The Most Common Regulatory Violations Found During An H&S Audit
APTIM has conducted hundreds of health and safety (H&S) audits across various industries to assist clients with their compliance with Occupational Safety and Health Administration (OSHA) requirements and associated state OSHA programs, such as California OSHA. Client facilities where H&S audits have been conducted include aerospace, distribution warehouses, power generating (hydro, fossil fuel, nuclear, and distribution), automotive, general manufacturing, retail, and pharmaceutical.
Here are the most common “Baker’s Dozen” of violations discovered during APTIM’s H&S audits.
- Electrical: Live electrical equipment is insufficiently guarded, flexible cords are used in lieu of permanent wiring, power strips are daisy-chained, and equipment, such as pedestal fans, are turned on and off by plugging/unplugging the cords instead of using a switch – OSHA standards 29 CFR 1910. 305(g)(2)(i)(B) and (g)(2)(ii), 1910.305(g)(1)(iv), 1910.303(b)(2), and 1910.334(b)(1)
- Machine Guarding: Machine guarding is inadequate in that required guards on specific machines did not exist or were ineffective and machines were not secured to prevent “walking”/tipping over – OSHA standards 29 CFR 1910.212(a)(1) and (b)
- Fall Protection: Fall protection devices, primarily guard chains or rails, were absent or not used – OSHA standard 29 CFR 1910.28(b)(1)(i) and California T8 CCR 3210(a and c)
- Lockout/Tagout: Equipment specific procedures for lockout/tagout were not developed and annual evaluations of the lockout/tagout program were not performed – OSHA standards 29 CFR 1910.147(c)(4)(i) and 1910.147(c)(6)(i – ii)
- Chemical Labeling: There was no hazard warning labels on secondary containers of chemicals – OSHA standard 29 CFR 1910.1200(f)(6)(i and ii)
- Hazard Assessments: Personal protective equipment hazard assessments have not been performed and/or there is no written certification for the assessments for all tasks and jobs performed at the facility – 29 CFR 1910.132(d)
- Inspections: There is no documentation that cranes’/hoists’ chains/ropes are inspected monthly – OSHA standard 29 CFR 1910.179(j)(2)(iv)
- Grinder Safety: Work rests are not positioned within ⅛ inch of the grinder wheels, OSHA standard 29 CFR 1910.215(a)(4)
- Recordkeeping: OSHA recordkeeping logs are not completed accurately – OSHA standard 29 CFR 1904.29(b)(1)
- Compressor Safety: The safety valves on the compressor air receivers are not tested at regular intervals – OSHA standard 29 CFR 1910.169(b)(3)(iv)
- Forklifts: The length of forks on forklift trucks do not match the capacity plate on the truck – OSHA standard 29 CFR 1910.178(a)(4)
- Permits: Hot work permits are not completed accurately or there is missing information/signatures – OSHA standard 29 CFR 1910.252(a)(2)(iv)
- Bloodborne Pathogens: Employees in the bloodborne pathogen program have not received or declined the Hepatitis B vaccination – OSHA standard 29 CFR 1910.1030(f)(2)(i and iv)
For comparison to the common H&S violations found by APTIM auditors, the OSHA Top 10 Violations list can be found at https://www.osha.gov/top10citedstandards.
APTIM recommends that Facility H&S professionals review the list of common violations and perform your own self-audit to ensure that these common violations are not present at your workplace in order to better protect the health and safety of your employees and to be ready for an OSHA compliance audit. For more information on health and safety auditing or more details on the violations listed above, contact Harry Pullum, CIH, CSP, CIAQP, at email@example.com.
 The OSHA regulations are applicable for all states but may be a different regulation number in some states that have their own approved OSHA program.
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