2024 Top 10 OSHA Violations

OSHA has released its list of most cited standards over the last fiscal year. Some of these may be familiar to you as topics that TT&S has touched on for member employees.

The Top 10 most frequently cited workplace safety standards for FY 2024 are:

1. Fall Protection – General Requirements (1926.501): 6,307 violations

2. Hazard Communication (1910.1200): 2,888

3. Ladders (1926.1053): 2,573

4. Respiratory Protection (1910.134): 2,470

5. Lockout/Tagout (1910.147): 2,443

6. Powered Industrial Trucks (1910.178): 2,248

7. Fall Protection – Training Requirements (1926.503): 2,050

8. Scaffolding (1926.451): 1,873

9. Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102): 1,814

10. Machine Guarding (1910.212): 1,541

If you're wondering where to start focusing on as far as improvements in your safety program, making sure you're up to speed in the areas on this list is a great start. If you would like assistance with this, please reach out to TT&S for support.

Fuel Storage Safety

Whether it’s for powering trucks, generators, or landscaping equipment, keeping a supply of gasoline or diesel on hand ensures smooth operations for many businesses. However, improperly stored fuel can mean serious safety risks, including fires, explosions, and environmental hazards. This guide will help you safely store small quantities of fuel to protect your employees, property, and the environment.

1. Choose the Right Containers

Using the correct container is the first step toward safe fuel storage. Many store fuel in the red plastic gas containers that you see everywhere, but not everyone knows those are not okay for businesses to use. 

 

At the very least, make sure the gas cans you're using are FM approved and/or UL listed. And if there's any chance of the container being transported in a company vehicle or being used in the field with construction, then DOT-approved cans are a must. 

 

Remember:

      •     Use certified safety cans that are FM approved and / or UL listed. The vast majority of these containers will be metal.

      •     Clearly label containers with the type of fuel inside (e.g., “Gasoline” or “Diesel”).

      •     Never store fuel in non-approved containers like plastic bottles or buckets.

2. Store Fuel in Well-Ventilated Areas

Gasoline and diesel give off vapors that are highly flammable and can accumulate if stored in confined spaces. Always store fuel in a well-ventilated area away from enclosed spaces, where vapors could ignite.

Best practices:

      •     Keep fuel containers outside, in a dedicated, well-ventilated shed, or in a flammable cabinet.

      •     Avoid storing fuel in basements, garages attached to living spaces, or other confined areas.

      •     Ensure there’s proper ventilation and airflow wherever fuel is stored.

3. Keep Fuel Away from Ignition Sources

Fuel vapors can ignite when exposed to sparks, flames, or heat sources. It’s crucial to store fuel away from anything that could cause ignition, including electrical equipment, heaters, or smoking areas.

Safety tips:

      •     Maintain at least 50 feet of distance between fuel storage and any ignition sources.

      •     Post signs indicating “No Smoking” near fuel storage areas.

      •     Store fuel away from direct sunlight to prevent pressure buildup in containers.

4. Limit Quantities Stored On-Site

It's best practice to only store the amount of fuel you need for short-term use to reduce potential risks. Storing large quantities of fuel increases the chance of accidents and makes them more severe.

Guidelines:

      •     Avoid stockpiling large quantities of fuel. Store enough for a few days or weeks based on operational needs.

      •     Regularly inspect and rotate fuel supplies to avoid keeping old, potentially unstable fuel on-site.

5. Follow Proper Fuel Handling Procedures

Handling fuel safely is just as important as storing it correctly. Ensure that all employees are trained in proper handling techniques to minimize the risk of spills, fires, and injuries.

Fuel handling dos and don’ts:

      •     Always handle fuel in a well-ventilated area and avoid skin contact.

      •     Wear protective gloves and avoid inhaling fuel vapors.

      •     Clean up spills immediately and dispose of contaminated materials properly.

6. Fire Safety Precautions

Even with all precautions in place, accidents can happen. Having fire safety equipment readily available and knowing how to respond to fuel-related emergencies is essential.

Recommendations:

      •     Install fire extinguishers rated for Class B (flammable liquids) fires near fuel storage areas.

      •     Train employees on how to use fire extinguishers and what to do in case of a fuel fire.

