OSHA Top Citations for 2020

FED-OSHA TOP 10 citations issued for 2020 are as follows:

1. Fall Protection:  Falls, primarily from ladders and roofs, accounted for 384 fatalities in 2016. Any time a worker is at a height of 4 feet or more (30 inches or more in CA), the worker is at risk and needs to be protected.
2. Hazard Communication: Employers are required to provide a written Hazard Communication Program, label hazardous chemicals, provide a Safety Data Sheet for each chemical, and document employee training.
3. Respiratory Protection: Body shop employees need specific training on policies (written) and practices involving the use of respirators during auto refinishing operations. Training on respiratory protection, fit testing, user seal check, and respiratory cleaning procedures are mandatory, and so is the OSHA Respirator Medical Evaluation Questionnaire. When an employee wears a respirator, even when it is not required under the regulation, information on proper usage, including limitations, must still be provided.
4. Scaffolding: Primarily applicable to the construction industry.
5. Ladders: Limit ladder use to trained and experienced staff only. Secure ladders with a chain to prevent usage by untrained staff.
6. Lockout/Tagout: Specific procedures and practices safeguard employees from the unexpected energization or startup of machinery and equipment. A written program and employee training is mandatory (annually). Employees working on automobiles must comply by isolating energy to the engine to prevent inadvertent movement during repair or service. A lockout kit including locks should be available.
7. Powered Industrial Trucks (Forklifts): The high number of fatalities associated with forklifts and high number of violations associated with powered industrial truck safety tell us that many workers are not properly trained to safely drive potentially hazardous equipment. OSHA compliance requires training in these specific activities: forklift operations, loading and unloading, and vehicle maintenance. Evaluating an operator every three years is also mandatory.

8. Fall Protection Training Requirements: This moved up a notch from the 2017 number 9 spot. Dealerships must protect employees working on 2nd floor of parts while loading/unloading parts at the mezzanine edge.

9. Eye & Face Protection: Essentially reinforce your Person protective Equipment (PPE) policy and ensure all your employee wear eye and face protection, as necessary.

10. Machine Guarding: Moving machine parts has the potential to cause severe workplace injuries, such as crushed fingers or hands, amputations, burns, or blindness. Safeguards, including anchoring machinery, are essential for protecting workers from these preventable injuries. Any machine part, function, or process that may cause injury must be safeguarded. When the operation of a machine or accidental contact with the machine may injure the operator or others in the vicinity, hazards must be eliminated or controlled. Moving parts in automobiles, grinders, and brake lathes are all subject to this regulation.


OSHA has stated repeatedly and consistently in its training-related interpretation letters that online or computer-based training is acceptable as part of an overall training program that includes hands-on, site-specific information and work practices where it is needed to meet workplace safety goals.  Many online courses may not be legitimate.  In many instances, the training company clearly states that the training does not meet any local, state, or federal standards.  The awakening happens when OSHA audits the workplace and finds the employer short on hands-on, site-specific information and work practices.

We discuss the hand-on element of some of the hands-on training requirements as follows:

1. Fall Protection:  Employees must have hands-on training on using fall protection equipment such as harnesses.  Also, the lanyards which automatically limit free fall distance are to be marked according to the actual edge.  In summary, the training is hands-on and site-specific.

2. Forklift Training:  Many employers are under the false assumption that the online training is sufficient for employees operating the forklift.  Completing merely online training and allowing one to operate a forklift is akin to driving an automobile after passing a written test.  We all know that hands-on proficiency is to be shown before an actual driver’s license is granted.  Some trainers in fine print state that hands-on training is necessary and some do not mention at all. An experienced trainer must provide training on the operation of the actual hoist and evaluate the employee on proficiency prior to providing an operator certification.

3. Lockout/Tagout:  A written program and employee training is mandatory along with the hands-on portion of lockout.  An effective Lockout program requires that the employee must be able to show to the certifier that he possesses the tools and has procedural knowledge to effectively lockout the equipment, i.e., a faulty hoist.

4. Respiratory Protection:  The employee must be fit tested for the specific respirator to be worn by the employee.  Respirator selection must be done by the employer based on the hazard exposed.  The employee should then be given training on the respirator that must be worn during the work shift.  The SDS for the chemical being used must be utilized in the selection process.


Type of ViolationPenalty
Generalup to $13,653 per violation
Serious$975 – $13,653 per violation
Failure to Abate$13,653 per day beyond abatement date
Posting Requirementsup to $13,653 per violation
Willful or Repeated$9,753 – $136,532 per violation

Note:  The penalties are now automatically adjusted for inflation on an annual basis.

DISCLAIMER:  The contents of this newsletter are merely for informational purposes only and are not to be considered as legal advice.   Employers must consult their lawyer for legal matters and EPA/OSHA consultants for matters related to Environmental, Health & Safety. The article was authored by Sam Celly of Celly Services, Inc. who has been helping automobile dealers in Arizona, California, Hawaii, Idaho, Nevada, New Mexico, New York, Texas, and Virginia comply with EPA and OSHA regulations for over 34 years.  Sam is Certified Safety Professional (No. 16515) certified by National Board of Certified Safety Professionals. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997).  Our newsletters can be accessed at www.epaoshablog.com.  Your comments/questions are always welcome.  Please send them to sam@cellyservices.com.

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