Top Ten Categories of OSHA Violations

OSHA recently released its most cited violations list for fiscal year ("FY") 2015. These rankings are virtually identical to the FY 2014 rankings, and both FY 2014 and FY 2015 are similar to the FY 2010 rankings. Though employers should be aware of all of their OSHA compliance obligations, it would be particularly worthwhile to pay attention to the following top four most-cited OSHA standards (FY 2010, FY 2014 and FY 2015): Fall Protection, Hazard Communication, Scaffolding and Respiratory Protection. Note that the fall-related categories (Fall Protection, Scaffolding and Ladders) are consistently ranked in the top seven.

As we move into 2016, several developments may impact the OSHA top ten violation rankings. For example, OSHA recently announced that it would institute a weighted inspection system to focus on more complex issues. And, earlier in 2015, OSHA changed its reporting requirements:

OSHA will now receive crucial reports of fatalities and severe work-related injuries and illnesses that will significantly enhance the agency's ability to target our resources to save lives and prevent further injury and illness. This new data will enable the agency to identify the workplaces where workers are at the greatest risk and target our compliance assistance and enforcement resources accordingly.[1]

Finally, employers must fully comply with OSHA's Hazard Communication Standard ("HCS")/Globally Harmonized System of Classification and Labeling of Chemicals ("GHS") by June 1, 2016. Although OSHA began enforcing the new HCS/GHS in 2013 (and violations of the HCS/GHS have consistently ranked high in the cited standards lists), OSHA is expected to increase its HCS/GHS inspections when the final compliance date takes effect in June. Consequently, more HCS/GHS citations are likely in 2016.

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[1] See https://www.osha.gov/recordkeeping2014/index.html