OSHA's Top Ten Violations for the Year
Regardless of economic conditions, safety is always important and OSHA has continued to be busy looking for violations. Below is a list of the top 10 citations for fiscal year 2008 (Oct. 2007 – Sept. 2008).
- Scaffolding, general requirements, construction (9,511 total violations)
- Hazard communication standard, general industry (6,662 total violations)
- Fall protection, construction (6,652 total violations)
- Respiratory protection, general industry (3,958 total violations)
- Lockout/Tagout (3,955 total violations)
- Electrical, wiring methods (3,371 total violations)
- Powered industrial trucks (3,262 total violations)
- Ladders (2,902 total violations)
- Machines guarding – general requirements (2,862 total violations)
- Electrical systems design, general requirements, general industry (2,741 total violations)
The highest penalties assessed by OSHA for the 2008 fiscal year include:
- Fall protection, construction
- Scaffolding
- Electrical
- Control of hazardous energy
- Machines
- General duty clause
- Powered industrial trucks
- Walking-working surfaces
- Process safety management of highly hazardous chemicals
The fines imposed for these violations can be severe. For example, a year ago, OSHA initiated an investigation of KMA Manufacturing LLC in Beaver County Pennsylvania in response to an accident that occurred when six tons of stainless steel became dislodged from a crane and fell on an employee.
OSHA found 42 serious violations and four repeat violations that included failure to ensure that a swivel hook, which was used on an overhead crane, was equipped with a safety latch. Employees were also observed operating the crane without proper training. The result is that OSHA is proposing a fine of $119,400 for the combined violations.
"Safety training is one of the most important things a company can do to prevent accidents," said Bruce Kuzmanich, contract training manager for Joliet Junior College's Corporate and Community Services Division. "While safety training can't prevent all accidents, the fact that a company has provided this training can minimize the severity of OSHA fines."
To learn how Joliet Junior College can help you avoid OSHA citations and operate your business safely, call Bruce Kuzmanich at (815) 280-1512, or e-mail him at bkuzmani@jjc.edu.
Are You Compliant with the New Edition of NFPA 70E?
Changes NFPA 70E may require employers to revisit arc flash hazard assessments, change warning labels and require workers to wear different personal protective equipment.
OSHA's job is to ensure safety in the workplace, but in many cases, the agency leaves the methods for achieving safety to other standard-setting bodies. An excellent example of this is arc flash safety. OSHA requires safe work practices, but it is the National Fire Protection Association's standard NFPA 70E: Standard for Electrical Safety in the Workplace that specifies safe work practices when arc flash is a hazard.
The 2009 edition of NFPA 70E was approved and released on Sept. 5. It contains a number of important changes that require many companies to change the way they operate. These changes affect labels on equipment, arc flash hazard analyses, required personal protective equipment (PPE), calculation of the protection boundary and training requirements. No longer will it be possible to get away with postponing a full arc flash hazard analysis until some unspecified future date, nor to leave panels unlabeled under the assumption that no one will ever work on them while they're energized.
Changes To Worker Training – Addition Of CPR
Several new articles in the 2009 edition of NFPA 70E address employee training. An addition to Article 110.6 (C) requires that employees be trained in CPR and recertified annually. Article 110.6(D)(1)(d) requires that employees be retrained before performing any tasks that are performed less often than once per year. And Article 100.6 (D) (3) requires that an employee must be retrained or receive additional training under any of the following circumstances:
If the supervisor observes, or annual inspections reveal, that the employee is not following the rules and regulations.
If new technology, new types of equipment or changes in procedures necessitate the use of safety-related work practices that are different from those the employee would normally use.
If the employee must use safety related work practices that are not normally used during his or her regular job duties.
Another new requirement, 110.6(E), requires that all training must be documented and employees must show proficiency, and that the documentation must be maintained for the duration of the employee's employment.
New Arc Flash Label Requirements
New NFPA 70E Article 130.3(C) requires arc flash warning labels to include, at a minimum, the arc flash incident energy or required level of PPE.
Up to this point, putting a generic label on equipment warning workers of potential arc flash hazards would fulfill the requirements of the 2004 NFPA 70E and the National Electrical Code, both of which say that all equipment that might be worked on while energized must have an arc flash warning label. According to NFPA 70E, if you work on live equipment operating at 50 volts or more, then you must perform an arc flash hazard assessment. Even if you always de-energize equipment before working on it, an arc flash hazard assessment should be performed to determine the type of PPE to use when verifying that power is off.
Make The Label Complete
Recent changes to NFPA 70E require that equipment be labeled with incident energy or required level of PPE. It is preferable to put complete information on the label to meet documentation requirements, prevent confusion and contribute to worker safety.
It's a good practice to also include shock and flash protection boundaries, available fault current and voltage level on the label.
Performing An Arc Flash Hazard Analysis
Since equipment must now be labeled with the incident energy and required level of PPE, someone must conduct an arc flash analysis before work is done on energized equipment. This is an important change.
There is only one exception to this requirement: the 2009 Edition of NFPA 70E states that an arc flash analysis is not required if the circuit is rated 240 volts or less and is supplied by a single transformer rated less than 125 kVA.
It is important to point out that, although an arc flash assessment is not required under this exception, shock hazards remain that must be guarded. A shock hazard analysis must be performed if workers could be exposed to energized circuit parts. The shock hazard analysis determines the voltage of the live parts, shock protection boundaries (limited, restricted and prohibited) and proper shock protection PPE to be used.
Changes To Required PPE
OSHA, in 29 CFR 1910.132(d), says that the employer must assess the workplace for hazards. If hazards exist that require PPE, the employer must select the right PPE for the worker, must communicate that selection process to the worker and must select the type of PPE that properly fits the worker. In OSHA subpart S, which covers electrical workers in general industry, 1910.335(a)(1)(i) requires the employer to provide the electrical PPE and also requires the employee to use it.
Changes To Hazard Risk Category 1 PPE
Most of the changes in PPE requirements apply to Hazard Risk Category 1. In an average manufacturing facility, an estimated 80 percent of electrical work will be done in Hazard Risk Category 1 or lower.
One significant change is that standard blue jeans no longer are acceptable for use when Category 1 risks are involved. In the 2004 version of NFPA 70E, a worker was allowed to use a long-sleeved fire-resistant (FR) shirt rated for 4 calories and standard blue jeans if they had a certain weight per square yard. No one ever paid any attention to the fabric weight of the material, and fabric weight certainly wasn't marked on the blue jeans at the store.
Under the 2009 edition of the standard, for Category 1, workers must wear long pants that have a rating of 4 calories or more, and that are verified by ANSI as FR pants and labeled accordingly. When it came to headgear, under the 2004 edition of NFPA 70E, a worker could walk up to a panel and open it as long as he or she was wearing a hard hat and a pair of safety glasses. Under the 2009 edition, the worker also must wear a face shield rated for 4 cal/cm2 or higher, which attaches to the hard hat and covers the face down to the chin, or an arc-rated flash suit hood.
Joliet Junior College can assist you with training your employees in NFPA 70E. For more information, contact Bruce Kuzmanich at (815) 280-1512 or bkuzmani@jjc.edu.