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OSHA’s Top 10 Most Cited
1. OSHA’s Top 10 Most Cited
Eric Schmitz
KPA Vice President Product &
Business Development
September 20, 2013
eric@kpaonline.com
303-228-8766
2,061 Total Citations
(10/1/10 thru 9/30/11)
2. QUESTIONS
• If you have questions during
the presentation, please
submit them using the
“Questions” feature
• Questions will be answered
at the end of the webinar
3. OSHA Statistics
As compiled from October 2010 to September 2011
http://www.osha.gov/oshstats/index.html
OSHA Inspectors & Offices:
2,200 inspectors responsible for the health and safety of 130 million workers,
OSHA has 10 regional offices and 90 local area offices.
OSHA Inspections:
FY 2010 Total Federal inspections: 40,993
FY 2010 Total 18(b) State Plan inspections: 57,124
OSHA Budget:
FY 2010: $558,620,000
OSHA inspections
[source: OSHA Directorate of Enforcement Programs]
4. ENFORCEMENT IS ON THE RISE
• Top 10 citations largely the same as 2010 but with
increased frequency & penalties
NUMBER OF CITATIONS
• FEDERAL - 498
• Alaska – 19
• Arizona – 54
• California – 141
• Indiana – 5
• Iowa – 21
• Kentucky – 2
• Maryland – 28
• Michigan – 67
• Minnesota – 11
• Nevada – 20
• New Mexico – 24
• Oregon – 214
• South Carolina – 4
• Tennessee – 231
• Utah – 28
• Virginia – 171
• Vermont – 7
• Washington – 498
• Wyoming - 18
Auto Service 2011 2,061 Total Citations
(10/1/10 thru 9/30/11)
6. #10 SPRAY FINISHING USING FLAMMABLES
• Airflow
• Chemical Usage
• Ignition Sources
• Paint Room Berm
7. #9 MEDICAL SERVICES & FIRST AID
• Emergency Services
– Within 3-4 minutes
• Providing First Aid Equipment
– YES at least the ANSI min
• Training Employees on First Aid
– Do not Require!
• Blood Borne Pathogens
– Use the KPA assessment tool at:
www.kpaonline.com/ehs/osha/bloodborne-pathogens.html
8. #8 EXIT ROUTES & EMERGENCY ACTION PLANS
• Blocked Exit “Serious Violation” = $32,500
Serious Violation
“Death or Serious Physical harm is likely to
result from hazards about which the
employer knew or should have known”
• Do you have a written plan?
19. Bonus Questions
• EPA Largest Citation?
AC Section 609 Compliance
• DOT Largest Citation?
20. Bonus Questions
• EPA Largest Citation?
AC Section 609 Compliance
• DOT Largest Citation?
Improper HazMat By Air Shipments
21. Actual Dollars Paid by Dealers
Issue State Amount
Training not provided for service technicians who operate lifts
Training not provided for vehicle positioning on lifts
CO
CA
$1,875
$9,000
Inadequate ventilation in paint mixing area (sealed vent)
Medical Evaluations not completed for respirator wearers
CT
CT
$4,000
$2,800
Air lines with solid nozzle tips at 100psi in use (greater than 30psi)
Compressed air at more than 10psi used to clean clothing
IN
CA
$1,200
$5,060
110V breaker box had uncovered openings
220V breaker box had uncovered openings
240V breaker box had uncovered openings
MD
IN
CA
$650
$1,600
$4,385
Safety devices removed from in-ground lifts
Lift inspections and preventative maintenance not completed
CA
CO
$11,250
$1,875
Missing grinder tool rest NV $4,500
Floor sill at mixing room entrance less than 4 inches in height TX $1,925
Wash rack employees don’t have neoprene gloves or glasses TX $2,925
General Duty - floor not reasonably free of oil, grease or water CA $900
Unlabeled Detail bottles FL $825
22. Actual Dollars Paid by Dealers
Issue State Amount
Training not provided for service technicians who operate lifts
Training not provided for vehicle positioning on lifts
CO
CA
$1,875
$9,000
Inadequate ventilation in paint mixing area (sealed vent)
Medical Evaluations not completed for respirator wearers
CT
CT
$4,000
$2,800
Air lines with solid nozzle tips at 100psi in use (greater than 30psi)
Compressed air at more than 10psi used to clean clothing
IN
CA
$1,200
$5,060
110V breaker box had uncovered openings
220V breaker box had uncovered openings
240V breaker box had uncovered openings
MD
IN
CA
$650
$1,600
$4,385
Safety devices removed from in-ground lifts
Lift inspections and preventative maintenance not completed
CA
CO
$11,250
$1,875
Missing grinder tool rest NV $4,500
Floor sill at mixing room entrance less than 4 inches in height TX $1,925
Wash rack employees don’t have neoprene gloves or glasses TX $2,925
General Duty - floor not reasonably free of oil, grease or water CA $900
Unlabeled Detail bottles FL $825
Read through headlinesSo not only is enforcement on the rise but the focus is shifting from compliance assistance to enforcement…
Check your Manometeror other flow meter6H Rules & Chemical usage4” Lip on mixing room door that leads to another room… Designed that way but mats, cardboard or buildup on a floor can destroy compliance.
Most common violations here – ignition sources & electrocution hazards (look around flammable liquids & wet areas)Ground plug story on older grinder in body shop & employee electrocution
Often it’s employee equipment that gets a dealer in trouble here…Floor surfacesHousekeeping
This is an OSHA inspectors favorite citation… It’s not subjective and never gets overturned on appeal.
Review Compliant ElementsAverageHazcom violation $2,500 per missing element – high KPA has seen for a dealership $42,000Discuss protocol for an OSHA Hazcom inspection