How To Cut Your Risk of OSHA Violations

Managing OSHA compliance can be a tough act.  Yet, some companies consistently have significantly fewer violations.  Here is an interesting glimpse into how they excel at OSHA compliance.

Common Characteristics in Successful Companies

The latest research shows that companies with the fewest safety and health violations have these common denominators:

Inspections and program audits.  Successful companies conduct scheduled safety inspections and program audits to identify hazards and compliance gaps.   Even simple inspection checklists can help companies reduce their risk of OSHA violations, provided they are customized for the facility and used on a regular basis.  Program audits are usually performed by seasoned health and safety experts to detect deeper and broader compliance risks.  Audits examine an entire program -- hazard identification and control, training, documentation, and recordkeeping. 

Hazard correction.  Equally important, after finding hazards, successful companies fix them in a timely fashion.  Although the real purpose of fixing hazards is to prevent costly injuries, OSHA compliance is an inevitable by-product of this effort.

Senior management support.  Top management is involved in the safety process.  They establish clear safety policies and goals, incorporate safety into business planning, assign safety and health responsibilities, provide authority and resources, and communicate openly and genuinely about safety.  This support cascades throughout the organization.

Emergency planning.  Research shows that failing to provide emergency training and investing in emergency equipment results in as many OSHA violations as any other safety area.  Perhaps emergency planning doesn't play a critical role injury prevention, but this topic is clearly on OSHA's radar since 9/11. 

Training.  Employees receive safety training to learn about and prevent hazards.  Likewise, supervisors and middle managers learn about their safety responsibilities. 

Where To Start -- Set Priorities

While all safety program elements are important, compliance with all regulations can be an overwhelming task.  With so many rules, it takes painstaking analysis to determine exactly how vulnerable you'll be if an OSHA inspector arrives at your door.  We suggest that you set priorities.

What are the highest priorities in terms of reducing injuries and your vulnerability to serious violations?  Year-in and year-out, the topics listed below are among the most frequently cited OSHA violations, and result in millions of dollars in fines.  We recommend that your hazard inspections, program audits, and training efforts focus on these areas:   

1. Guarding (machinery and power transmission devices)
2. Hazard Communication
3. Electrical Safety
4. Lockout-Tagout
5. Respiratory Protection
6. Powered Industrial Trucks
7. Bloodborne Pathogens
8. Personal Protective Equipment
9. Abrasive Wheel Machinery
10. Fire Extinguishers

NOTE: In the construction industry, the list is slightly different.  It includes fall protection (roofs, scaffolds, open-sided floors, aerial lifts, etc.) and ground excavations (trenching, cave-in protection, access/egress, etc.).

Focusing on these areas will not only lead to fewer violations, but it can significantly lower serious injury risks and reduce your insurance costs.

Three Final Suggestions

1. Make sure your injury recordkeeping log (OSHA Log) and supporting documentation is in good order.  This is the first area that OSHA will review at the beginning of an inspection.  It can make the difference between whether they decide to depart without doing an inspection, or to stay and conduct a "wall-to-wall."
2. Address any unique regulations that apply to your facility or industry.  For example:

• If your facility uses methylene chloride, beryllium, or another toxic substance, be sure you have measured employee exposures and are in compliance with the complex regulations that apply, or 
• If your facility has permit-required confined spaces, be sure to follow applicable safety procedures and invest in proper equipment and training.

3. Lastly, prepare for the inevitable OSHA inspection.  Know what to say and not say.  Know what to do and not do.  Know your rights and those of your employees.  See How To Survive An OSHA Inspection for more information.

Back to Articles