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January 19, 2023

How to Prevent OSHA Citations and Protect Your Team

Introduction: How to Prevent OSHA Citations

Everyone deserves to feel safe at work. This isn’t a “nice to have,” like a vending machine in the breakroom. Safety at work is a necessity, not an option. Congress passed the Occupational Safety and Health act in 1970, creating the Occupational Safety and Health Administration (OSHA). The role of OSHA is to ensure safe, healthy working conditions for all workers. This consistent level of safety is managed by the standards OSHA puts into place by sector: Agriculture, Construction, Federal Agencies, Healthcare, Maritime, Oil and Gas, Warehousing, and general industries. General industry is a catch-all that ensures OSHA can oversee safe work environments for companies that may not fall under the main sectors. Now let’s talk about how to prevent OSHA citations.

OSHA Standards: Your Rulebook for Safety

The best first stop for any employer is www.osha.gov. OSHA standards are the rules an employer *must* follow to protect their employees. Some of these standards apply across all industries, but each specific sector has additional expectations for hazards unique to their work. For example, the Maritime sector has specific standards for shipyards that don’t apply to Healthcare. The first step is to go to OSHA’s website and look up the standards for your industry. You can use these quick links to access the laws and regulations that will directly impact your company:

Preventing Citations Sounds Simple… Until It Isn’t.

Let’s look at an example:

A new employee on the shop floor is using a ladder to change a light bulb. Easy, right? It’s one of the longest-standing jokes in history. However, this new employee walks up the ladder holding the fragile bulb with both hands, worried about breaking it on his first day. He reaches up, loses his balance, and falls. Not only is he injured, but this is a reportable safety incident. And guess what? Lack of fall protection (including ladder safety) is the number one most common OSHA citation.

The employer should be asking: Did I provide the training for safe ladder use? According to OSHA standard 1910.23, no employee should carry any object that could cause them to lose balance. All employees must maintain three points-of-contact on the ladder. If you didn’t know that, you have homework to do!

Lack of compliance with OSHA standards will absolutely increase the likelihood of an OSHA citation.

Recordkeeping: If You Didn’t Write It Down, It Didn’t Happen

OSHA is serious about expanding electronic submission requirements for the 300, 300A, and 301 forms. Employers with 100 or more employees in certain high-hazard industries are required to submit these logs annually. This focus on electronic submission means employers *need* to invest in electronic recordkeeping or a Learning Management System (LMS).

Why an LMS is a Game-Changer

An LMS is your all-in-one package and is crucial if you want to know how to prevent OSHA citations. Your safety team can track recordable incidents, non-recordables, and near misses directly in the software. Many LMS options include a mobile app so your team isn’t chained to a desktop to log an incident. Tracking incidents all year makes electronically submitting 300 logs painless. The software handles the formatting and submission. Investing in a good Learning Management System is a smart move.

You can check out our Learning Management System (LMS) below:

Hazard Communication (HazCom)

It’s critical to ensure your safety team has a strict understanding of the OSHA standards that impact your industry. Current Hazard Communication (HazCom) standards are always evolving. Lack of compliance opens employers to citations. Always stay current on changes to classifications, shipping requirements, and what’s needed on your safety data sheets (SDS).

Lockout Tagout (LOTO)

Lockout Tagout includes the procedures that *must* be followed when shutting down equipment for maintenance. These rules protect employees from injury or the accidental release of hazardous energy. LOTO standards are evolving to reflect computer-based controls, which is a big change from the original 1980s rules. Stay tuned to OSHA for upcoming notices of proposed rule-making (NPRM) on this topic.

OSHA Citations and How to Avoid Them

For work environments that are not in compliance, OSHA will issue a citation. A citation lists the specific law the employer violated. The citation requires the employer to “abate” the hazard, which means the issue isn’t resolved until the employer fixes it. There are varying levels of citations, each with increasing seriousness.

OSHA is Cracking Down on Repeat Offenders

OSHA is expanding its Severe Violator Enforcement Program. The new criteria focus on repeat offenders. Two willful or repeat violations that receive failure-to-abate notices will become serious violations. Follow-up inspections can be made 1-2 years after the final order. Employers can be removed from the program after 3 years of good behavior, or reduce it to 2 years if they consent to an agreement that includes a top-tier safety program based on OSHA’s Recommended Practices.

