, and employee training were not being met.
Hazard communication addressing chemical safety remains in the top five of all violations. The most cited violations under the HCS are the lack of a written program, no employee training, not having safety data sheets for all chemicals, and no secondary chemical container labeling. Meeting these requirements can be met with the use of resources available at PRINTING United Alliance.
Given the serious nature of these violations, the average penalty being imposed on printing operations remains high in the $7,000–$10,000 range for each violation. The highest penalty that can be imposed for a violation is $13,653, unless it is a repeat or willful violation, where the maximum can be $136,532 for each violation.
When conducting an inspection, OSHA tends to find multiple violations, and the citations can be very costly. Even though OSHA can reduce penalties for small businesses, many citations for printing operations will start with a total penalty range of $35,000–$40,000. The penalties can be much higher for larger operations.
The top 10 list gives you an effective way to review your safety program whether you are just putting one together or have had one in place for many years. Focusing your safety program to address these common deficiencies will help prevent injuries, citations, and penalties.
PRINTING United Alliance’s Government Affairs Department has many resources, such as written program templates, designed to assist printing operations address their compliance programs. Please contact the department at govtaffairs@printing.org for assistance.
Gary A. Jones is the director of environmental, health, and safety affairs for PRINTING United Alliance. His primary responsibility is to monitor and analyze EHS regulatory activities at all domestic and some international government levels. He provides representation on behalf of the printing and specialty graphic imaging industry.
In doing so, Jones works closely with the federal and state-level Environmental Protection Agencies, Occupational Safety and Health Agency, Department of Transportation, and other agencies. He also provides membership assistance on EHS compliance and sustainability programs.