      •     Create an emergency response plan for fuel spills, fires, or leaks.

Fuel storage safety is a critical aspect of maintaining a safe work environment. By using the right containers, storing fuel in appropriate locations, and following best practices for handling and fire safety, you can significantly reduce the risks associated with fuel storage. Regular training and inspections will ensure your employees are always prepared to handle fuel safely.

Flammable Cabinet Basics

 

Flammable cabinets are everywhere, and that's a good thing. But everyone might be a little fuzzy on what should get stored inside them. We're here to give you the basics.

1.  Only flammable liquids should be stored inside flammable cabinets.

Sometimes, the cabinets can become a catch-all for all hazardous materials on a site, including any acids, corrosives, or other hazardous substances. However, these should not be stored together with the flammable liquids. A separate cabinet with the appropriate construction and color should be provided for these materials.

2. There are limits to the amounts of each material allowed in a cabinet. 

OSHA sets the limits as follows: "Not more than 60 gallons of Category 1, 2, or 3 flammable liquids, nor more than 120 gallons of Category 4 flammable liquids may be stored in a storage cabinet."

3. Not all flammable cabinets are created equal.

OSHA says the cabinet "shall be designed and constructed to limit the internal temperature to not more than 325 °F. when subjected to a 10-minute fire test." Look for a cabinet that is certified by an independent third party such as Underwriters Laboratory (UL) or Factory Mutual Global (FM), as well as one meets for OSHA and NFPA 30 requirements.

 4. You should avoid storing items on top of flammable cabinets.

They might be a convenient place to set items down, but doing so can pose a risk, especially storing easily combustible items such as paper or cardboard.

There you have it! You never knew you needed a blog post about a cabinet before, but things were not quite as simple as they might seem when it comes to flammable cabinets. Be sure to contact TT&S with any further questions on proper flammable cabinet use.

 

 

Little-Known Facts for HazCom Managers

 

OSHA's hazard communications (HazCom) standard is intimidating, and it changes a lot. Due to efforts to align with international regulations, OSHA makes incremental changes to the standard that can make it hard to keep up with. There are also different aspects of the standard that apply to chemical manufacturers, importers, and employers, so it can be hard to know what might apply to you.

You may also think that if you're job title isn't "hazcom manager," then you're off the hook, but if you:

• Manage or update your company's SDS's, 
• Are in charge of purchasing, 
• Or work with chemicals in your workplace,

then you might just learn something important today. Here's a few aspects of HazCom that are maybe not talked about as much and you should be aware of.

1. SDS's should be kept for 30 years after the chemical or material is no longer in use. (See this OSHA letter of interpretation.)

This one can be a shocker to many, but because SDS's can be used as exposure records as well as an inventory of current materials in use, it's not the best idea to get rid of SDS's as soon as you stop using a product. As it turns out, they are a very effective way to record the hazards an employee was exposed to. 

There is technically an alternative to storing SDS's for that long, but it might be taking the hard way out: "Employers may discard [material] safety data sheets if some record identifying the substances used, where it was used and when it was used is retained for at least 30 years." In the long run, it's probably simpler to just keep the old SDS around.

2. There's a consumer use exception for SDS's, but it's not as useful as you may think.  

Do you need an SDS sheet for every single product in the workplace? Technically no. "OSHA does not require that [M]SDS be provided to purchasers of household consumer products when the products are used in the workplace in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience." Great! Get rid of that Windex SDS, stat! 

Except, of course, it's not usually that simple. Is the employee who generally uses Windex using it for the same duration and frequency as a general consumer? Or are they in a facilities maintenance position where they may be using it for many hours a week, much more than a general consumer? If so, an SDS must be kept on file.

The same goes for any product on site. If motor oil is on site, frequency and duration of the product must be considered. Is any one employee exposed more than a general consumer would be? If there's any room for doubt, it's SDS time.

However, that does leave employers off the hook for products that employees may bring into the workplace, such as lotion or hand sanitizer to keep by a desk, or products that genuinely are used in the same manner as a general consumer.

3. All it takes is one unlabelled container. HazCom is almost always one of the top cited OSHA standards, and it's a really easy one to violate. What does it take? One spray bottle without a label can land you a citation. Remember to label your containers, and while you're at it, you want to make sure it's a compliant label too. See example of all required label elements for hazardous chemicals below.

