OSHA’s Top 10 and Human Error

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The irony of writing about OSHA’s top 10 safety violations is that, if you are reading this, your propensity for seeking safety improvements make it overwhelmingly unlikely you’ll be on OSHA’s radar anytime soon. Most OSHA violations stem from an employer disregarding general safety principles, and that’s not something you can usually say about folks who take time out of their busy schedule to read safety blogs like this one.

If a proactive safety advocate exists at a company there are likely few opportunities for citations unless he or she is having trouble getting corporate buy-in (time, budget, priority) for safety or there are issues with employees and supervisors executing the safety program that’s in place (or both). In either case, the safety pro’s bigger challenge is that of fighting everyone’s complacency with hazards and fines—the “we’re safe enough already” or “it won’t happen to us” mentality—or fighting the never-ending battle between safety and production where rushing, frustration and fatigue also need to be addressed.

For 44 years OSHA has set the national standard for safety compliance requirements. In an annual list of the 10 biggest categories of violations, OSHA publicly outlines which of its citations it has been most frequently handed out in the past year. The goal is to shine a light on the most common workplace hazards and safety violations, and in doing so encourage companies to ensure they meet the minimum standards required for a safe workplace.

For the last decade the same violations have appeared on OSHA’s top 10 list, and while the exact order is shuffled from one year to the next, the overall content of the list has remained the same. Issues like scaffolding, fall protection and lockout/tagout have a lasting place on OSHA’s list for good reason: they are the parts of the modern workplace that present some of the greatest risks of injury and they are the most susceptible to failure by critical errors or decisions clouded by complacency. As such, they are worth paying attention to even if you’re in full compliance with OSHA regulations because there is clearly more work to be done.

Learning from the areas that other organizations struggle with can help you better assess where your own employees are most at risk. Taking the opportunity to revisit your safety measures in light of OSHA’s most frequent violations will allow you to ensure you’re taking every conceivable step to stave off injury and illness. It’s worth noting that OSHA’s primary response to safety offenses is to issue fines and, in rare cases, to recommend criminal charges. But there is a huge difference between not breaking the law and being a model citizen. And as someone who has created safety rules and procedures, you know how difficult it is to ensure they are followed 100% of the time when the person governed by those rules are faced with deadlines and distractions—even if they know the risks and repercussions.

Patrick Kapust, the deputy director of OSHA’s Directorate of Enforcement Programs, recently noted in an interview with Safety+Health that, “Employers are encouraged to adopt a positive safety culture and to develop and implement a safety and health management system that will prevent or reduce workplace injuries and illnesses to the extent feasible.” It’s hardly a shocking statement, but it’s noteworthy because OSHA’s stated goal—illness and injury prevention—is only partly achievable with the tools that OSHA has in its toolbox. Inspections, fines and other punishment-oriented actions are a great way of enforcing a minimum standard of safety compliance but there is a great deal of safety that they aren’t able to effectively influence. And it’s a pretty smart statement when you think about it. Companies would be hard-pressed to “adopt a positive safety culture” if they haven’t already adopted the OSHA standards. Imagine morning meetings with “safety first” mantras if you haven’t guarded hazards and given everyone proper PPE. Compliance has to come first but it is certainly not last.

Take fall protection, for example. OSHA provides a minimum level of safety in its requirements that companies protect the sides and edges of work areas, ensure there are no holes in standing surfaces and take additional precautions when employees work on steep roofs. These measures help reduce the risk of falling but they don’t eliminate it entirely and there are a number of factors that also compromise their effectiveness. When workers are rushing they may  forgo the use of a fall arrest harness. If they are frustrated they may overreach and topple over a railing. And there are any number of small reasons that could contribute to a rule going unfollowed like a split-second decision in the heat of the moment, forgetting a critical step in a procedure or allowing a bad habit to surface over time with complacency. While safety managers are there to help catch these oversights, like OSHA’s inspectors they can only be in so many places at once. Workers need to self-regulate in these situations and it’s not easy without motivation, practice and skill.

There are a few aspects of safety that will never appear on OSHA’s top 10 list because it’s simply impossible to craft rules to govern them. Major issues like safety culture, human factors training and off-the-job safety are beyond the scope of OSHA’s inspect-and-cite approach but just because there’s no legislation on it doesn’t mean they’re not important. To establish a truly positive and proactive safety culture you need to address the full range of causes of injury, starting with the physical hazards but also including human factors and employees who lack strong personal safety skills.

Human error is the single largest contributor to injuries in the workplace. In the aviation industry, one of the most actively studied business sectors in the world, Boeing estimates that human error causes 70% of commercial airplane hull-loss accidents. In addition to eliminating and controlling hazards, OSHA’s rules are designed to protect workers once an error occurs but they are unable to prevent an error from occurring in the first place. It’s far safer when we provide workers with the training, skills and habits required to avoid  the mistakes we all make, in addition to following OSHA’s safeguarding rules. If injury prevention is our goal, both are needed—neither are optional.

The fact of the matter is that OSHA can set the minimum standard you need to meet, and set the fines for failure to comply, but it doesn’t mean that you should stop improving safety once you meet regulatory basics. Passing an OSHA inspection is a great indication that you’re taking steps to provide a safe workplace.

But keep in mind that compliance can be compromised by complacency at any time. Use OSHA’s annual top 10 to upset this complacency in your organization and go beyond compliance by addressing human factors to keep safety, rules and risk in mind when production demands steal focus from workers.