Top OSHA Citations for COVID-19 Inspections

Frequently Cited OSHA Standards for COVID-19 Inspections

In conducting COVID-19-related inspections, OSHA has frequently cited employers for violating certain standards. Employers can learn more about those frequently-cited standards and relevant resources in OSHA’s in-depth analysis of Common COVID-19 Citations. Employers must be vigilant to meet all OSHA requirements. The following are examples, to date, of requirements that employers have most frequently failed to follow:

  • Provide a medical evaluation before a worker is fit-tested or uses a respirator.
  • Perform an appropriate fit test for workers using tight fitting respirators.
  • Assess the workplace to determine if COVID-19 hazards are present, or likely to be present, which will require the use of a respirator and/or other personal protective equipment (PPE).
  • Establish, implement, and update a written respiratory protection program with required worksite-specific procedures.
  • Provide an appropriate respirator and/or other PPE to each employee when necessary to protect the health of the employees (ensuring the respirator and/or PPE used is the correct type and size).
  • Train workers to safely use respirators and/or other PPE in the workplace, and retrain workers about changes in the workplace that might make previous training obsolete.
  • Store respirators and other PPE properly in a way to protect them from damage, contamination, and, where applicable, deformation of the facepiece and exhalation valve.
  • For any fatality that occurs within 30 days of a work-related incident, report the fatality to OSHA within eight hours of finding out about it.
  • Keep required records of work-related fatalities, injuries, and illness.


OSHA Recordkeeping and Recordability: Medical Treatment vs. First Aid

OSHA Recordability Medical Treatment First Aid

Determining what constitutes an OSHA recordable injury can often be a science in itself.  Luckily, the good folks at JJ Keller have put together a list of medical treatments (recordable) vs. first aid (non-recordable) for your reference.  Care categories include:

  • Visits to health care professionals
  • Cuts, lacerations, punctures, abrasions
  • Inoculations
  • Splinters
  • Strains, sprains, dislocations
  • Burns, skin rashes, blisters
  • Bruises, contusions
  • Medications
  • Oxygen
  • Physical therapy (PT)
  • Loss of consciousness

Click below for a .pdf copy of the summary document.

  OSHA Medical Treatment vs. First Aid (52.3 KiB, 3,320 hits)

Want to know what is considered first aid in the eyes of OSHA 29 CFR 1904.7.b.5.ii?  Download OSHA’s first aid list below.

  OSHA First Aid (5.9 KiB, 1,826 hits)

Source: JJ Keller

GAO Issues New Report on Underreporting of Workplace Injuries

errorIn a survey of 504 occupational health practitioners (including company doctors & nurses), the U.S. Government Accountability Office (GAO) concluded that the government has not done enough to ensure that the reporting has been accurate.

The findings include:

  • More than 33% of the doctors/nurses said they were pressured to provide insufficient treatment so that the job-related injuries did not show up on injury logs.
  • More than 50% of the doctors/nurses said they were pressured from upper management to downplay injuries & illnesses.
  • More than 65% of the doctors/nurses said they knew of employees who would not report injuries & illnesses to avoid disciplinary measures.

The findings were further complicated by the fact that employees are often rewarded for maintaining “safe-work” environment for long periods of time, thereby reducing reporting.

The GAO is recommending that the Secretary of Labor direct OSHA to do the following:

Calculators: Injury and Illness Incidence Rate & DART

Want to calculate your Injury and Illness Incidence rate (I&I) and/or your Days, Away, Restrictions and Transfers (DART) rate? Use’s Incidence Rate and DART Rate calculator (Excel spreadsheet format) to determine your rates.

Download the Calculator HERE for use on your computer:

  DART Rate Calculator (42.0 KiB, 1,712 hits)

Sample Screenshot IR & DART Calculator

Sample Screenshot IR & DART Calculator

OSHA NEP: Under Recorded Injuries and Illnesses

Effective September 30, 2009, OSHA has begun a new National Emphasis Program (NEP) for inspecting the accuracy
of the Occupational Injury and Illness Recording and Reporting Requirements for low rate establishments in selected industries.

OSHA postulates the most likely places where under-recorded injuries and illnesses may exist
would be low rate establishments operating in historically high rate industries. The NEP will
pilot test OSHA’s ability to effectively target establishments to identify under-recording of
occupational injuries and illnesses.

This NEP is one component of OSHA’s effort to address the issue of inaccurate recording of
occupational injuries and illnesses. In addition to this NEP, OSHA will address the issue through
comprehensive training of its compliance staff to identify and correct violations of the
recordkeeping regulation. OSHA will also develop other enforcement and quality assurance
programs to address the recordkeeping issue in establishments and industries outside the scope of
this NEP (e.g., the construction industry, Partnerships, VPP and SHARP establishments).

Industries included have a DART (days away, restrictions and transfers – based on the 200,000 hour benchmark) rate of 5.7 to 8.1 and include:

  • Animal slaughtering
  • Scheduled passenger air transportation
  • Steel foundries (except investment)
  • Other nonferrous foundries (except die-casting)
  • Concrete pipe manufacturing
  • Soft drink manufacturing
  • Couriers
  • Manufactured home (mobile home) manufacturing
  • Rolling mill machinery and equipment manufacturing
  • Iron foundries
  • (more…)