The TopTen OSHA Violations Before Christmas. On the Eve Day


It’s Christmas Eve at the Northpole and everybody is busy and celebrating!  Santa and the elves did an outstanding job of fixing all the violations which included hours of training and practice and then completing the seemingly impossible task of getting all the toys and gifts that boys and girls around the world had asked Santa for produced and loaded on the sleigh!  This could only have been accomplished thanks to the great team effort of the elves.

That’s what it takes when it comes to safety at the workplace,  It takes a team of dedicated workers watching each other’s backs and reminding how to properly deal with hazards.  Even if the call for safety doesn’t come from the top executives you can still control what goes on in your work area.  You make the decision to wear your PPE, (safety goggles, ear protection, dust mask, and bump caps.  You make the decision to wear your fall protection gear, you make the decision to work on your machine without LOTO.  You make the decision to inspect your forklift before using it.

It is against the law to bully or threaten an employee to commit an unsafe act.  It is against the law to tamper with any kind of safety shutoff.   Yes, some companies are disrespectful dumbasses and may fire you for insubordination but do you want to work for a company that doesn’t care enough about whether you live or die on the job?   You do have OSHA in your corner.  That’s why they have an 1-800-321-6742 (OSHA) HOTLINE.  

Tomorrow is Christmas day, and around our beautiful country, as families gather and celebrate the holiday, there will be over 5,000 empty seats.   Mothers, fathers, sons, daughters, uncles, aunts, cousins will not be there because they died in an industrial accident this year.  We will miss the way they carved the ham, that special pie she made, the awful jokes Uncle told or the great laugh she had.  They will be missed and the heartache will have to be relived all over again.  We are all like snowflakes, no two alike.  Each with our own combination of skills and talents which makes us unique.  We come into this world for a short time to accomplish goals, have families, make a comfortable living.  You never know if they were the one with the next cure for a disease or invention to benefit the human race.

Thank you for stopping by and taking time out of your busy day to read our presentation of the TopTen OSHA Violations before Christmas.  The reception has greatly exceeded our expectations and that’s only because of great fans like you. Thank you.  Wish you all a Happy Chanukah and a Merry Christmas.


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The TopTen OSHA Violations Before Christmas. On the Tenth Day


Santa received a notice of violation(1926.501) Fall Protection-General Requirements and this unfortunately still #1 on OSHA’s TopTen violations for 2019.

In fact, falls have been the number 1 cited violation since 2011 and shows no sign of loosening its grip on that distinction.  This is very frustrating since falls can be stopped with the use of one word, NO.  If your foreperson or boss tells you we don’t have the time for you to put on your safety gear and properly tie off tethers to finish work on the roof just tell them I don’t have the time to die today, so NO!

Why?  Let’s say you do the right thing and wear your harness and all the gear needed.  You grab that 4×8 sheet of plywood to take it across the roof when a gust of wind catches the board like a sail and pulls you over the edge.  However, your fall is suddenly stopped by the tether and as you wait to be pulled up, you realized you lived and have a good tale to tell.  Meanwhile, in an alternate universe, you decided the boss is right and not to wear any of your protective gear.  Your reasoning, it’ll only take a second to move that sheet of plywood to the other side of the roof and it’s almost quitting time.  As you carry the board across the roof a gust of wind grabs the board and pulls you over the edge and as you plummet there is no sudden jerk from the tether to stop your fall but you have enough seconds to think,, rethink and rethink your mistake, your family, your kids until the ground breaks your fall.  If you are lucky the fall killed you instantly, no pain or suffering if you are not, expect a long life of pain, rehab, therapy, and disability.

So as you see the choice is yours.  It always has been.  Never allow anyone to challenge your courage, your manhood, your personality, your culture,  your capability to be a team player or other abilities just to goad you into committing an unsafe act or be bullied or threaten your job to do the same.  The law protects you.  Call the OSHA HotLine at 1-800-321-6742 (OSHA). 

