The OSHA top ten citation list. We see it every year, but what does it tell us? It covers hospitals, restaurants and yes, construction, but all types of construction. Because California has unique regulations, California data is not included. So just for you here are the:

Top Ten Cal/OSHA Citations for Painting Contractors over the past year.

1. Injury and Illness Protection Program
2. Heat Illness Prevention Plan
3. Ladders
4. Fall Protection
5. Reporting Serious Injuries
6. First Aid Kits and Training
7. Manlifts
8. Confined Space
9. Scaffolding
10. Lead

Now let us dive into what is being cited and what you can do to prevent injuries and avoid these citations. 

2. Heat Illness Prevention Program (HIPP)

Citations are for not having a written Heat Illness Prevention Plan (HIPP), having a HIPP that is not implemented or effective, or not having all the required elements in the HIPP and training program. Failure to provide or replenish water is also frequently cited. Review your written program and training to make sure they have all the required elements. New regulations also require heat illness protections for indoor work so if you have not added these requirements to your HIPP now is the time to do it. [GISO 3395 and now 3396]

3. Ladders

Not inspecting or using ladders and not training employees on their inspection and use. The instructions and training material are stuck on the ladder; what an easy tailgate. Ladders must be inspected “frequently” which technically means at least 13 times a year. The ladder user must inspect it at the beginning of each shift, but you should also do more thorough documented inspections at least monthly. Common misuses include using the wrong type or length of ladder, climbing too high and leaning step ladders. Using lean safe ladders goes a long way on that. [GISO 3276 and CSO 1675]

4. Fall protection

The number one citation is not using fall protection when it is required. Other issues include improper use: using insufficient anchor points installing manufactured anchor points incorrectly; sliding the rope grab to the end of the lifeline, or improper installation or makeshift horizontal lifelines. Decisive enforcement and training are the keys. Your employees must know there is no compromise on fall protection. Make them understand the effect a fall would have on them and their family. And they need the best training to make it happen. One final issue is using a fall protection plan without proving conventual fall protection cannot be used. [CSO 1670 and 1671.1]

5. Reporting Serious Injuries

Failure to report a death, or an injury or illness that requires inpatient hospitalization for other than observation or in which an employee suffers an amputation, the loss of an eye, or any serious degree of permanent disfigurement to Cal/OSHA within 8 hours. Train foremen, superintendents, admin, and HR in reporting requirements. It is a stressful time so the more people who know, the more likely someone will remember to report. [Title 8 Section 342]

6. First Aid Kits and Training

Not having enough, or no, people current in first aid training. This training is required every two years. View First Aid/CPR training as an employee benefit and offer it to everyone. First aid kits are a consumable item and must be replenished or replaced regularly. [CSO 1512]

7. Manlifts

The most common citation is for not tying off in an aerial device. Other common violations are climbing on the guardrails and traveling when conditions or manufacturers requirements do not allow it. Mobile Elevated Work Platform (MEWP) training is required and should cover fall protection and proper operation. You also need to get the right piece of equipment to get the employee to the work location. [GISO 3648]

8. Confined Space 

When working in permit-required confined spaces (PRCS) you need to have and follow a written confined space program. There are no exceptions for short duration or just putting your arms in. A qualified entry supervisor is required to ensure all measures necessary for safe entry are detailed on the permit and followed. The attendant must not do anything that would interfere with monitoring the employees in the confined space. Confined space entry is a hazardous task and quality training is necessary. [CSO Article 37]

9. Scaffolding

Citations are for improper erection, missing guardrail and platforms not being fully planked. Rolling scaffolds are cited for not locking the wheels and surfing. I you erect your own scaffold make sure the crew is trained. All scaffold users need to be trained in proper use and inspection and be encouraged to speak up when something is wrong. Users should never modify a scaffold. Another issue is not using a scaffold when you should or using or using other objects instead of a scaffold. [CSO 1637, 1644 and 1646]

10. Lead

Lead exposure exists anytime lead containing materials are ground, sanded, scraped, or otherwise disturbed. Lead is a toxin, and detailed measures are needed to prevent exposure to employees and to prevent them taking this toxin home to their families. If you do not know how to safely remove lead materials hire an abatement contractor. If you do your own abatement provide detailed training and the PPE and other equipment needed. The exposure limits for lead were lowered and new requirements added at the beginning of the year, so this is likely to go up on the list next year. [CSO 1532.1]

Take some time to ensure your safety programs address these topics in tailgates. Training is a common theme, but training must be practicable and understandable. Bad training covers the rules, good training teaches employees how to work safely. The Safety Orders referenced can be found at https://www.dir.ca.gov/samples/search/query.htm.