Top 3 OSHA Violations Revealed

Every year, the Occupational Safety and Health Administration (OSHA) announces the Top 10 most frequently cited workplace violations. Each year PRINTING United Alliance publishes the Top 10 list for printing operations which can be found at this link.

OSHA’s annual list includes violations from several industry segments including construction and general industry, with printing falling under the latter category. The top 10 violations for printing were isolated from OSHA’s violation statistics, and this list should be used by printing operations to ensure their safety program addresses the most common shortcomings identified by OSHA.

In examining the Top 10 violations for printing each year a trend has emerged and that involves the three most violated OSHA regulations. Each year, the Top 3 most violated regulations remain the same. What can happen from year to year is that the order can change, but the regulations remain the same.

The Top 3 violations for the printing industry are:

Lockout/Tagout (29 CFR 1910.147)

The lockout/tagout (LO/TO) regulation requires specific practices and procedures to protect employees from the unexpected startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities. The LO/TO regulation has core requirements:

• Perform a hazard assessment of all equipment that is hard wired or has more than one type of energy source, such as electricity and pneumatic.
• Develop and maintain a written program that includes how employees will be protected during minor servicing and maintenance procedures and machine specific procedures for equipment that will be locked or tagged out.
• Provide lockout devices for all equipment that will be locked or tagged out.
• Conduct employee training based on responsibility under program – authorized, affected, and other.
• Perform periodic inspection at least annually and document that all authorized employees have demonstrated competency in locking out the equipment they are allowed to lockout.

Common violations being cited in printing operations include failing to lockout equipment, lack of a written program, and failing to conduct annual inspections of machine specific procedures with authorized employees.  While it is possible that some printing operations would not be required to have a LO/TO program, most do not have equipment that is purely “cord and plug”, which are excluded from the standard. This means that just about every printing company is required to have a program.

The program needs to identify activities considered minor servicing and maintenance tasks, such as makeready, clearing certain jams, performing lubrication, etc. The program also needs to train employees as to what measures are necessary to protect themselves, such as using the inch-safe-service method. Authorized employees need to be trained in machine specific procedures and undergo an annual performance review with each piece of equipment they are authorized to lockout.   

Machine guarding (29 CFR 1910.212)

OSHA has several standards to protect employees from exposure to machine hazards. The hazards include those created by point of operation, ingoing nip points, rotating parts, flying chips, sparks, drive shafts, pulleys, belts, and other moving components. This regulation requires that physical guards or other methods be provided to protect employees from exposure and contact with the hazards associated with the equipment.

The most common violations in the printing industry include not having any guards to protect from hazards, missing or broken guards, defeated interlocks (e.g., safety switches that prevent machine motion when the guard or other component is open), and not anchoring equipment that can move when it is operated.

The two biggest misconceptions about guarding are that all new equipment is properly guarded or that existing equipment is “grandfathered” and  guards are not required if they were not originally installed. OSHA’s regulations hold the equipment owner responsible for proper guarding and ensuring that all hazardous areas are guarded. It is not all that uncommon to find new equipment that is not properly guarded due to several reasons including a lack of risk assessment, different regulations in the country of origin, and adhering to traditional manufacturing practices. OSHA’s regulations do not make any distinction between when equipment was manufactured, which means existing or new equipment that is not properly guarded must be guarded or the owner will be cited and fined for a violation.

Hazard communication (29 CFR 1910.1200)

OSHA’s Hazard Communication Standard (HCS) requires information be communicated to employees about the chemical hazards they are exposed to and protective measures to ensure their health and safety. There are five main requirements to the HCS, and they are:

• Develop and maintain a written hazard communication program.
• Develop and maintain an inventory of hazardous chemicals used in the facility.
• Provide Safety Data Sheets (SDSs).
• Ensure proper chemical labeling on containers.
• Conduct employee training for every worker that could be exposed to chemical hazards in the workplace.

Common citations include not having a written program, providing safety data sheets for all chemicals, not providing employee training and no secondary container labels. Secondary containers are used when smaller quantities of a chemical are needed, the most common being a squirt bottle. The goal of the HCS is to protect workers from injuries and illnesses associated with using hazardous chemicals in the workplace. HCS compliance requires attention and active management of chemical inventories, SDS, and secondary container labels. If a full or part-time safety person is not available, one of the best approaches to achieving and maintaining compliance is to appoint a responsible employee to serve as a coordinator for the program. Without having a focus, an HCS program can quickly fall into noncompliance and can lead to citations and penalties.

For fiscal year 2023, there was a shuffling of the top five, but the three most cited violations remained the same and are consistent from year to year. The machine guarding and lockout requirements are complementary and work together to protect employees. Guards keep workers safe during normal operations, while lockout procedures protect those who must bypass guards or put themselves in a hazardous situation while they are performing certain tasks including servicing and maintenance.  Enforcing these standards is a priority for OSHA as the printing industry is still considered a high hazard industry for amputations.  Due to the severe injuries associated with equipment, such as amputations, crushing, and broken bones, citations for not meeting lockout/tagout and machine guarding requirements remain common and expensive.

Having proper safety procedures, training, and documentation of the training is an important part of any safety program. PRINTING United Alliance has a lockout/tagout template that members can download for free and the iLEARNING+ Center has two courses on lockout/tagout and one on machine guarding that can be used for safety training. The Alliance strongly recommends members use these resources to help reduce or eliminate citations in these areas.

Hazard communication addressing chemical safety remains in the top five of all violations. The most cited violations under the hazard communication standard are the lack of a written program, no employee training, not having Safety Data Sheets (SDS) for all chemicals, and no secondary chemical container labeling. The Alliance has a sample written program that can be downloaded for free and has a training course in the iLEARNING+ Center that can be used to fulfill the training requirements.

When conducting an inspection, OSHA tends to find multiple violations, and under the current enforcement guidance, field offices are instructed to itemize each violation and assign the maximum penalty. It is OSHA’s position that the penalties are not high enough to provide an incentive for companies to comply with the regulations. Even though OSHA can reduce penalties for small businesses, many citations for printing operations will start with a total penalty range of $40,000-$45,000 and can be much higher for larger printing operations.

The Alliance’s Government Affairs Department has many other safety and OSHA compliance resources, such as written program templates, checklists, safety posters, etc, designed to assist printing operations and their compliance programs. Please contact Gary Jones at gjones@printing.org or Sara Osorio at sosorio@printing.org for assistance.

In this article, Gary Jones, VP EHS Affairs, PRINTING United Alliance, addresses OSHA compliance. More information about OSHA can be found at https://www.printing.org/library/business-excellence/environmental-health-safety/safety-health  or reach out to Gary should you have additional questions specific to how these issues may affect your business: gjones@printing.org.   
 
To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.