A Quick Review of the Top 2023 OSHA Violations for Printing Operations
Every year, the Occupational Safety and Health Administration (OSHA) announces the Top 10 most frequently cited workplace violations. OSHA’s annual list includes violations in several industry segments including construction and general industry, with printing falling under the latter category.
The most recent top 10 list for the 2023 fiscal year (October 1, 2022 to September 30, 2023) is now available. The entire list of top 10 violations in the printing industry can be found on the PRINTING United Alliance website — following you’ll find the top five to help you understand where printers are being cited.
Top 5 OSHA Violations – Printing Operations
- Lockout/Tagout (29 CFR 1910.147) – The lockout/tagout regulation protects employees from unexpected machine startups or hazardous releases during servicing and maintenance. Failing to lockout equipment, have a written program, and conducting annual inspections of machine-specific procedures are the most common violations.
- Machine guarding (29 CFR 1910.212) – OSHA has several standards to protect employees from exposure to hazards, such as ingoing nip points, drive shafts, pulleys, and other moving components. This regulation requires that physical guards are provided to protect employees from exposure and contact with hazards associated with moving parts.
- Hazard communication (29 CFR 1910.1200) – OSHA’s Hazard Communication Standard (HCS) requires information be communicated to employees about the chemical hazards they are exposed to as well as protective measures that ensure health and safety. Common citations include not having a written program, safety data sheets for all chemicals, employee training, and secondary container labels.
- Powered industrial trucks (29 CFR 1910.178) – Employees that operate forklifts or other industrial-powered vehicles must be initially trained, certified, and reevaluated every three years. Violations include improper vehicle use, lack of training, and failing to recertify operators at the required cadence.
- Respiratory protection (29 CFR 1910.134) – If respirators are required for employees, there are specific steps that must be followed such as a written program, medical evaluation, fit testing, cleaning, proper storage, and employee training. Fit testing and employee training must be performed annually. Failing to establish a written respiratory program was one of last year’s most common violations, followed by the failure to provide proper medical evaluations to those using respirators. Voluntary use of dust masks, N-95 respirators, and elastomeric respirators (e.g. the ones with cartridges) requires that employees be given a copy of Appendix D of the standard. Those using elastomeric respirators also require a partial written program that addresses medical evaluation and care and use of respirators and a medical evaluation.
Note: The regulations addressing machine safety — lockout/tagout and machine guarding — remained among the most frequently cited standards. Over the two years, there has been a sharp focus on these two regulations as they apply to automatic screen presses. Printing operations with this type of equipment are encouraged to perform a critical review of their equipment to ensure the regulations are being met because the penalties for noncompliance can be significant.
Given the serious nature of all these violations, the average penalty being imposed on printing operations is high, ranging from $8,000-$12,000 for each violation. The highest penalty that can be imposed for a violation is $16,131. In the case of a repeat or willful violation, the maximum penalty can reach $161,323 for each violation.
Alliance Resources – Safety and Training
For fiscal year 2023, there was a shuffling of the top five, but the most cited violations tend to remain consistent from year to year. One new regulation on the top 10 list this year is eye and face protection.
Having proper safety procedures, training, and documentation of the training is an important part of any safety program. PRINTING United Alliance has templates that members can download for free, and the iLEARNING+ Center offers two courses on lockout/tagout, one on machine guarding, and one for hazard communication that can be used for safety training. The Alliance strongly recommends members utilize these resources to help reduce or eliminate citations in these areas.
Please contact Gary Jones at gjones@printing.org or Sara Osorio at sosorio@printing.org for assistance.
In this article, Gary Jones, vice president of environmental, health and safety (EHS) affairs, PRINTING United Alliance, addresses OSHA compliance. More information about OSHA can be found at Business Excellence-EHS Affairs or reach out to Gary should you have additional questions specific to how these issues may affect your business: gjones@printing.org.
To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588/membership@printing.org.