Are there exceptions? Sure, if you transfer a chemical to a portable container for immediate use, you don't need a label. But it might not be a great idea to make a habit of it.

Remember, all of these products may not be as mild or effect-free as you may think. The HazCom standard exists for a reason.... to keep you safe from what might be sneaky effects in the products that you use every day.

Hard Hat Best Practices

 

While everyone knows what a hard hat is, and it seems pretty self-explanatory, there's a lot more beneath the surface you should know about selecting the right hard hat, how to keep them maintained properly, and when they should be replaced. Read on to learn more.

• If the manufacturer has a set expiration date, that's the date you must take the hard hat out of service.
• If there's no recommended expiration set by the manufacturer, a common timeframe is five years, although this is not a set-in-stone OSHA requirement.
  
• The recommended hard hat replacement schedule is two years if the hard hat is regularly subjected to harsh environments like sun exposure or extreme temperatures. Storing them in a temperature-controlled environment can help on this one.
• An easy test for hard hat condition is to use both hands to squeeze the hard hat’s shell inward. If you hear cracking or the hard hat ‘gives,’ then replace it.
  
• Sometimes the suspension system inside the hard hat has a different replacement schedule than the shell. Many manufacturers recommend replacing this on a yearly basis.
• This one is not always popular, but it’s best practice not to put stickers or paint on hard hats. The main gist is that it could affect the electrical protection or hide any damage or defects on the hard hat. (https://www.osha.gov/laws-regs/standardinterpretations/2009-10-27)
• Always make sure you’re using the correct hard hat for the job – there are different classes for electrical hazards and direction of hazards (above vs. above and from the side). See charts below.

 

 

(This image is from DuraLabel:  https://resources.duralabel.com/articles/osha-ansi-hard-hat-requirements)

(This image is from PowerPak.net: https://www.powerpak.net/blog/everything-you-need-to-know-about-hard-hats/)

Still not sure which hard hat is the correct type for you? Go ahead and follow this link to take a quiz: https://take.quiz-maker.com/QW2Y90M9K

If you're familiar with the TT&S safety manual, we recommend a Class E hard hat in general.

How Does your Company's Safety Program Measure Up?

 
In the broadband industry, safety isn’t just a priority—it’s a core value that can’t be compromised. But not all safety programs are created equal. They evolve over time, progressing through stages of maturity. Understanding where your safety program stands on the maturity spectrum can help you find areas of improvement and ensure your workforce is protected at all times. 

In this blog post, we'll explore how to measure the maturity of your safety program and provide suggestions for improving safety at each level.

Too long; won't read? Take this quiz to find out which stage your company is in. Personalized recommendations included: https://take.quiz-maker.com/QL3V4JR3J

1. Reactive Stage

What this looks like:

• Safety is mostly put on the backburner, or if it's considered, is mostly driven by compliance with regulations, sometimes after the threat of a citation.
  
• Incidents and accidents are often the drivers for safety initiatives.
• There is minimal employee involvement in safety processes.

How to improve at this stage:

•  Establish Basic Reporting Systems: Implement a simple incident reporting system that allows employees to easily report hazards and near-misses. It doesn't matter whether this is paper or electronic -- simple is best.
  
• Training & Awareness: Conduct basic safety training sessions to ensure all employees understand the importance of safety and their role in it. If TT&S is your training provider, great! Make sure management is attending trainings and referring to training to help bolster the points being made.
  
• Develop a Safety Policy: Create a clear safety policy that outlines the company’s commitment to safety and the responsibilities of each employee, or feel free to adopt or borrow from TT&S's rural broadband safety manual.
  

2. Compliance-Based Stage

What this looks like:

• The focus is on adhering to legal and regulatory requirements.
• Safety processes are in place, but they are often seen as a checkbox exercise.
• Employee involvement is still limited, and safety culture is weak.

How to improve at this stage:

 

• Strengthen Leadership Commitment: Encourage leaders to actively participate in safety initiatives and demonstrate a commitment to safety beyond compliance. Consider making safety the first line item of management meetings as a start.
  
