OSHA’s Top 10 Most Frequently Cited Standards for FY 2023
Let’s review each standard and OSHA’s guidelines and requirements as we discuss this year’s list.
- By Robert Yaniz Jr.
- Nov 08, 2023
Every year at the National Safety Council (NSC) Safety Congress & Expo, OSHA reveals its Top 10 Most Frequently Cited Standards for that fiscal year. At the 2023 event, Eric Harbin, regional administrator for OSHA Region 6, shared the preliminary data, which accounts for violations cited between Oct. 1, 2022, and Sept. 29, 2023.
The finalized numbers likely will not be released until spring 2024. As such, this data is subject to change. Bearing all that in mind, let’s take a look at OSHA’s Top 10 Most Frequently Cited Standards for Fiscal Year 2023 (FY 2023).
10) Machine Guarding
As was the case in 2022, Machine Guarding fills in the last spot on the OSHA top 10. This year’s figures saw the number of violations increase from 1,370 to 1,644 in FY 2023. Plastic products manufacturing companies were the most likely to receive a citation for machinery.
OSHA defines machine guards as “barriers which prevent access to danger areas.” Naturally, this critical safety equipment intends to shield employees from dangers posed by machinery. However, the absence or misuse of these tools can result in OSHA violations.
The OSHA standard 1910.212 outlines the requirements for machinery and machine guarding, including those that commonly require guards. Employees working with or near such machinery can encounter an array of hazards, including those associated with “rotating parts” and “sparks.”
9) Personal Protective and Lifesaving Equipment - Eye and Face Protection
Although still at number 9 on the OSHA list, the number of violations for Eye and Face Protection increased significantly. In FY 2023, the agency cited 2,074 violations, nearly 700 more than last year. The top industry cited for these protections was roofing contractors.
OSHA Standard 1926.102 mandates employers to provide suitable eye and face protection for workers exposed to hazards such as "flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors or potentially injurious light radiation."
For employees wearing prescription lenses, employers must ensure that eye protection accommodates these prescriptions or must comfortably fit over prescription glasses. Research has shown comfort, fit and ease of cleaning are paramount in boosting compliance.
8) Fall Protection – Training Requirements
Yet another entry on the list to retain its place on OSHA’s list is Fall Protection - Training Requirements. In FY 2023, the agency cited 2,112 violations, a rise from the previous year’s 1,556 violations. Roofing contractors were among the most frequently cited industries here too.
Educating workers on fall protection is key to decreasing the incidence of workplace deaths resulting from falls. OSHA’s standard on fall protection, 1926.503, mandates that employers implement a training program that includes guidance and strategies to govern these systems.
Even after training is complete, employers are required to maintain a written certification record of employees’ participation and completion of the program. Retraining is required if an employee demonstrates a lack of familiarity or if training or equipment becomes obsolete.
7) Respiratory Protection
Dropping from number 3 in FY 2022, Respiratory Protection slips down to number 7 with 2,481 violations. However, it was cited more in FY 2023 than the previous year, when it had 2,185 violations. Automotive paint and body shops were most likely cited for these violations.
Selecting the appropriate respiratory protection for workers, according to OSHA standard 1910.134, involves considering multiple factors to ensure safety from environmental hazards. A work environment might call for an air-purifying respirator or an atmosphere-supplying model.
OSHA’s guide on respirator selection dictates the process should include an exposure assessment to identify the type and level of hazardous exposure workers might face. Additional considerations include understanding the job site, worker characteristics, and other factors.
6) Lockout/Tagout
Often considered a subset of controlling hazardous energy, Lockout/Tagout (LOTO) remains in sixth place on OSHA’s list, though this category rose nearly 600 from 1,977 violations in FY 2022 to 2,554 violations in FY 2023. It also had the second most willful violations on this list.
OSHA’s standard 1910.147 outlines the protocols for controlling hazardous energy, including implementing an energy control program. This process prevents accidental activation of a machine during maintenance that can result in severe injuries or even fatalities.
