Top 2022 OSHA Violations for Printing Operations
Every year, the Occupational Safety and Health Administration (OSHA) announces the top 10 most frequently cited workplace violations. Its most recent list — the 2022 fiscal year — reflects violations recorded from Oct. 1, 2021, through Sept. 30, 2022.
OSHA’s annual list includes violations from several industry segments, such as construction and general industry, with printing falling under the latter category. The following article lists part of the printing industry’s top 10 violations. It is important to note these were isolated from OSHA’s violation statistics, and this list should be used by printing operations as a guide to ensure their safety program is addressing the most common shortcomings that are being identified by OSHA.
A Few of the Top Violations
While the full top 10 list of violations for the printing industry — and our observations — are available to PRINTING United Alliance members on printing.org, here are violations 6-10:
- Respiratory protection (29 CFR 1910.134). If respirators, other than voluntary use of dust masks or N95 respirators, are to be provided to employees, there are specific steps that must be followed. 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 and N95 respirators requires that employees be given a copy of Appendix D of the standard.
- Maintenance, safeguards, and operational features for exit routes (29 CFR 1910.37). This standard has several components addressing emergency exit routes and doors. Exit routes must be free and unobstructed. No materials or equipment may be placed, either permanently or temporarily, within the exit route. The exit access must not go through a room that can be locked, such as a bathroom, to reach an exit or exit discharge, nor may it lead into a dead-end corridor. Flammable furnishings and décor should be kept away from exit routes. Exit routes should be well lit and posted with directional signs, while “EXIT” signs must be placed at exits. Doors that are not exits but are located near exit access points should be labeled “Not an Exit,” or labeled with their use (e.g., “To Basement” or “Closet”). An emergency alarm system must be present and operational.
- Electrical safety — general (29 CFR 1910.303). This regulation contains many technical requirements and addresses methods, components, and equipment. It requires electric equipment to be free from recognized hazards that are likely to cause death or serious physical harm to employees. This includes guarding when live parts are exposed for inspection or service. The most-cited paragraph is proper use of equipment, which mandates, “Listed or labeled equipment shall be installed and used in accordance with any instructions included in the listing or labeling.” This can cover things like improper installation of an electrical box, but OSHA has also cited this for things such as improperly using power strips or allowing employees to use outlets that were not correctly installed. Another common violation is the failure to maintain access and working space around electrical equipment (usually 3 ft. for printing operations).
- Electrical safety — wiring methods, components, and equipment for general use (29 CFR 1910.305). This regulation has many provisions and covers requirements for facility wiring, cabinets, boxes and fittings, switches, conducts, and enclosures for damp and wet location. It prohibits using damaged cords, or extension cords for permanent wiring, and does not allow open slots in breaker boxes or missing knockouts in junction or breaker boxes. The regulation also requires breaker identification and labeling, and having proper pendant drops for portable equipment.
- Reporting fatalities and multiple hospitalization incidents (29 CFR 1904.39). This regulation requires employers to report to OSHA any in-patient hospitalization of an employee resulting from a work-related incident if the hospitalization occurs within 24 hours of that work-related incident, amputation, or loss of an eye. Any employee fatality resulting from a work-related incident must be reported within eight hours if the death occurs within 30 days of that work-related incident.
The Implications for Decorators
While the top 10 list for fiscal year 2022 saw some shuffling and violations resulting from a couple of new regulations, it emphasizes how having proper safety procedures, training, and documentation of the training is an important part of any safety program.
Given the serious nature of the violations, the average penalty being imposed on printing operations remains high, ranging from $7,000-$10,000 for each violation. The highest penalty that can be imposed for a violation is $13,653; however, if it is a repeat or willful violation, the maximum penalty can be $136,532 for each violation.
When conducting an inspection, OSHA tends to find multiple violations, and the citations can be very costly. Even though OSHA can reduce penalties for small businesses, many citations for printing operations will start with a total penalty range of $35,000-$40,000. The penalties can be much higher for larger operations.
The top 10 list gives safety managers an effective way to review existing safety programs or to create new safety programs. Focusing your safety program to address these common deficiencies will help prevent injuries, citations, and penalties.
The Alliance’s Government Affairs Department has many resources, such as written program templates, designed to assist printing operations and their compliance programs. The iLEARNING+ platform has a new training course on machine guarding, with more safety-related courses to be released. Please contact the Government Affairs Department at govtaffairs@printing.org for assistance.
About PRINTING United Alliance
Gary Jones is the VP of of environmental, health, and safety at PRINTING United Alliance, the most comprehensive member-based printing and graphic arts association in the United States, comprised of the industry’s vast communities. The Alliance serves industry professionals across market segments with pertinent education, training, workshops, events, research, government and legislative representation, safety, and environmental sustainability guidance, as well as resources from the leading media company in the industry – NAPCO Media. Now a division of PRINTING United Alliance, Idealliance is the global leader in standards training and certification for printing and graphic arts operations across the entire industry supply chain.
To become a member of PRINTING United Alliance and learn more about how its subject matter experts can assist your company with services and resources such as those mentioned here, please contact the Alliance membership team: 888-385-3588/ membership@printing.org.