• Improve Communication: Start regular safety meetings and encourage open communication between management and employees about safety concerns. If you haven't already started a near miss reporting program, now's a great time. Starting a company safety committee is great too -- make sure both management and front line employees are represented.
  
• Expand Training Programs: Introduce more comprehensive training that goes beyond compliance, focusing on hazard identification, risk assessment, and proactive safety behaviors. Attending or watching recordings of TT&S's safety leadership topics trainings would be a great start here.
  

3. Proactive Stage

What this looks like:

 

• Safety is integrated into daily operations, and there is a focus on preventing incidents before they occur.
• Employees are increasingly involved in safety initiatives, and there is a growing safety culture.
• Safety performance is monitored and used to drive continuous improvement.

How to improve at this stage:

 

• Implement a Safety Management System (SMS): Develop and implement a formal SMS that includes risk management, incident investigation, and safety performance monitoring. Does your company have formal annual reviews for employees? Consider including an annual safety goal along with their other goals that are reviewed yearly.
  
• Encourage Employee Ownership: Empower employees to take ownership of safety through involvement in safety committees and suggestion programs.
  
• Focus on Leading Indicators: Shift focus from lagging indicators (like injury rates) to leading indicators (like safety observations and near-miss reports) to predict and prevent incidents.

4. Managed Stage

What this looks like:

 

• Safety is well-managed with documented procedures and processes.
• Safety performance is systematically reviewed and improved.
• The safety culture is strong, and employees actively participate in safety initiatives.

How to improve at this stage:

• Enhance Data Analytics: Use advanced data analytics to identify trends and make informed decisions to further reduce risks. Measuring those leading and lagging indicators will get you there.
  
• Benchmarking: Compare your safety performance with industry peers to identify best practices and areas for improvement.
• Continuous Improvement: Regularly update safety procedures based on feedback and the latest industry standards (TT&S can keep tabs on that for you). Engage in ongoing training and development to keep safety practices current.

5. Integrated Stage

What this looks like:

 

• Safety is deeply integrated into the company’s values and business strategy.
• Safety leadership is demonstrated at all levels, and employees are fully engaged in maintaining a safe work environment.
• Continuous improvement is embedded in the organization’s culture, with safety performance reaching excellence.

How to improve at this stage:

• Innovate and Lead: Focus on innovation in safety practices and technologies, becoming a leader in safety within the industry.
• Share Knowledge: Share your safety success stories and best practices with the broader industry to contribute to overall industry safety improvement.
• Sustain the Culture: Continuously nurture the safety culture by recognizing and rewarding safety excellence, keeping safety at the forefront of every decision.

Assessing the maturity of your safety program is an essential step in ensuring the well-being of your workforce and the overall success of your company. By understanding your current maturity level and taking actionable steps to improve, you can create a safer work environment, reduce incidents, and foster a culture where safety is truly valued. Start where you are, and commit to continuous improvement—because when it comes to safety, there’s always room to grow.

Construction Focus Four: Fall Hazards

 

We're going to end our blog series on OSHA's "Fatal Four" hazards with a discussion on fall hazards, the last hazard in our series.

 

In the rural broadband industry, it's not uncommon for employees to find themselves working at significant heights, whether on ladders, bucket trucks, or communication towers. This high-altitude work comes with inherent risks, with falls being one of the leading causes of injury and fatality.

For rural telecom workers, the risks can be even more pronounced due to the unique challenges they face—isolated locations, unpredictable weather, and limited access to immediate emergency response. This makes prioritizing fall protection not just a regulatory requirement but an essential aspect of worker safety and productivity.

Understanding the Hazards

      1. Ladders, bucket trucks, scissor lifts

Working on any of these presents a significant fall hazard, especially in remote areas where terrain can be uneven or weather conditions hazardous. Ice, wind, or even loose soil can make footing uncertain, making the need for stable and reliable fall protection systems critical.

 

      2. Rooftop Work

While many urban telecom workers may rely on roof safety systems that are already in place, rural workers often deal with rooftops that lack such precautions. When installing or repairing rooftop equipment, there may be no guardrails or designated fall protection systems, increasing the need for personal protective equipment (PPE) and careful planning.