Lockout is mandated when an energy-isolating device can be locked out, ensuring complete de-energization. When this isn’t possible, tagout may be employed if it assures full employee protection. Training in LOTO procedures is mandatory, with retraining when necessary.
5) Powered Industrial Trucks
Rising from 1,749 violations in FY 2022 to 2,561 violations in FY 2023, Powered Industrial Trucks remains at number 5. It’s one of the few categories included in OSHA’s list not to heavily factor into the construction industry. Its top industry cited was plastic product manufacturing.
OSHA Standard 1910.178 addresses safety requirements tied to “fork trucks, tractors, platform lift trucks, motorized hand trucks and other specialized industrial trucks powered by electric motors or internal combustion engines,” though not other industrial trucks or farm vehicles.
OSHA’s mandate features a comprehensive collection of provisions that govern how employers and workers use these vehicles. These mandatory guidelines include operator training and certification, pre-shift inspections, and operating environment restrictions.
4) Scaffolding
Scaffolding is at number 4 on OSHA’s list, rising one spot from its placement on the FY 2022 list. However, the number of violations increased significantly from 2,058 to 2,859 violations in FY 2023. In addition, masonry contractors were the most cited industry for this type of violation.
This OSHA standard, 29 CFR 1926.451, mandates every scaffold and its components must bear its own weight and at least four times the maximum intended load. The platform should be a minimum of 18 inches wide and equipped with a guardrail or a personal fall arrest system.
However, the installation of guardrails isn’t always required. In some cases, workers may be adequately protected even without this safety feature. OSHA’s standards underline the role of structural integrity and protective measures in preventing scaffolding-related accidents.
3) Ladders
Taking a step up from its FY 2022 placement on OSHA’s list is Ladders. In this year’s edition, Ladders racked up 2,978 violations, more than 800 more than last year’s 2,143 violations. The top industry cited for these violations was, perhaps unsurprisingly, roofing contractors.
The OSHA standard for ladders, 1926.1053, specifies protocols to ensure safety, including guidelines for various types of ladders. Ladders must not be loaded beyond their designated weight capacity, and the steps or rungs should be free of hazards that could cause slips.
If a portable ladder has defects, it should be promptly removed and clearly marked to alert workers not to use it. OSHA’s safety protocols dictate workers should always face the ladder while ascending or descending and maintain “at least one hand” on the ladder at all times.
2) Hazard Communication
With a year-over-year increase of 789 violations, Hazard Communication (HazCom) holds onto the runner-up slot among the most frequently cited violations. In FY 2023, 3,213 violations were cited, meaning these citations came up in roughly 10 percent of all OSHA inspections.
Standard 1910.1200 provides guidelines on hazard classification, establishing a HazCom program, proper labeling practices, worker training and the management of trade secrets. Safety Data Sheets (SDSs) are mandatory where chemicals are used, produced or imported.
SDSs offer detailed information on chemicals, including their hazards, first-aid measures and guidelines for storage and transportation. To remain in OSHA compliance, chemical manufacturers need to update SDSs whenever chemicals change to prevent outdated data.
1) Fall Protection - General Requirements
For the 13th year in a row, Fall Protection retains its dominance on OSHA’s list. While this accounted for 5,260 violations in FY 2022, OSHA cited 7,271 of these violations in FY 2023. Fall Protection also had the most serious violations and most willful violations during this period.
OSHA outlines several key standards to address the various safety risks that can arise in the workplace. Some preventative actions employers can adopt include installing guards for holes, guardrails and toe-boards, and harnesses, safety nets or railings where fall hazards are present.
OSHA mandates employers ensure work environments do not maintain any known dangers, keep work area floors as clean and dry as possible, provide necessary employees with no-cost PPE and make hazard training accessible to all. Yet, these violations continue to persist.
This article originally appeared in the November/December 2023 issue of Occupational Health & Safety.