Santa’s crew is training on how to properly wear their harness and how and where to properly tie off tethers before working right after they spent time learning what hazards to look for before working at any height over 6 feet, (9 feet in Arizona) since there are so many other ways to die from a fall.  Mis-use of ladders, poorly assembled scaffolding, side rails with missing sections, unmarked holes in the floor, wet or slick floors, distraction while working with spinning or vibrating equipment.  This is why you always inspect the area and safety equipment to be used before beginning work and never use any safety equipment that is damaged, frayed or altered.  What good is a side rail going to do for you if a section is missing to stop your fall?  What good is a rope rated to hold 100 lbs., when you weigh 220 lbs.?  Get in the habit of asking questions. The answers you get will give you enough insight to tell you if you want to continue working for that company.  If they give you answers and take safety seriously you found a keeper,

Santa’s Northpole workshop as well as your fall prevention program should include:

  1. Training – Identification of fall Hazards, how to wear and use PPE, anchoring tethers/lanyards and other associated items.
  2. Live demonstration and practice wearing and using.
  3.  Document all training including signatures of attendees, the material covered and who conducted the training.
  4. Enforce the rules, evenly and consistently.
  5. Group inspection of PPE  Equipment needs to be inspected on a regular basis, what better way to turn it into a safety training.
  6. Morning Huddle is a good tool to keep everyone in the loop as to what’s going on and any changes that are being made.
  7. Training – This is not one and done.  Don’t hesitate to have a refresher especially if you feel your staff needs it.

That was the last violation.  I believe Santa has complied fully and should get a clean bill of health but then you never know what the grinch has up his sleeve.  TOMORROWTHE DECISION







The TopTen OSHA Violations Before Christmas. On the Ninth Day


Santa received a notice of violation(1910.1200) Hazard Communication #2 on OSHA’s TopTen violations for 2019

Santa admits that he’s been so busy running the family business that he has not always kept up with changes.  He was very surprised to find out that his old MSDS book was incredibly out of date.  Back in 2012, the U.S. joined the Globally Harmonized System (GHS) which makes it easier for companies in classifying, labeling and producing data sheets for chemicals by complying with one system, globally.  As of June 1, 2016, it became mandatory for all U.S. companies under Hazard Communication Standard (HCS) or as it’s also referred to HazCom.

If you work where chemicals are produced, stored, shipped, transported or used you face a number of health hazards including irritation of skin, eyes or lungs and physical hazards like flammability or corrosion.  That is why you must have training on HCS and understand the processes and procedures that you must use in the handling, shipping or any form of exposure to chemicals.  All of the information is included in the Safety Data Sheets (SDS)  and labeling of item requirements.  The Safety Data Sheets should be located at every warehouse or facility where it is accessible by ALL.  Anyone who is involved, the truck driver loading chemicals, the UPS driver delivering, the dock forklift driver, the order picker, the clerk at the cheap retail store.  You all should have access to the SDS so you know what you are dealing with, what protective measures you must use and what to do in the case of a spill or leak.  The main change between old MSDS and current SDS is the order the information must appear:

  1. Identification
  2. Hazard(s) identification
  3. Composition/information on ingredients
  4. First-aid measures
  5. Fire-fighting measures
  6. Accidental release measures
  7. Handling and storage
  8. Exposure controls/personal protection
  9. Physical and chemical properties
  10. Stability and reactivity
  11. Toxicological information
  12. Ecological information
  13. Disposal considerations
  14. Transport information
  15. Regulatory information
  16. Other information

Santa and crew are busy updating their SDS and chemical handling procedures as well as training,  It feels like we cleared a pretty big hurdle but the biggest is yet to come.    Monday: On the Tenth Day. 





The TopTen OSHA Violations Before Christmas. On the Eighth Day


Santa received a notice of violation(1926.451) Scaffolding which is severe making it #3 on OSHA’s TopTen violations for 2019.

Think of scaffolding as another way to keep you from falling.  It gives you a stable platform to work on at several stories high if needed.  You can surround your project with scaffolding and work on it safe from all angles while stacking materials and using small pieces of equipment.

There are several kinds of scaffolding.  Single or brick layer’s scaffolding, Double, Cantilever, Suspended, and Trestle.  No matter which one you use it is only as good as it’s base so only a certified individual should direct and train other workers on its assembly.


Santa forgot to have one of his fore-elves certified and would have understood the procedures to control or minimize the hazards associated with erecting scaffolding and to train other elves so they may participate and assist in the construction.  So guess what?  Here again, training is critical for the safety of everyone involved.

  1. Plan ahead
  2. What kind of conditions will you be dealing with and for how long?
  3. How many people and what kinds of equipment and materials will be used?
  4. Pick your scaffolding
  5. Inspect
  6. Refresher training with all workers involved and how you’ll all proceed
  7. Assemble scaffolding
  8. Inspect. Never assume.
  9. Inspect
  10. Inspect
  11. Taking it down can be as dangerous as putting it up if not more.  Pay attention and stay focused.
  12. As with all training, document with signatures and a copy of the materials used.