Investing in an Employee Safety and Wellness Program

This is the #1 way to stay proactive. The entire goal is to prevent injuries, illnesses, or deaths. It’s easy to get overwhelmed, so it’s best to start small and build over time. Learning how to prevent OSHA citations starts with educating your employees.

OSHA even provides a 10-step guide to get started!

Taking safety seriously means the difference between a day when everyone goes home to their families and a day when that may not happen. OSHA citations aren’t just about fines; they’re about putting your people at risk.

The Importance of Safety Inspections

Conducting safety inspections allows you to spot issues *before* they lead to an injury.

The types of inspections vary by industry, as does the frequency. For example, there should be a *daily* inspection checklist for machinery or vehicles. In addition, those vehicles require frequent, in-depth inspections to uncover maintenance needs.

Examples of safety inspections include:

OSHA enforces these rules. You can learn more about OSHA enforcement on their site.

OSHA Inspections Due to Noncompliance

OSHA inspections are the *result* of noncompliance.

All safety incidents that result in injury, illness, or death are legally required to be reported. All companies with 100 or more employees (in certain industries) are required to submit Form 300 logs yearly. Depending on these logs, a citation or inspection can be triggered. You can learn more in this OSHA Fact Sheet on Inspections.

There are six types of OSHA inspections that take priority:

  1. Imminent danger – hazards that can cause death or serious physical harm.
  2. Reported severe injuries and illnesses – fatalities, inpatient hospitalizations, amputations, or losses of an eye.
  3. Worker complaints or allegations of hazards or violations.
  4. Referrals of hazards from other federal, state, or local agencies.
  5. Targeted inspections for high-hazard industries.
  6. Follow-up inspections to check on previous citations.

OSHA typically conducts inspections without any advance notice.

This is why it’s vital to have a safety program in place that proactively trains, monitors, and implements controls to show you are correcting any violations.

OSHA can ask for a phone or onsite inspection.

For low-priority hazards, OSHA may call to get more information. The officer will request a fax providing details of the problem and your corrective actions. You have five days to respond. An onsite inspection isn’t required if OSHA is satisfied.

However, for higher-priority concerns, OSHA will conduct an onsite inspection. Without notice. The inspection consists of an officer holding an opening conference, followed by a walkthrough and record review. During the walk, the officer will point out apparent violations. *Correcting them immediately is seen as a sign of good faith!* After the walkaround, the officer will have a closing conference to discuss citations, penalties, and possible courses of action.

Conclusion: Preventing OSHA Citations

The best way to prevent OSHA citations is to create proactive safety training programs, implement inspections, and track your own incidents to see patterns. These citations don’t just cost thousands in penalties; they reflect an unsafe work culture. If OSHA is giving citations, it’s time to take a hard look at your training and policies.

Proving you’ve taken proactive measures can mean the difference between a fax report and an unannounced onsite inspection.

OSHA gets a bad rep, but in truth, they exist to create guidelines that allow all employees a safe place to work. At the end of the day, we all just want people to be safe.


Frequently Asked Questions About OSHA Citations

What is the most common OSHA citation?

Year after year, the most common OSHA citation is for Fall Protection. This is consistently on OSHA’s “Top 10” list, often followed by Hazard Communication, Respiratory Protection, and Ladder Safety. This shows that even the most basic safety measures are often overlooked.

What is the best way to prevent OSHA citations?

The single best way is to be proactive, not reactive. This means having a written safety and health program, conducting regular training, performing routine self-inspections to find and fix hazards *before* an incident occurs, and keeping meticulous records of all your efforts.

What happens if I get an OSHA citation?

If you receive a citation, you will be given a specific timeframe to “abate” (correct) the hazard. You will also be required to pay a penalty, which can range from thousands to hundreds of thousands of dollars depending on the severity (e.g., Serious, Willful, or Repeat). You must post the citation near the place of the violation to alert employees, and you have the right to contest the citation within 15 working days.

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