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Stop the OSHA standards cheerleading

January 15, 2013
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One objection of mine to adding more OSHA standards is that the standards cited frequently (top ten in frequency) remain generally the same year to year. Sometimes they shift position in frequency order. Sometimes the numbers of citations trend up or down, but generally it all remains in a controlled range.

For example, lack of a HAZCOM written program has, as I recall, been on the Top Ten List since the HAZCOM Standard was imposed on us. How difficult is that to get done? Should not be a lot.

When I get the chance, I ask safety professional groups I speak to how many of your sites have a written HAZCOM program. All hands go up—except just recently. One hand did not go up so I was inquisitive as to why. The response was that this person had just taken on staff safety responsibilities. There had not been a written HAZCOM program but he was developing one. Just remember this when OSHA and the DC OSHA cheerleading crowd wants to impose new written program standards—such as I2P2.  All that will happen is there will be new member of the OSHA annual Top Ten citations list.

Not to bore you with data, but just to illustrate the point about the generally unchanging face of OSHA citations, here is a table of the Top Ten over the past 3 years.

Standard Cited

FY 2012

FY 2011

FY2010

Scaffolds  1926.451

7250

7069

8371

Fall Protection 1926.501

4696

7139

7559

Hazard Communication 1910.1200

3814

6538

6633

Respiratory Protection 1910.134

2371

3944

3932

Ladders 1926.1053

2310

3244

3820

Machinery & Machine Guarding 1910.212

2097

2728

2556

Powered Industrial Trucks 1910.178

1993

3432

3224

Electrical Wiring Methods 1910.305

1744

3584

3381

Lockout/Tagout 1910.147

1572

3639

3531

Electrical – General Requirements 1910.303

1332

2863

2770

These are published each year to let you know where OSHA is finding violations. But if you are reading this, you know where the issues are for your site and are working on them.

You see some downward trends in some of the numbers for 2012 but I would not assign any significance to one year’s data.

 The numbers show some minor shifting in citation frequency order, but the Top Ten in general remains the Top Ten.

The point I am making is that until these standards become more ingrained in workplaces, and therefore become much fewer in number or finally drop off the Top Ten list, there is no need for more OSHA standards for sites, particularly those estimated 7.3- 7.4 million sites with no safety staff.  

OSHA needs to work on implementation through compliance assistance at these sites for the 40+ years of OSHA standards already on the books and required.

And to my point in this column, safety would better served by OSHA increasing budget for Compliance Assistance, generating funds for that safety improvement by reducing or eliminating Safety Standards.

More OSHA standards in the face this citation data is purely a political agenda motivation rather than a genuine safety improvement motivation.

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