February 2014

How a top 10 violations list can improve your safety program

By Ellis Brasch

What makes numbered lists so appealing is that they seemingly express everything you need to know about a topic in neat, ordered, numerical headlines. Lists can be short and compact or they can expand to limits set only by your desire to stop counting. For example:

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A numbered list can even improve your workplace safety program. Here's how.

Consider Oregon OSHA's "top 10 violations" for 2013. Most businesses in Oregon are required to have safety committees or safety meetings. And many - if not mmost - businesses are affected by the requirements in Oregon OSHA's hazard communication standard. Yet these rules rank No. 1 and No. 2 on the top 10 violations list, which suggests that employers' safety programs are missing some of the required elements. What are those missing elements? Let's take a look.

Safety committees and safety meetings

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Does your workplace have a safety committee or hold safety meetings? No? Are you sure that your workplace doesn't need one? You might want to check the requirements in 437-001-0765(1).

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Have the members of your safety committee been trained in the principles of accident investigation and hazard identification? No? Check the requirements for safety committee members in 437-001-0765(4).

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Is your workplace holding safety meetings at the proper intervals? You can have quarterly meetings if your employees do mostly office work. Monthly meetings are required for most other businesses. How often should your employees meet? Check the requirements in 437-001-0765(11).

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Is someone taking minutes at your safety meetings? If your employees do construction, utility work, or manufacturing, you must keep minutes of all your safety meetings for three years. Find out if the requirements apply to your workplace in 437-1-765(13).

Hazard communication

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Does your workplace need a written hazard communication program? If your employees use or may be exposed to hazardous chemicals, you probably need to prepare one. You'll find the requirements in 1910.1200(e).

If you have a written hazard communication program, make sure that you don't come short on the following key requirements. They're among the most frequently cited violations in the hazard communication standard.

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Labels and other forms of warning. Every container of hazardous chemicals at your workplace must have a label that identifies the chemical and includes information about its hazards. You need to describe in your written program how you will ensure that all the containers are properly labeled. You'll find the requirements in 1910.1200(f).

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Safety data sheets. Your workplace must have a safety data sheet for each chemical on your list of hazardous chemicals. Keep safety data sheets where they are readily available for all employees and make sure they know how to find them in an emergency. You'll find the requirements in 1910.1200(g).

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Employee information and training. In your plan, describe the training employees will receive so that they know how to protect themselves from chemical hazards and understand the information on product labels and safety data sheets. You'll find the requirements in 1910.1200(h).

What are the top 25 violations in your industry?

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You can get current lists of Oregon OSHA's 25 most-violated rules in your own industry with the Oregon OSHA top violations report. The report lets you to search for the most-violated rules by calendar year and by NAICS codes or by industry groups such as construction and manufacturing.

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You'll find the report on the DCBS Information Management Division's Workplace Safety and Health page under "Oregon OSHA Activities." Click on Oregon OSHA top 25 violations report.

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Do an audit to ensure that your business is complying with the frequently violated rules in your industry. It's easy do and will help strengthen your safety program in 2014.


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