One objection of mine to adding more OSHA standards is that the standards cited frequently (top ten in frequency) remain generally the same year to year. Sometimes they shift position in frequency order. Sometimes the numbers of citations trend up or down, but generally it all remains in a controlled range.

For example, lack of a HAZCOM written program has, as I recall, been on the Top Ten List since the HAZCOM Standard was imposed on us. How difficult is that to get done? Should not be a lot.

When I get the chance, I ask safety professional groups I speak to how many of your sites have a written HAZCOM program. All hands go up—except just recently. One hand did not go up so I was inquisitive as to why. The response was that this person had just taken on staff safety responsibilities. There had not been a written HAZCOM program but he was developing one. Just remember this when OSHA and the DC OSHA cheerleading crowd wants to impose new written program standards—such as I2P2.  All that will happen is there will be new member of the OSHA annual Top Ten citations list.

Not to bore you with data, but just to illustrate the point about the generally unchanging face of OSHA citations, here is a table of the Top Ten over the past 3 years.

These are published each year to let you know where OSHA is finding violations. But if you are reading this, you know where the issues are for your site and are working on them.

You see some downward trends in some of the numbers for 2012 but I would not assign any significance to one year’s data.

 The numbers show some minor shifting in citation frequency order, but the Top Ten in general remains the Top Ten.

The point I am making is that until these standards become more ingrained in workplaces, and therefore become much fewer in number or finally drop off the Top Ten list, there is no need for more OSHA standards for sites, particularly those estimated 7.3- 7.4 million sites with no safety staff.  

OSHA needs to work on implementation through compliance assistance at these sites for the 40+ years of OSHA standards already on the books and required.

And to my point in this column, safety would better served by OSHA increasing budget for Compliance Assistance, generating funds for that safety improvement by reducing or eliminating Safety Standards.

More OSHA standards in the face this citation data is purely a political agenda motivation rather than a genuine safety improvement motivation.