 

            3. Communication Towers

Rural telecom workers sometimes climb communication towers to install or maintain antennas and equipment. These towers often extend hundreds of feet in the air, and falls from such heights can be devastating. Without proper fall protection systems in place—like harnesses, lanyards, and anchor points—the risk of serious injury or death increases exponentially.

 

Key Fall Protection Solutions

To mitigate these risks, rural telecom companies should implement a comprehensive fall protection strategy that includes:

      • Personal Fall Arrest Systems (PFAS): Every worker climbing a tower or working at heights should be equipped with a PFAS, which typically includes a harness, lanyard, and an anchorage point that meets OSHA standards.

      • Guardrails and Barriers: Where possible, use physical barriers such as guardrails to prevent workers from reaching the edge of a rooftop or elevated platform.

      • Ladder Safety Devices: Fixed ladders on communication towers and poles should be equipped with safety devices, such as climbing ladder sleeves or safety cages, to prevent falls. However, if using such devices, it is absolutely essential that employers confirm safety devices are in working order with documented inspection and maintenance practices.

      • Training and Competency: Workers must be trained not only in how to properly use fall protection equipment but also in hazard identification. Routine training and refresher courses are essential to ensure workers remain competent in fall protection techniques.

      • Emergency Response Planning: In remote areas, timely emergency response is not always available. It’s crucial to have a well-established rescue plan in place, including ensuring that workers have communication devices on hand and that nearby hospitals or emergency responders are aware of the site and can provide timely assistance if needed.

Adapting to Rural Challenges

Rural environments introduce additional variables that telecom workers must consider when implementing fall protection measures. For instance, wind speed at higher altitudes on towers can make climbing more hazardous. Uneven terrain can destabilize ladders or platforms, while extreme weather conditions—common in rural areas—can further complicate safe work practices.

Rural telecom companies need to ensure that their fall protection systems are adaptable to these conditions. Regular inspections of both equipment and job sites are critical in ensuring that everything is in working order and that workers are always operating under the safest possible conditions.

By ensuring that proper fall protection systems are in place, companies can significantly reduce the risk of falls and help ensure that every worker returns home safely at the end of the day.

Construction Focus Four: Electrical Hazards

 
Following along our review of the top four hazards in construction safety, one of the most significant dangers is electrical hazards. Whether you’re climbing poles, working on underground cables, or performing maintenance on equipment, understanding and mitigating electrical risks is crucial for your safety.

Understanding Electrical Hazards

Electrical hazards in the broadband industry can arise from a few sources, including:

      1.    Power Lines: Direct contact with live power lines is a major risk. Even without direct contact, electrical arcing can cause severe injuries.

      2.    Faulty Equipment: Old or poorly maintained equipment can malfunction, leading to electric shocks or fires.

      3.    Improper Grounding: Equipment that is not properly grounded can become a hazard, especially in wet or damp conditions.

      4.    Static Electricity: Accumulated static electricity can lead to sudden discharges, potentially causing harm.

Key Safety Measures

• Conduct Thorough Inspections: 
• Before starting any work, inspect all tools and equipment. Look for signs of wear, damage, or frayed wires.
•  Ensure all equipment is properly grounded.
  
• Stay Informed and Trained:
• Regularly participate in safety training sessions.
•  Stay updated on the latest safety protocols and industry standards.
• Follow Proper Procedures:
• Always assume that power lines are live. Maintain a safe distance and use insulated tools.
•  De-energize and lock out/tag out equipment before performing maintenance.
• Be Mindful of Weather Conditions:
•   Avoid working in wet or stormy weather whenever possible, as moisture increases the risk of electrical hazards.
•  Use additional caution when working in damp environments.

Emergency Preparedness

In case of an electrical incident, you have to act quickly.

      1.    Do Not Touch: If someone is in contact with an electrical source, do not touch them directly. Turn off the source of electricity if possible.

      2.    Call for Help: Immediately call emergency services.

      3.    Administer First Aid: If trained, provide first aid such as CPR until professional help arrives.

Working in the broadband industry can be rewarding but comes with its share of risks. By understanding electrical hazards and adhering to strict safety protocols, you can protect yourself and your colleagues. Remember, safety always comes first—never compromise on the precautions necessary to ensure you return home safely at the end of the day.