It seems like it’s been a long week with so many issues cleaned up at Santa’s workshop and we are now down to the top two.   Friday: On the Ninth Day. 




The TopTen OSHA Violations Before Christmas. On the Seventh Day


Santa received a notice of violation(1910.147) Lockout/Tagout and this is serious enough to be #4 on OSHA’s TopTen violations for 2019.

Lockout/Tagout or LOTO as it’s also known as is a pretty important safety feature that prevents unexpected operation of a piece of equipment while you are working on it.  You see the scene played over and over on comedies, One guy is working on an electrical issue and his friend comes over and flips on the light switch leading to shock and laughter but imagine the horror on your face if a packaging machine with moving belts and rotating filler spouts suddenly started up while you were up to your elbows in the machines main compartment!

Or worse, clearing a jam on a belt in a machine and because you thought you would save time by just reaching in clearing it quickly, but as you clear it the belt suddenly lurches and takes two fingers with it.  This actually happened at a food manufacturing plant and I can assure you that no elves were injured during the writing of this post.

This is why as I’ve said before and will again and yet again training is critical to a great safety program.  It’s not enough to just turn off the power with the flip of a switch before servicing the machine, you want to make absolutely positively sure that no one but YOU can turn the power back on before your work is done.


That’s why this year Santa will be giving his machine operators, maintenance elves, and fore-elves the gift of their own LOTO sets.  Santa wants to do the training of LOTO  correctly so he will have his machine operators do an actual LOTO demonstration for the group for each piece of equipment.

Whenever you need to do maintenance, adjustments, line changes or clear a jam you must Lockout/Tagout the equipment so it can not operate while you work on it.

  1. Determine where to cut the power and use your lock. Your tag should have your name and department on it along with what ever other information the company wants.  Some want employee number, so anyone coming by knows you are the person working on that machine and initiated the lockout.
  2. In most cases, you pull the lever of the circuit breaker down so you can lock it in the off position.  In some older facilities, you may not find circuit breakers to lockout.  Find and pull the fuses and use the special fuse lockout.  Before beginning make sure the machine is totally deenergized as some parts mid-stroke may still move.
  3. Each additional worker who needs to service the machine along with you also needs to lock out the same source of power as you. As they finish their segment they can then remove their lock until the last person responsible for the project removes their lock and returns power.
  4. Never remove your lock until the work is completed.
  5. Never give your key to your lock to anyone else.  Only YOU can unlock it.  If you have to leave have your relief lock out the power source with their lock and then you can remove yours.
  6. Never allow anyone to bully you into removing your lock before work is completed.
  7. As with all training, document it with signatures of attendees and the material covered.

Now that we know all about LOTO. Thursday: On the Eighth Day.



The TopTen OSHA Violations Before Christmas. On the Sixth Day



Santa received a notice of violation(1910.134) Respiratory Protection and this is #5 on OSHA’s TopTen violations for 2019.

Your lungs bring fresh oxygen to your brain, organs, and tissues via the circulatory system and then expel carbon dioxide with every breath you take.  When O2 levels are where they should be, your body functions at its peak.  However, your lungs can also transport toxins to those very same organs while also damaging themselves over a period of time causing debilitating diseases and a slow death when oxygen can no longer reach and organs fail but in some instances, contact with the toxic fumes can bring instant death.  It turns out Santa’s fore-elf, due to his own ignorance was not insisting that the elves wear their respirators properly in the paint shop.  Because of their beards, the respirators were not fitting correctly and leaving a gap in protection and allowing fumes to accumulate in the mask rendering it useless.

Working with solvents, chemicals, paints, lubricants, dust-producing equipment and any other toxic air causing materials is a dangerous job.  Some hazards are easy to see like sawdust at a mill and some are colorless and hard to detect but all are toxic to your lungs and when working with them in a confined area like a paint shed or storeroom it makes their effects even stronger and without proper protection can overwhelm you in seconds rendering you unconscious and death.  There have been incidents, luckily not at Santa’s workshop where someone passed out after entering an area with toxic fumes and the next person rushes in to rescue them, without a respirator, only to succumb to those same fumes themselves because they are so overpowering and both workers wound up dying.

