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as well as the associated information under each heading: identifification, hazard identifification, composition/information on ingredients, fifirst-aid measures, fifire-fifighting measures, accidental release measures, handling and storage, exposure controls/ personal protection, physical and chemical properties, stability and reactivity, toxicological information, ecological information, disposal consideration, transport informaiton, regulatory information and other information including date of preparation or last revision.6
You can find more information about the SDS sections and associated information under Appendix D.
Coming in at number four in the list is Scaffolding, general requirements (29 CFR 1926.451). This standard held steady at number four in comparison to the fiscal year before. The preliminary data shows that there were 1,948 violations in fiscal year 2021, which is a slight drop from 2020 which shows 2,538 violations were recorded during that fiscal year.
For this construction standard, Kapust said OSHA was finding that employers were not providing proper fall protection for their employees, did not secure scaffolds from tipping and, in certain locations, platforms were not fully planked or decked. OSHA was also finding that employers were not installing guardrails as a means of fall protection for workers. These issues were most commonly found with masonry contractors, framing contractors and roofing contractors.
According to the standard, employers must provide fall protection for each employee on a scaffold more than 10 feet above a lover level. When it comes to understanding the types of fall protection necessary, OSHA has provided a Fact Sheet, which includes a table explaining the type of scaffolding and what fall protection is required. For instance for aerial lifts, you’ll need a personal fall arrest system. However, for a single-point and two- point suspension scaffold, you’d need a personal fall arrest system and a guardrail system.7
Stairways and Ladders
Ladders (29 CFR 1926.1053) is one of two construction industry specific standards in the top three of OSHA’s Top 10 list. This standard saw 2,026 violations in fiscal year 2021 and jumped up two spots from number five in the list from fiscal year 2020 when OSHA reported 2,129 violations.
According to the standard, there are some very strict rules an employer must implement when using ladders at your jobsite. Many of the key components of safe ladder use are highlighted in the preliminary data from Kapust. In order to ensure safe ladder use at your jobsite, be sure to properly train workers on what proper use of a ladder looks like. Employers should provide training by a competent person and should include topics such as: finding the right ladder for the job, how to inspect ladders before use, maintaining three points of contact at all times, ensuring proper set up and how to set up non-self-supporting ladders at the proper angle before ascending.8
There are a few large mistakes that workers can make when using a ladder. Employers should ensure that employees are not standing on the top step or rung of the ladder unless the label states that it is safe to do so (most don’t). Workers should not
lean away from the ladder or overreach in any direction, as this can throw of the weight centered between the vertical rails and lead to tipping or falling. Another large mistake workers tend to make is placing the ladder on uneven ground or another object to reach a higher point. If their ladder is not tall enough for a worker to safely worker, then workers should be trained to get another ladder or find another means of safely reaching the work area.
Respiratory Protection
Moving up to number two for fiscal year 2021 is Respiratory Protection (29 CFR 1910.134), the only general industry standard to make it into the top three. It should not shock most to find this standard sitting close to the top of the Top 10 list given the ongoing Covid-19 pandemic. The standard saw 2,527 violations in fiscal year 2021, which is actually a small decline from the year prior when it the violation count was up to 2,649.
According to Kapust, most of the 1910.134 violations were due to the Covid-19 pandemic. OSHA found that employers were not completing medical evaluations prior to handing out respirators. Kapust explained that it is important to ensure that employees are physically capable of wearing the respirator before providing the PPE, as for some, the respirator could introduce more hazards than it is protecting the worker from.
Another violation that OSHA regularly found what the failure to provide a written respiratory program or properly train employees on appropriate use of the respirator. Without this information and training, OSHA found that employees did not have adequate knowledge on how to safely work with their respirator on.
Different than other standards listed in the OSHA Top 10 Most Frequently Cited Standards list, Respiratory Protection is the only standard to have found the majority of its violations in healthcare facilities such as medical and surgical hospitals, nursing care facilities and assisted living facilities for the elderly.
Fall Protection, General Requirements
For those familiar with OSHA’s Top 10 Most Frequently Cited Standards list, you will not be surprised to see Fall Protection- Training Requirements (29 CFR 1926.501) at number one. This construction standard has dominated the top spot for 11 years and has over double the number of violations for the standard that sits directly below it at number two. The preliminary data shows that OSHA reported 5,295 violations for this standard in 2021. This is a drop from fiscal year 2020 when the standard saw 5,424 violations.
In an overview from OSHA, employers must prevent employees from being injured from falls.9 The following are recommended ways to do this:
■ Guard every floor hole into which a worker can accidentally walk (using a railing and toe-board or a floor hole cover).
■ Provide a guard rail and toe-board around every elevated open sided platform, floor or runway.
■ Regardless of height, if a worker can fall into or onto dangerous machines or equipment (such as a vat of acid or a conveyor belt) employers must provide guardrails and toe-boards to prevent workers from falling and getting injured.
■ Other means of fall protection that may be required on certain jobs include safety harness and line, safety nets, stair
26 Occupational Health & Safety | NOVEMBER/DECEMBER 2021

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