I was at the America Society of Safety Engineers (ASSE) annual Professional Career Development day in Minneapolis last week. I had a chance to sit in on Minnesota OSHA’s presentation on the partial repeal of the Minnesota Employee Right to Know Act (MERTKA) and the adoption of the Federal Hazard Communication standard (HCS), presented by Mr. Bill Stuart of MN OSHA.
During his presentation, he showed a slide identifying the top 10 most common MN OSHA citations from the last year.
- Employee Right to Know training – 530 citations
- Hazard Communication training – 205 citations
- Machine guarding – general requirements – 221 citations
- Control of hazardous energy (Lockout/Tagout) – 172 citations
- A Workplace Accident and Injury Reduction program (AWAIR) – 166 citations
- Powered Industrial Trucks (Forklifts) – 147 citations
- Respiratory Protection – 143 citations
- Electrical wiring methods, components, equipment for general use – 132 citations
- Carbon Monoxide monitoring – 99 citations
- Hand and portable tools and equipment – 89 citations
It’s no surprise that Right to Know and Hazard Communication (Haz. Comm.) training are at the top of the list. They are perennial “list toppers” in Minnesota and elsewhere. It’s clear that Right to Know and Haz. Comm. have been, and will continue to be a priority for enforcement, at least in Minnesota.
But what is noteworthy this year, is that the 735 citations for this group of requirements is more than the next four most common citations combined.
It’s also interesting to note that those types of violations are specific only to training requirements under Right to Know and Haz. Comm. Other possible violations under those rules aren’t included in these statistics (i.e. Safety Data Sheets, chemical labeling, written programs, etc.) If we add the violations for those deficiencies, the numbers become even more convincing.
The most common issues with Right to Know and Haz. Comm. training are (in no particular order).
- Failing to provide the training at all.
- Failing to train new employees. Employees covered by the program must be trained before they are allowed to be exposed to any hazardous chemical, harmful physical agent, or infectious agents.
- Failing to provide annual refreshers. Each employee covered by the program must have refresher training at least annually.
- Failing to train when hazards change. Re-training must be provided when new hazards that employees have not been trained on, are introduced.
- Inadequate training. There are strict requirements for content of training. The most common issues is that training does not include information about the specific hazards to which employees will be exposed (i.e. Noise, heat, tick-borne illness, carbon monoxide, compressed gases, flammables, human blood and body fluids, etc.)
- Failing to include required information about Global Harmonization System (GHS), specifically GHS formats for labels and Safety Data Sheets.
- Poor documentation. Safety professionals have an expression; “If it’s not documented, it didn’t happen”. All safety training must be adequately documented. At a minimum safety training records should always include the names/titles of participants, the name (and sometimes even the qualifications) of the trainer, the date of training (don’t forget the year) and a summary or outline of what was covered.
Sotera Consulting would like to remind you that Hazard Communication and Right to Know training is one of our specialties. We’ve done literally thousands of sessions over the last 25 years. We can usually develop and conduct training on this topic for just a few hundred dollars. Please contact us for more information on this topic.
What do you think about these MN OSHA statistics? Has your company been cited for any of these? What do you think is your current level of compliance?