Deputy Director  of OSHA’s Directorate of Enforcement Programs Patrick Kapust presented the agency’s preliminary list at the National Safety Congress and Expo on September 26.

Powered Industrial trucks 1910.178 makes the TOP TEN again in 2017

Here are the Top Ten, along with the number of citations.

  1. Fall Protection – General Requirements (1926.501) – 6,072
  2. Hazard Communication (1910.1200) – 4,176
  3. Scaffolding (1926.451) – 3,288
  4. Respirator Protection (1910.134) – 3,097
  5. Lockout/Tagout (1910.147) – 2,877
  6. Ladders (1926.1053) – 2,241
  7. Powered Industrial Trucks (1910.178) – 2,162
  8. Machine Guarding (1910.212) – 1,933
  9. Fall Protection – Training Requirements (1926.503) – 1,523
  10. Electrical – Wiring Methods (1910.305) – 1,405

If you are just now reviewing your OSHA training  performance, these standards would be a great place to start.
The  items numbered 1910 are General Industry, those numbered 1926 are Construction.
Photo courtesy Staffing Talk

EHS magazine had a great post on the  overuse as abuse of PPE.

Diminished Returns, Diminished Awareness was written by John Olesky.

Apparently John is as tired as I am of seeing everyone wearing whatever they call that high-visibility neon-green regardless of their actual job, hazard, or risk.

Maybe it keeps these guys from getting hit when they are on the red carpet?


I think that this high-visibility neon-green is actually a magical talisman summoned up by the high priests/ witch doctors of safety.

It’s no coincidence that the witch doctor is using magical neon safety green…

Witch Doctor

Here’s a brief excerpt from John’s blog dealing with those neon green vests:

Vest Concerns

Why is it when I look at some construction sites, I see EVERYONE on site wearing reflective safety vests? OSHA, in 29 CFR 1926.651(d), sets forth requirements for workers who are exposed to vehicular traffic. OSHA states that “employees exposed to public vehicular traffic shall be provided with, and shall wear, warning vests or other suitable garments marked with or made of reflectorized or high-visibility material.”

And according to DOT, 23 CFR 634.3, Use of High-Visibility Apparel When Working on Federal-Aid Highways: “All workers within the right-of-way of a Federal-aid highway who are exposed either to traffic (vehicles using the highway for purposes of travel) or to construction equipment within the work area shall wear high-visibility safety apparel.”

These vests specifically were designed for use when there is some kind of vehicular traffic on or near the work site, or if heavy equipment such as a dozer or crane is moving around the site AND the workers will be exposed to the dangers of being struck by that traffic.

So I have to ask project managers and project safety managers, “Is there a danger of being hit by a ‘vehicle’ when employees are working on the 15th floor of a 30-story high rise building?” If not, then why are they required to wear reflective vests?

Amen John. And by the way, they are also wearing them in the store, the gas station, everywhere. I am seeing this neon -green assault to the eyes everywhere.  It’s become ubiquitous.

The proper PPE is not magic. It is the result of proper analysis of hazards at that occupational location.  The guy in the crane  high above doesn’t need his visibility improved to protect him from vehicular traffic.  The roofer doesn’t need a neon-green shirt, he needs fall protection. Guess which the roofer is actually wearing?

Dude- Where’s the tie off and fall protection?


As John Olesky said:

If we did a JHA correctly we would have to ask if the universal use of these vests on site truly makes the workers safe. We need to ask: Does this universal donning of safety vests even when they aren’t needed increase or diminishthe visual awareness for the heavy equipment operator or for the general public driving past the construction site?

It is my belief that the over use of these vests actually will diminish the safety factor that these vests originally intended for both the workers and for the general public.

Do the Hazard Analysis. Require appropriate PPE for the involved employees.

Avoid the if it’s good for one, it’s good for many approach.

After all safety ain’t magic.


Safety isn’t shamanism. It isn’t about magic. It’s about critical thought.

Critical thought- like requiring high visibility clothing- ONLY for those who would be protected by it.

What irks you about the perception of magical safety solutions?

Thanks to EHS Today for sharing John Olesky’s great post.

Please note that these  Top Ten Citations are for all industries (including construction), not just Precision Machining.

This Top 10 list is nothing to laugh at...

Fall protection – 7,139 violations.

Scaffolding – 7,069 violations. 37 fatalities.

Hazard communication – 6,538 violations.

Respiratory protection – 3,944 violations.

Lockout/tagout – 3,639 violations.

Electrical – wiring methods – 3,584 violations.

Powered industrial trucks – 3,432 violations.

Ladders – 3,244 violations.

Electrical – general – 2,863 violations.

Machine guarding. Number of citations not published, last year there were 2,364 violations.

If you get a visit from OSHA, you can bet they will be taking a look at the items on this list.

And here’s an employers rights guide from OSHA that will tell you what to do after their visit.