Top Ten Cited OSHA Standards Part 1

Top Ten Frequently Cited OSHA Standards

Since i’ve been bored out of my mind waiting for a big job to break, i’ve been doing some reading on the OSHA site. Yes, i realize how much of a loser this makes me, but there are only so many videos I can watch on youtube.

Anyway, here’s a list of the most commonly cited OSHA standards. OSHA updates the list yearly, but for the most part they don’t change too much. If you’ve ever worked in construction there’s a good chance that you’ve violated at least one OSHA standard, if not many of them. My view of these comes from an industrial construction point of view, but these standards, or variations of them, also apply to other sectors like residential, commercial, mining, agriculture, or manufacturing for instance. The good news: there are no standards that are specific to welding and cutting on the list! The bad news: most of these on the list are are things that can be directly related to or done when welding and cutting!

1. Scaffolding – 1926 Subpart L – Scaffolds

This is number one for a reason. It’s a HUGE section. There are rules and guidelines for supported scaffolds, suspended scaffolds, aerial lifts – powered lifts, scissor lifts, boom lifts, etc. Scaffolding can’t be erected by just anyone, they need to be trained specifically for that task, and then it must be inspected by a competent person on a daily basis. Couple that with the fact that there are many different types of scaffolding systems, and it becomes apparent why there are companies that only erect scaffolding. Now throw in all of the different rules and regulations that govern the use of aerial lifts, and it’s easy to see why this is in the number one position. In the not too distant future, we will be required to have dedicated aerial lift operators that function much like the old elevator operators*!

*this statement may or may not have been sarcasm.

2. Fall Protection – 1926 Subpart M – Fall Protection

Another big one. How many buildings or factories have you built or worked on that were only 6 feet high? Yeah, me either. Any time that you’re over 6 feet off the ground, OSHA requires some type of fall protection. Whether it’s guardrails or a harness and lanyards, the 6 foot rule seems to be a standard across the board. That is unless of course you’re involved with residential construction, roofing, or you climb on rebar. It’s easy to get confused when there are so many special circumstances and corresponding regulations, hence the reason this section is the number 2 position.

3. Hazard Communication – Hazard Communication. – 1910.1200

The purpose of this standard is to inform employees of any potential hazards related to any chemicals that are used on the job. This includes the use of Material Safety Data Sheets (MSDS), and the labeling of all of the chemicals used. Although this is a good standard, it’s a difficult one to follow completely. It’s not that it’s hard to compile the required MSDS folder, the problem is that it’s very tough to get Joe the plumber to label the soda bottle he filled with threading fluid when the oiler broke on the pipe threader. Or Barry the welder, who mixed up some solar flux in a mountain dew bottle.

Even though they’re just examples, similar events happen every day on every job site. Unless you have dedicated safety personnel that are continually looking out for these things, most people in the field will rarely take the time and follow all labeling requirements. It’s incredibly easy to overlook these things in the field. All it would take is a surprise inspection by OSHA, and you or the company you’re working for could be facing a number of violations. Again, it’s a well intentioned standard, but unless you’ve got a good safety person, way too easy to overlook by guys in the field.

4. Lockout Tagout – 1910.147 – The control of hazardous energy (lockout/tagout)

Maybe it’s because I typically work on heavy industrial projects, but from my vantage point I don’t run across many obvious violations of this standard. It may be because the systems we work on have incredible amounts of energy associated with their operation, and all of the people involved in the operation and repair of them are so keenly aware of this that safety is our first consideration. Or it may be because they systems are so incredibly complex, that a proper LOTO requires the planning and involvement of many people. Boilers are a good example. The amount of potential energy stored in even the smallest boiler can be thought of in terms of sticks of dynamite. You just don’t mess around when it comes to stuff like this.

Typically, on large and complex systems, one single person assumes overall responsibility for the entire job. Underneath them, the individual employees will then put their locks in a lockbox, or on the subsystem that their working on. Here’s a good outline of how it works LOTO. I once worked on a job that had over 1000 people working per shift. At the start of the shift, each of these people had to lockout, and at the end they had to remove their locks. And if you forgot to remove your lock, there would be hell to pay! I’m not sure why this is so highly cited, but it’s certainly not something i’ve seen problems with on heavy industrial projects.

5. Respiratory Protection – Respiratory Protection. – 1910.134

This is definitely a big one when it comes to welding and cutting. And unfortunately, I not only see this standard violated frequently, I’m guilty of violating it myself. How many times have you lacked adequate ventilation when you were welding? If you’ve ever watched someone welding, you’ll notice that the smoke and fumes almost always waft directly up under the hood of the welder. I’ll bet that most of us that weld can identify what welding rod is being used just by the smell of it. I’m not sure that it’s something to be proud of, but it is what it is.

Add to that the cutting and grinding we do with electric grinders, and the fumes from when we use torches, and it’s easy to see why so many welders have lung problems later in life. Throw in all the dangerous materials we work around, asbestos and lead paint for instance, and it’s really amazing that any of us are still alive. Lung cancer here we come!

It’s pretty easy to see, at least from a welding standpoint why this one is on the list. So the next time you notice the taste and smell of your favorite rutile rod, do yourself a favor and get some respiratory protection. Chances are your company will provide it to you for free, why not use it?

Stay tuned for part 2

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