Thoughts on OSHA’s Top Ten Citations for 2014

The Occupational Safety and Health Administration (OSHA) recently issued its annual report highlighting the ten most frequently cited safety violations for the past year. Three of the top ten citations during Fiscal 2014 were related to electrical safety violations.

Citations relative to the lockout/tagout of energized equipment ranked sixth on the list. Failure to implement proper electrical wiring methods ranked eighth, while failure to comply with general electrical requirements ranked 10th.

The fact that electrical safety issues held three of the top ten spots is rather remarkable, given the common knowledge – even among non-electricians – of the potential dangers of working with electricity. It’s pretty clear that virtually every “average” homeowner knows that danger lurks within their main electrical panel or their home appliances. So it really should be no surprise to plant managers and those who work daily with electrical and electrically charged components that steps must be taken to protect workers. Unfortunately, far too many employers (and workers for that matter) simply don’t realize the risk, or they take an “It can’t happen to me” attitude and then pay a heavy price for their laxity.

Given the preponderance of violations in this area, it’s also no surprise that regardless of the violation, OSHA is not shy about holding employers responsible when an employee is injured – or in the worst case killed – while on the job.

In fact, OSHA routinely cites companies not only for failure to train employees in the proper safety procedures, but also – even in cases where training was provided – for their failure to ensure that employees are actually following those procedures. This clearly shows that training is not enough: Employers are obligated to hold their employees and temporary workers accountable to practice what they learn in training.

So, what must employers and their workers know before working in electrified environments? Here is our own Top Ten list:

  • Understand electrical accidents and arc flash incidents do, indeed, happen, they CAN happen to you, and the results can be catastrophic, tragic with strong financial consequences!
  • Employers must insist on safe work practices and support electrical safety programs rather than relying on a policy that is simply in place and ignored unless “the safety person” is watching.
  • Employees MUST be adequately trained so they understand AND USE proper safety procedures.
  • Contrary to popular belief, ignoring the issue or bending the rules to save money does not save money. It simply increases your risk of liability.
  • Employees must know that their employer will hold them accountable for ignoring or violating prescribed safety procedures.
  • Relying only on Personal Protective Equipment (PPE) – while a necessary and relatively easy first step – is not sufficient protection.
  • Failure to use a permit system signed off with the understanding energized work by true definition is not normally necessary or required.
  • Procedures must be in place to lockout and/or tagout machines or equipment to “prevent unexpected energization, startup or release of stored energy.” The “stored energy” component of this requirement is something many managers overlook or don’t understand: Oftentimes, even “de-energized” machines and equipment will hold a potent charge that must be released before maintenance is performed.
  • Periodic inspections of equipment are a vital element of the safety plan.
  • Failing to properly test equipment to ensure it operates as designed.

Mitchell & Lindsey has worked with companies in 33 states to develop and implement safety improvement plans. We can also help your organization. Our services include arc-flash analysis, safety training, compliance audits and more. Give us a call at 502-682-8491 or visit us at www.MitchellandLindsey.com.

See OSHA’s list of Top 10 Citations for 2014.

See our post about OSHA’s Top 10 for 2015: “David Letterman’s got nothing on OSHA’s Top 10

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