If you compiled an annual list of the top OSHA sign, label, tag and marking violations, you would quickly discover that the same violations keep popping up. If this trend holds, then a list of the top marking violations may give you a good place to start when assessing your marking needs. Not only will you raise the level of protection you provide your employees, but you could reduce your chances for a citation. Take a look at the top ten OSHA marking violations for 2005:

1) §1910.1200(f)(5)(i), Hazcom identity label
2) §1910.303(b)(2), Electrical equipment label
3) §1910.1200(f)(5)(ii), Hazcom hazard warning
4) §1910.303(f), Electrical, identify disconnect and circuits
5) §1910.22(d)(1), Load markings
6) §1910.37(b)(2), Exit sign
7) §1910.147(d)(4)(i), Lock/tag application
8) §1910.147(c)(5)(i), Lock/tag provided by employer
9) §1910.146(c)(2), Confined space posting
10) §1910.37(b)(4), Directional exit sign

Hazard communication labels

With over 3 million facilities covered by the Hazard Communication (Hazcom) Standard §1910.1200, it makes sense that a lot of employers wind up with hazcom labeling violations. This label is probably the most important part of any hazcom program because it is the most immediate source of chemical information. Paragraph (f)(5)(i) calls for employers to ensure that containers of hazardous chemicals are labeled with the chemical identity, while paragraph (f)(5)(ii) calls for appropriate hazard warnings. Together, these labeling items are intended to provide a snapshot to remind employees that the chemicals are hazardous.

Electrical labels and markings

Electricity is such an integral part of our lives, we often take its power for granted. However, hundreds of deaths result from electrocution in the workplace each year. Checking your electrical equipment for an “approved” marking and ensuring your employees use the equipment in conformance with that approval may be one of the most critical things you can do as an employer. Also, keeping durable and legible markings on your disconnecting means and circuits, unless obvious, would be next. That may be why these requirements, found at §1910.303(b)(2) and (f) are the number two and four marking violations.

Load marking

In order for your employees to avoid overloading mercantile, business, industrial or storage floor surfaces, OSHA’s §1910.22(d)(1) requires that load limits be posted in a conspicuous place, by a local government official who is responsible for enforcing the local building codes. If a plate is lost, removed or defaced, you must replace it. Generally, however, OSHA does not require load limit signs in office space, lunchrooms, showers, restrooms or locker rooms.

Exit signs

While OSHA’s 2002 final rule on exit routes says that the agency rewrote the requirements in clearer language so they will be “easier to understand,” the fact is that general exit sign violations at §1910.37 dropped only slightly, but remain in the top ten. Each of your exits must be marked with a clearly visible sign that reads “Exit.” Where a way to reach an exit is not immediately visible to your employees, you have to mark the access to these exits with readily visible directional exit signs.

Energy control tags

Lockout/tagout violations under §1910.147 can be OSHA’s costliest violations. You must provide locks, tags or other hardware for isolating, securing or blocking machines or equipment from energy sources. Under lockout and tagout procedures, authorized employees must affix lockout or tagout devices to each energy isolating device. Make sure your tagout devices identify the user and are durable, standardized by print and format, and substantial enough to prevent removal.

Confined space posting

Once you have determined a permit-required confined space exists, you are obligated by §1910.146(c)(2) to inform exposed employees before the next entry. Signs should be your principal method of warning, but alternative methods, such as additional training, may be used where they are truly effective in warning all employees who could reasonably be expected to enter the space. Moreover, if your space has a locked entry cover or panel, or an access door that can only be opened with special tools, signs may not be necessary if you inform all your affected employees about such a space, and they know that the space is not to be opened without taking proper precautions – including posting temporary signs – to restrict unexpected or unknowing entry.

Beyond the top ten

While the top ten can be predictable, they are not locked in, so it’s worth mentioning what’s found immediately following the top ten:
  • §1910.37(b)(5), Not an exit sign
  • §1904.32(b)(3), Annual summary certification
  • §1910.178(a)(4), Powered industrial truck plate modification
  • §1910.178(a)(6), Legible powered industrial truck marking
  • §1910.176(a), Aisle marking
Armed with the top ten-plus OSHA marking violations, you should be able to focus on some of the major marking offenses. While it may be impossible to eliminate all OSHA marking violations, you now have a place to begin.