By Ruth Kiefer, ARM, Loss Control Manager

As many of you know, we base our annual safety inspections on injury trends and MiOSHA’s most common cited violations. Last year MiOSHA issued 408 general industry health citations with the average citation being $1,708, that’s $696,911 collected in health citations with regards to general industry.

For general industry Safety violations, a total of 1.38 Million was collected and 543 citations issued. So the average citation issued in 2018 was $2,555. This year MiOSHA broke down the top violations into both Health Violations and Safety Violations. If you are unsure if you have a Health or Safety violation, please ask your Loss Control consultant for more guidance on any of these violations noted below.

Listed below are the 2018 most recent general industry HEALTH violations cited by MiOSHA:

Part 430. Hazard Communication – 93 Citations Issued with $101,900 in penalties

  • Not having a written program
  • Not completing training (GHS requirements)
  • Not posting SDS Revisions
  • No labels and other forms of warning

Part 472. Medical Services & First Aid – 90 Citations with $160,800 in penalties

  • Not having adequate flushing systems that provide at least 15 minutes of continuous running flush.
  • Blocked eyewash stations that limit immediate emergency use.

Part 430. Hazard Communication – 43 Citations Issued with $92,200 in penalties

  • Not completing training on chemicals in employees work area.

Part 451. Respiratory Protection – 40 Citations issued with $55,100 in penalties

  • 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.

Part 433. Personal Protective Equipment – 36 Citations Issued with $19,100 in penalties

  • Employees not wearing safety glasses or face shields when exposed to:
    • Flying particles
    • Molten metal
    • Liquid Chemicals
    • Corrosive Materials
    • Air Contaminants
    • Radiation

Part 554. Blood Borne Pathogens – 25 Citations with $18,400 in penalties

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

Part 380. Hearing Conservation Program – 24 Citations with $67,400 in penalties

  • Not conducting Noise Monitoring.
  • 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.

Part 433. Personal Protective Equipment – 20 Citations Issued with $13,300 in penalties

  • Employees not wearing hand protection when exposed to:
    • Skin absorption of harmful substances
    • Severe cuts or lacerations
    • Severe abrasions
    • Chemical Burns
    • Irritating materials
    • Thermal burns
    • Harmful temperature extremes

Part 451. Respiratory Protection – 19 Citations issued with $28,900 in penalties

  • 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.

Part 554. Blood Borne Pathogens – 18 Citations with $37,900 in penalties

Not maintaining a list of all job classifications that are determined to be “Category A” This category is an employee that is exposed or reasonably anticipated to be exposed.

Listed below are the 2018 most recent general industry SAFETY violations cited by MiOSHA:

Part 85. Control of Hazardous Energy Sources – 108 Citations with $611,800 in penalties

  • Not having documented and utilized procedures for the control of potentially hazardous energy when employees are engages in the activities covered in this section.

Part 85. Control of Hazardous Energy Sources – 77 Citations with $106,100 in penalties

  • Not conducting training for authorized employees. They must receive training in the recognition of applicable hazardous energy sources, they type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.

Part 7. Guards for Power Transmissions – 75 Citations with $260,500 in penalties

  • Exposed belts, rotating shafts, and pulleys

Part 1. General Provisions Machine Guards and Devices – 56 violations $190,600 in penalties

  • Not providing point of operations guarding or devices to prevent the operator from entering the hazardous area during the operating cycle.

Part 21. Powered Industrial Truck – 55 violations and $146,160 in violations

  • An employer shall ensure that a highway truck and trailer are not boarded by a power industrial truck before the truck and trailer has its brakes set and not less than 2 wheels blocked or be restrained by a locking dock to prevent the trailer from movement.

Part 33. Personal Protective Equipment – 42 Citations with $69,300 in penalties

  • Employees not wearing safety glasses or face shields when exposed to:
    • Flying particles
    • Molten metal
    • Liquid Chemicals
    • Corrosive Materials
    • Air Contaminants
    • Harmful contacts

Part 1. General Provisions: Machine Guarding – 41 Citations with $135,800 in violations

  • When an employee is exposed to a hazard created by a pinch point other than the point of operation, the hazard shall be guarded or the employee protected.

Part 21. Power Industrial Trucks – 34 Citations with $36,620 in violations

  • Not providing an industrial truck license.

Part 7. Guards for Power Transmissions – 29 Citations and $84,000 in violations

  • Exposed gears, sprockets, and chain drives

Part 2. Walking Working Surfaces – 26 Citations with $46,700 in violations

  • Inadequate guard rail systems, safety net systems, or personal fall protection systems
  • Protecting employees from fall hazards
  • Unprotected sides and edges that is 4 feet or more above a lower level

This seems to be a rotating list of violations, but there are some differences this past year that correlate with the recent rule changes. If you need assistance in assessing the new Part 2 Walking Worker Surfaces please ask us, we would be happy to assist in addressing any of the above rules so that if a compliance officer stops at your door you’ll be ready. Don’t forget we also have an Alliance with MiOSHA CET and can send in one of their specialists as well to assist you with complying with any of the above safety rules. We are here to help you tackle the maze of rules and regulations, so all questions are welcome.