When working under these conditions like a wood mill or paint room at Santa’s workshop

  1. Choose the correct mask for the job.
  2. Even if it has a venting system you still must wear the properly rated respirator to protect yourself.
  3. No matter what type of mask you need to wear, they need to fit tightly on your face so there are no gaps to allow dust or toxins in.  The vendor will work with your employees to teach and accomplish that.
  4. That means you may have to shave facial hair to ensure that tight fit.
  5. Training on how to wear their respirators and as always, document the training.
  6. Take proper care of respirator and clean and change filters per manufacturer’s instructions.
  7. If respirators are part of an emergency response kit make sure to test and check them to ensure their availability when needed.

Santa continues to work with OSHA while upgrading the workshop into the twenty-first century.  It won’t happen overnight but then Santa is magic.  Wednesday: On the Seventh Day.




The TopTen OSHA Violations Before Christmas. On the Fifth Day



Santa received a notice of violation(1926.1053) Ladders which is #6 on OSHA’s TopTen violations for 2019.

It’s looking more hopeful at the Northpole as Santa’s team spent the weekend getting all the elves caught up on much-needed training and important upgrades of equipment to fix the first four OSHA violations.  Today we work with ladders.  What?  Ladders?  Seriously? How dangerous can a ladder be?  It’s dangerous enough to become sixth on  OSHA’s TopTen list for killing 150 workers a year and injuring another 20,000.

Maybe because a ladder looks so easy and innocent to use or maybe we learned how to use a ladder incorrectly from our Dads why so many winds up visiting the E.R.  Here again, training is the most critical part of safety and learning how to properly use a ladder is a skill you’ll use pretty much the rest of your life.  Remember as with any training given, always document by having workers sign in and attach copies of the material covered.

  1. Ladder missing rungs, cracked or broken rungs, broken side rails or broken spreaders should never be used and immediately tossed into the trash.
  2. Set up the ladder on a firm flat even surface.  Using a ladder on an incline may only hasten your fall.
  3. Always open a ladder and lock the spreaders in place before using so you have a firm base to work on.
  4. Keep your hands free from holding tools, tool bag or a cup of coffee when using a ladder.  You need both hands to keep your balance and safely ascend/descend the ladder.
  5. Don’t stand on the top cap.  It’s not a step or a place to stand on.  It also makes the ladder less stable and more possible of a fall.
  6. Don’t be lazy.  Get down and move the ladder closer to what you’re working on instead of overreaching which can lead to loss of balance and a fall.
  7. NEVER use a metal ladder when working near or around power lines.

Santa still has some work to do but all the elves and everyone else seem to be responding well to the changes especially since no one wants to see the workshop shut down.  Tuesday: On the Sixth Day.



The TopTen OSHA Violations Before Christmas. On the Fourth Day


Santa received a notice of violation( 1910.178) Powered Industrial Trucks.  This is listed as #7 on OSHA’s TopTen violations for 2019.

We must be on the right track because we haven’t seen or heard from the grinch since we began this series.  As mentioned yesterday, training is the most critical part of safety.  I can’t say it enough.  With proper training chances are an elf can retire with all body parts intact.  Powered Industrial Trucks are included in the category of don’t touch until you’ve been trained.  Powered Industrial trucks include tugs, ride-ons, forklifts and any other vehicle that moves within your warehouse using electric, propane, diesel or reindeer as a power source.


Even before Santa was allowed to fly the sleigh he had to spend hours training and practicing at the controls and learn what to inspect during pre-flight, how to properly hook up the reindeer and board and care for them as well.  The training should include how to professionally operate the forklift within the confines of or the outside of your facility.  You need to know how to inspect the vehicle before operating which must be done at the beginning of each shift and how to properly red tag out of service if needed so someone else won’t operate an unsafe vehicle.  You also need to be aware of the capacity of your forklift.  How much weight can it lift safely without tipping over?  Yes, tipping over.  If you lift beyond what your forklift can handle or shift in the wrong direction it all, including yourself will tip over.

