By: Ruth Kiefer, MSc, ARM, Loss Control Manager

Well, it’s that time of year again when MiOSHA released their top violations for general industry at the Michigan Safety Conference. This is also where we, as loss control consultants, focus our attention when we conduct our site safety surveys at your facilities. This year they broke down the top violations into both Heath Violations and Safety Violations, we will start with the Health Violations, which you may be less familiar with. If you are unsure if you have a health violation, you may ask your loss control consultant for more guidance on any of these violations noted below.

Listed below are the 2014 most recent general industry health violations cited by MiOSHA:

1. Part 602 – Asbestos Standards for Construction – 622 Citations Issued

  • Not having an exposure assessment before starting renovation projects at your facility. Any building built before 1971 must have an asbestoses survey completed.
  • Not having proper engineering controls and work practices when renovating.

2. Part 430. Hazard Communication – 257 Citations Issued

  • Not having a written program
  • Not completing training (GHS requirements)
  • Not posting SDS Revisions

3. Part 433. Personal Protective Equipment – 120 Citations Issued

  • Employees not wearing safety glasses
  • Not having a workplace hazard assessment
  • No employee training

4. Part 603. Lead Exposure – 161

  • Not completing an exposure assessment before renovation projects at your facility. Any building built before 1971 must have a lead assessment if you are tearing down and re-constructing.
  • Not providing proper PPE when removing paint
  • Not training and having a copy of the standard for those employees doing the work.
    safety-notice

5. Part 309 Cadmium – 101 Citations

  • Not training employees of the hazards
  • Not having bio monitoring in place for affected employees
  • Not having a copy of the standard readily available for employees

6. Part 472. Medical Services & First Aid – 69 Citations

  • Not having adequate flushing systems that provide at least 15 minutes of continuous running flush.
  • Blocked eyewash stations
    first-aid-station

7. Part 451 – Respiratory Protection – 60 Citations

  • Missing written program
  • Not having a signed Appendix D. When employees voluntarily use a respirator they must complete Appendix D and this signed copy must be kept in their personnel file.
  • Not providing respiratory protection when needed.

8. Part 554 – Blood Borne Pathogens – 53 Citations

  • Not having a written exposure control plan
  • Not training employees
  • Not having an exposure determination

9. Part 11. Recording & Reporting of Occupational Injuries & Illnesses – 30 Citations

  • Not completing the 300 log – you must have one even if you didn’t have any injuries.
  • Missing information on the log – you can always ask us to review your logs when we do our visit. We will let you know if you are missing anything.

10. Part 380. Hearing Conservation Program – 19 Citations

  • Not conducting annual audiogram requirements
  • Not enforcing wearing of HPD when under the program
  • Annual training for employees under the program was not conducted – this can be tied into your annual audiogram program
  • Not having adequate records – You can tie this into your audiogram testing. A good testing company will provide the necessary recording paperwork.

Listed below are the 2014 most recent general industry safety violations cited by MiOSHA

1. Part 85 Control of Hazardous Energy Sources – 170 Citations

  • Not having a written program
  • Not having machine specific instructions when equipment has two or more energy sources
  • Inadequate training for employees

2. Part 92. Hazard Communication – 78 Citations

  • Not having a written program
  • Not conducting the GHS training for employees

3. Part 33. Personal Protective Equipment – 67 Citations

  • Employees not wearing safety glasses.
  • Not having a written program

4. Part 21. Powered Industrial Trucks – 67 Citations

  • No licenses or training of operators
  • Not having a written program

5. Part 39. Design Safety Standard for Electrical Systems – 99 Citations

  • Blocked electrical panels – not having the 36 inch clearance
  • Missing knockouts or electrical fuse gaps in boxes
  • Exposed wires
  • Using extension cords as permanent wiring
    electrical

6. Part 7 Guards for Power Transmissions – 49 Citations

  • Exposed belts, rotating shafts, and pulleys

7. Part 1. General Provisions – 92 Citations

  • Not guarding pinch points. Remember you shouldn’t be able to reach under, around, or through to access the pinch point or point of operation.
  • Air pressure at the discharge end of a portable air blow gun or air hose shall be less than 30 pounds per square inch gauge when dead-ended.

8. Public Act 154. General Duty Violation – 48 Citations

  • This is the “catch-all” The employer must furnish to each employee, employment and a place of employment that is free from recognized hazards that are causing, or are likely to cause, death or serious physical harm to the employee.

9. Part 2. Floor & Wall Openings, Stairways, & Skylights – 45 Citations

  • Open sided floor or platform that is 4 feet or more above the adjacent floor or ground level
  • Not having a toe board in place

10. Part 40. Electrical Safety Related Work Practices – 44 Citations

  • Damaged or taped extension cords or cords of plug connected equipment.