Every year, the Occupational Safety and Health Administration (OSHA) announces the Top 10 most frequently cited workplace violations. The newest Top 10 list for the 2023 fiscal year, in this case from October 1, 2022 to September 30, 2023, was recently released.
OSHA’s annual list includes violations from several industry segments including construction and general industry, with printing falling under the latter category. The top 10 violations for printing were isolated from OSHA’s violation statistics, and this list should be used by printing operations to ensure their safety program addresses the most common shortcomings identified by OSHA.
The Top 10 violations for the printing industry are:
- Lockout/Tagout (29 CFR 1910.147) The lockout/tagout 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.
- Machine guarding (29 CFR 1910.212) OSHA has several standards to protect employees from exposure to hazards such as, ingoing nip points, points 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.
- Hazard communication (29 CFR 1910.1200) OSHA’s Hazard Communication Standard (HCS) requires 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.
- 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.
- Respiratory protection (29 CFR 1910.134) If respirators are required to be used by employees, there are specific steps that must be followed such as a written program, medical evaluation, fit testing, cleaning, proper storage and employee training. Fit testing and employee training must be performed annually. 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, N-95 respirators, and elastomeric respirators (e.g. the ones with cartridges) requires that employees be given a copy of Appendix D of the standard. Those using elastomeric respirators also require a partial written program that addresses medical evaluation and care and use of respirators and a medical evaluation.
- Electrical safety - wiring methods, components, and equipment for general use (29 CFR 1910.305) This regulation covers requirements for facility wiring, cabinets, boxes and fittings, switches, conducts, enclosures for damp and wet location, and has many provisions. Among the prohibitions in this regulation is using extension cords for permanent wiring and damaged cords. It also requires breaker identification and labeling, not allowing open slots in breaker boxes, missing knockouts in junction or breaker boxes, and having proper pendant drops for portable equipment.
- 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 (PPE) is required to protect employees from injuries. In addition, employers are required to provide PPE and provide employee training in its proper use. Failure to conduct and certify the assessment is a commonly overlooked requirement.
- Electrical safety – general (29 CFR 1910.303) This regulation contains many technical requirements and addresses methods, components, and equipment. It requires electric equipment to be free from recognized hazards that are likely to cause death or serious physical harm to employees and that includes guarding when live parts are exposed for inspection or service. The most-cited paragraph is proper use of equipment which mandates “Listed or labeled equipment shall be installed and used in accordance with any instructions included in the listing or labeling.” This can cover things like improper installation of an electrical box, but OSHA has also cited companies for things such as improperly using power strips, or allowing employees to use outlets that were not correctly installed. Another common violation is the failure to maintain access and working space around electrical equipment, which is usually three feet for most printing operations.
- 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 shafts. Failure to provide a physical guard to prevent employee contact with these moving machine parts is a common violation.
- Eye and face protection (29 CFR 1910.133) This standard is part of the PPE standard, and it requires that all employees who are exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation, are provided and use appropriate eye or face protection. Side eye protection is required when there is a hazard from flying objects. Notably, the employer does not have to pay for prescription eyewear. Common violations include not identifying the hazards and failing to require employees to wear eye and face protection. If a hazard is identified, wearing eye and face protection is mandatory.
For fiscal year 2023, there was a shuffling of the top five, but the most cited violations tend to remain consistent from year to year. One new regulation on the Top 10 list this year is eye and face protection. When OSHA revised the standard in 2012, they changed the hazard assessment for corrosive materials and many materials such as certain inks and coatings that were not previously considered corrosive, now have a corrosive pictogram on their label. When this appears on a product label, protective eye and face protection is required when the employee works with the product.
Three regulations addressing machine safety - lockout/tagout standard and two for machine guarding remained as some of the most frequently cited standards. These standards are also a priority for OSHA as the printing industry is still considered a high hazard industry for amputations.
Due to the severe injuries associated with equipment, such as amputations, crushing, and broken bones, citations for not meeting lockout/tagout and machine guarding requirements remain common. For lockout/tagout violations, OSHA noted the lack of a written program, energy control procedures, and employee training requirements not being met.
Having proper safety procedures, training, and documentation of the training is an important part of any safety program. PRINTING United Alliance has a lockout/tagout template that members can download for free and the iLEARNING+ Center offers two courses on lockout/tagout and one on machine guarding that can be used for safety training. The Alliance strongly recommends members utilize these resources to help reduce or eliminate citations in these areas.
Hazard communication addressing chemical safety remains in the top five of all violations. The most cited violations under the hazard communication standard are the lack of a written program, no employee training, not having Safety Data Sheets (SDS) for all chemicals, and no secondary chemical container labeling. The Alliance has a sample written program that can be downloaded for free and has a training course in the iLEARNING+ Center that can be used to fulfill the training requirements.
Given the serious nature of these violations, the average penalty being imposed on printing operations remains high, ranging from $7,000-$10,000 for each violation. The highest penalty that can be imposed for a violation is $16,131. In the case of a repeat or willful violation, however, the maximum penalty can reach $161,323 for each violation.
When conducting an inspection, OSHA tends to find multiple violations, and under the current enforcement guidance, field offices are instructed to essentially itemize each violation and assign the maximum penalty. It is OSHA’s position that the penalties are not high enough to provide an incentive for companies to comply with the regulations. Even though OSHA can reduce penalties for small businesses, many citations for printing operations will start with a total penalty range of $40,000-$45,000 and can be much higher for larger printing operations.
The Top 10 list gives safety managers an effective way to review existing safety programs or to create new safety programs. Focusing your safety program to address these common deficiencies will help prevent injuries, citations, and penalties.
The Alliance’s Government Affairs Department has many resources, such as written program templates, designed to assist printing operations and their compliance programs. The iLEARNING+ platform provides a new training course on machine guarding, lockout/tagout, and hazard communication. Please contact Gary Jones at gjones@printing.org or Sara Osorio at sosorio@printing.org for assistance.
In this article, Gary Jones, vice president of environmental, health and safety (EHS) affairs, PRINTING United Alliance, addresses OSHA compliance. More information about OSHA can be found at Business Excellence-EHS Affairs or reach out to Gary should you have additional questions specific to how these issues may affect your business: gjones@printing.org.
To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.