Forklifts are the workhorse for every facility in every trade or industry.  They are NOT toys and NOT to ever be used in horseplay.  Santa pays an enormous annual workers compensation premium and doesn’t need your help to increase it any time soon.  So now the elves will be trained as follows:

  1. Never operate any powered industrial truck that you have NOT been trained or certified to operate.  You need to be certified to operate by a trained instructor.
  2. Certification is achieved by first completing a classroom training session using a combination of written materials, videos, and instruction.  Document all training with signatures of those attended and the material covered and keep.
  3. Upon completion of the classroom segment, the candidate takes a road test operating the vehicle.  Some think you need to set up some sort of obstacle course as part of the road test.  I want to make sure my elves can pull or put away pallets and load trucks.  That’s what I actually test them on.  Again, document.
  4. Demonstrate what to examine and look for during a preshift inspection of a forklift. If it is not safe to operate never be afraid to RED TAG it.
  5. NEVER use your forklift to transport people, as a piece of exercise equipment, like a ladder, like a racecar or drag racer and NEVER use it for horseplay.

Santa will be taking a breather during the weekend as the crew concentrates on their upcoming deliveries around the world.  He greatly appreciates all of everyone’s support and good wishes in getting his workshop back in order.  Hope you all have a great weekend preparing for the holidays.  Monday: On the Fifth Day.


The TopTen OSHA Violations Before Christmas. On the Third Day



Santa received a notice of violation( 1926.503) Fall Protection – Training Requirements.  This happens to be #8 on OSHA’s TopTen violations for 2019.

It appears we’re on a roll solving the issues at Santa’s Northpole workshop so let’s keep the momentum going.  Training is the most critical part of safety.  Without it, you may not know how to properly wear PPE, or at what height you need to wear PPE or how to respond in an emergency.  There are several ways to prevent falls and whether using a safety harness and tether or railings and handrails training needs to be conducted for all of them.

Even Santa didn’t just wake up one morning and say, hey, I think I’ll climb down chimneys to deliver toys for a living.  (Well he actually may have).  He had to learn how to and then practice repeatedly to safely land on a roof with a team of reindeer as well as getting down and back up a chimney without detection.  The hours of training he received from chimney sweeps and ninjas.

Santa needs to make sure that all of his elves and other employees get training before they are allowed to work at heights over 6 feet from the ground (9 feet in Arizona).

  1. Classroom training – all the employees at the workshop are required to attend the training which should include hazards that can be encountered when working at heights and why you need to wear the proper PPE.  Carrying a sheet of plywood on a roof may seem easy but if a gust of wind comes along and catches it, chances are you’ll be airborne and fall without the proper protection.
  2. Live Demonstrations – A senior employee can show how to properly wear PPE/fall prevention gear and then give all employees the opportunity to try on and wear the PPE to get a feel for it.
  3. Document and keep on file all training including signatures of attendees and the actual material covered.
  4. Don’t try and be a nice guy.  Uniformly and fairly enforce the rules to prevent falls.

We’ll begin conducting training later today in shifts so the elves can keep working throughout.  The deadline is near and Santa is still not out of the OSHA woods yet!  Tomorrow: On the Fourth Day.






The TopTen OSHA Violations Before Christmas. On the Second Day



Santa received a notice of violation( 1910.212) Machine Guarding. This is #9 on OSHA’s TopTen violations for 2019.

After solving the PPE issue yesterday, let’s take a look at machine guarding.  As we had mentioned yesterday, machinery is extraordinary and can be challenging yet quite rewarding to operate and maintain.  Some professional operators have such a strong bond with their machine they can tell just by the sound if it’s running at it’s best.

Most machines are constructed to operate with many moving parts.  Gears, belts, chains, cables moving at high speed so the machine can do what it needs to do to produce that end product for your customers.

While watching the elves at work above, it’s obvious that they are exposed to moving mechanical parts. When you are trying to concentrate on keeping a machine operating and have to move around the machine you shouldn’t have to worry about getting caught in the moving parts and losing a limb or your life.

  1. Gears, belts, and other moving parts should have machine guarding which is a cover for the moving parts so you don’t come into contact with them.
  2. Some machines have auto shutoffs, so if the guard is removed the machine will not operate.  Never tamper with or disable an emergency shutoff on a machine.
  3. You do not have to operate a machine without proper guarding or be forced to disable any emergency shutoff.
  4. Even if they tell you the guarding is in the shop being repaired or will be here soon, do not operate that piece of equipment.

Once we have the saw blade, belts, and other moving parts fitted for guards we will have another violation licked and another step in saving Santa’s workshop.  Tomorrow: On the Third Day.

Will this be enough to fix this ticket let alone save Santa’s workshop?  Find out tomorrow.  On the Second Day.