Construction Safety and
The Top 10 OSHA Citations for 2006
Written By: Ray Pirnat, CSA
Manager – Technical Services
Atlantic Environmental, Inc.
Construction safety, that is, injuries and
illnesses at construction sites, have been getting increased
attention from OSHA Inspectors. OSHA has already compiled
a Top 10 List of Citations for 2006 and half of these
are from Construction Regulation violations.. (Section
1926 of OSHA regulation)
The Construction Standards apply to all
types of construction; roads, high rises, demolition,
housing, reclamation, public works, and renovation
The Top 10 Citations
– by specific standard include the following:
1. Scaffolding (29CFR1926-451) Construction
2. Hazard Communication (29CFR1910.1200) General Industry
3. Fall Protection (29CFR1926.501) Construction
4. Respiratory Protection (29CFR1910.134) General Industry
5. Lock Out/Tag Out (29CFR1910-147) GeneraSupersexy813l
6. Powered Industrial Trucks (29CFR1910.178) General Industry
7. Electrical Wiring (29CFR1910.305) General Industry
8. Machine Guarding (29CFR1926-300) Construction
9. Ladders (29CFR1926.1053) Construction
10. Electrical (29CFR1926.402) Construction
The following is a more detailed listing
of common citations in each of these OSHA standards:
1. Scaffolding (1926.451 )
• Not having the scaffold deck fully floored
• Not having the scaffold level or capable of supporting
its designated load with the proper use of screw jacks,
• Not providing safe access for each scaffold
• Not providing proper fall, or falling object,
protection — guardrails, midrails, toe boards, screens
and debris netting
• Not having scaffold components approved by a competent
person on the job site
• Not having the scaffold inspected daily
• Coble also said access should be provided by fixed
2. Hazard Communication
• A written hazard communication program had not
been developed, implemented, or maintained (29 CFR 1910.1200(e)(1)).
• Material safety data sheets were not available
for each hazardous chemical used (29 CFR 1910.1200(g)(1)).
• Containers of hazardous chemicals did not identity
the contents (29 CFR1910.1200(f)(5)(i)).
3.Fall Protection (1926.501)
• 1926.501(b)(1) Fall protection at 6 feet
• 1926.503, Training requirements
4. Respiratory Protection (1910.134)
• 1910.134(c)(1) Failure to establish written respiratory
• 1910.134(e)(1) Failure to provide medical evaluations
to determine employee ability to use a respirator
• 1910.134(a)(2) Failure to provide respirators
According to OSHA, a lockout/tagout program must
include three basic elements.
• 1910.14(c)(1) Failure to have a written
lockout tagout program that complies with the standard
• Exposure of employees to energized machines or
equipment during service maintenance operations.
• 1910.134 (c )(7)Failure to train employees in
lockout/tagout safety procedures
• 1910.134 (c)(4) Failure to develop procedures,
document6ed and utilized for the control of potentially
hazardous energy when employees are engaged in the activities
covered by this section
1. Written procedures for controlling
hazardous energy releases from each piece of equipment.
They should describe preparation for shutdown, actual
shutdown, and equipment isolation, steps for applying
and removing lockout/tagout devices, requirements for
testing that hazardous energy has indeed been isolated,
and notification of employees.
2. Training for: "authorized"
employees who do the maintenance and servicing work and
must know how to safely isolate energy sources before
beginning work; "affected" employees who might
be working in the vicinity of a locked-out machine and
must understand the hazards of attempting a start-up;
and "other" employees who might be walking through
part of a plant where a machine is locked out.
3. Periodic audits, at least once a year,
of the overall program. This inspection must be done by
an authorized employee who is not actively involved in
the energy control procedures being inspected.
The standard does not cover normal production operations,
such as routine adjustments, which are covered by OSHA's
machine guarding standards. Also excluded are hot tap
operations involving gas, steam, water or petroleum products
where shutdown is impractical and other documented procedures
guarantee worker safety. Furthermore, the standard does
not apply to work on equipment powered through a cord
and plug when it is unplugged and the authorized employee
has complete control over the plug.
6. Powered Industrial Trucks (1910.178)
• 1910.178(i)(1) Failure to provide adequate
training, the employer must ensure that the employee is
competent to operate a powered industrial truck, as demonstrated
by successful completion of a training program and evaluation.
• 1910.178(o)(1) Failure to use only stable or safely
7. Electrical Wiring (1910.305)
• Misuse of Equipment: OSHA 29
CFR 1910.303 (b)(2) requires all electrical equipment
to be used or installed in accordance with any instructions
included in the listing or labeling
• Guarding of Live Electrical Parts:
Unguarded energized conductors pose a serious electrocution
hazard. OSHA 1910.303 (g)(2)(i) requires all energized
conductors > 50 volts within eight (8’) feet
of the floor or working surface to be guarded against
• Reverse Polarity: This condition
occurs whenever the hot and neutral electrical wires are
reversed. OSHA 1910.304 (a)(2) prohibits reverse polarity.
A receptacle tester may be utilized to verify that receptacles
are wired correctly.
Proper Use of Flexible Cords and Cables:
29 CFR 1910.305(g) addresses flexible cords and cables.
Flexible cords and cables may not be used:
• As a substitute for the fixed wiring of a structure
• Where run through holes in walls, ceilings or
• Where run through doorways, windows, or similar
• Where attached to building surfaces, or
• Where concealed behind building walls, ceilings,
Ground Fault Protection: OSHA’s
Construction Standards (29 CFR 1926) requires ground fault
protection on construction sites. 29 CFR OSHA 1926.404
(b) requires ground fault circuit interrupters or an assured
equipment grounding conductor program on all construction
sites with temporary wiring that contain 120-volt, single-phase
15 and 20 ampere receptacles
8. Machine Guarding (1926.300)
• 1926.300 (2) Failure to provide
adequate guarding in equipment that can cause injury due
to belts, gears, shafts, pulleys, sprockets, spindles,
drums, fly wheels, chains, or other reciprocating, rotating
or moving parts of equipment.
9. Ladders (1926.1053)
• 1926.1053(b)(13) The top or top step of
a step ladder shall not be used as a step.
• 1926.1053(b)(1) Not having adequate tie off of
ladder that extends less than 3 feet above upper landing
surface to which the ladder is used to gain access to.
• 1926.1053 (b)(22) Carrying an object up a ladder
that could cause the employee to loose balance and fall.
10. Electrical (1926.402 )
• Improper installation of electrical equipment
used to provide electric power and light at the jobsite.
We have 28 years of experience
in construction safety including program development,
site inspections, training, and regulatory interpretation.
Our staff includes Certified Safety Professionals and
Certified Industrial Hygienists and Field Inspectors.
For more information or a specific quotation e-mail us
or call Bob Sheriff at 800-344-4414.
References: National Safety Council: Safety & Health
Magazine December 2006
OSHA Website: www.OSHA.gov/pls/imis/citedstandard.html
Atlantic Environmental Inc
2 East Blackwell Street
Dover, NJ 07801
(973) 366-3116 Fax