The OSHA Wolves are at residential contractors door..........                         

Fall protection violations are top dog........Respiratory violations are number 4.....

OSHA recently released statistics for its most frequently violated standards for fiscal year 2011 (October 1, 2010 through September 30, 2011). Violations of the fall protection in construction standard 29 CFR 1926.501 topped the list this year switching places with last year’s first place holder, the construction scaffold standard 29 CFR 1926.451. Hazard Communication remains in third place overall and first for general industry.

Contractors are required to be compliant with the new OSHA Residential Fall Protection Directive as of 6/16/2011. Contractors who work 6' above lower levels must have a written fall protection plan in place. They must train their workers. They must use guard rails, safety nets and or fall arrest systems.

The surprising top violation is for Respiratory violations. This is of particular concern for contractors in states like Massachusetts. Mass took over the EPA RRP Lead Law and in true Mass fashion added a lot more on top of the EPA regulation. Mass added the OSHA Respiratory and Medical Monitoring Standards and made them part of the Mass RRP Lead Law CMR 454.22.00. In order to qualify to become a certified firm Mass contractors must sign under the penalties of purjury that they comply with the OSHA respiratory and medical monitoring standards. Mass contractors must complete an application to become a Lead Safe Renovation Contractor (same as Certified Firm). They also agree by their signature on the application that they are following the OSHA medical monitoring and respiratory standards written into the Mass Regulation. 

If a RRP licensed contractor is caught working in Mass on RRP jobs without following the proper respiratory and medical monitoring standards written into the Mass Law they may be subject to severe penalties from OSHA. The contractor must make sure that all workers are protected under the OSHA standard. This includes workers and sub contractors. To comply  employers must have a written medical monitoring and respiratory plan. These plans require lead blood testing, lung capacity testing, respirator fit testing and the appropriate PPE for workers.

Many contractors who were trained before 7/9/2011 when Mass was delegated authority by the EPA to take over the law are exposed if they have not been updated on the Mass changes. Many who certified with the EPA have not certified their firms in Mass. Some who did certify using the waiver application, have not updated their training to make sure that they are following the OSHA standards in the Mass regulation.

OSHA Respiratory and Medical Monitoring Training

Fall Protection Training                                     RRP Coaching and Consulting

2011 Most Cited OSHA Violations                        

1. Fall protection – 7,139 violations.
2. Scaffolding – 7,069 violations.

3. Hazard communication – 6,538 violations.

4. Respiratory protection – 3,944 violations.
5. Lockout/tagout – 3,639 violations
6. Electrical – wiring methods – 3,584 violations
7. Powered industrial trucks – 3,432 violations
8. Ladders – 3,244 violations.
9. Electrical – general requirements –

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