OSHA’s Top 10 and How they can Affect your Safety Program with Stephen Badger

In 2020, Fall protection was once again, number one of OSHA’s Top
Ten most frequently cited standards. On this episode of the MEMIC
Safety Experts Podcast, Steve Badger, CSP, OHST, and Safety
Management Consultant with MEMIC breaks down OSHA’s Top 10 and
how it can be used as a tool for continuous improvement of your
safety program.


 


Peter Koch: [00:00:03] Hello, listeners, and
welcome to the MEMIC Safety Experts podcast, I'm your host, Peter
Koch. Well, we all make lists. I don't know about you, but I love
to check stuff off my list. For me, it represents an
accomplishment or at the very least, something I don't have to
worry about anymore until, of course, it resurfaces on my lists
again, lists tend to be an important part of any safety
management process, and they can help keep us on track for the
myriad of different topics, hazards and exposures that must be
addressed by our teams every day in the workplace. It can be
overwhelming about the number of things that we have to manage.
So lists become an important part and sometimes we generate lists
to help us focus our limited resources and energies. So consider
hazard or injury mapping. These are two great ways to generate
and prioritized injury prevention and hazard mitigation
[00:01:00] efforts and strategies. Well, if you're not sure what
those two things are, we can put some resources in the show
notes. But this is not a podcast about hazard and injury mapping.
We're talking about lists today and specifically OSHA's top 10
list. So OSHA has a myriad of different lists and their lists can
also help employers and business owners find a starting place in
workplace safety. So to help us with that today on the podcast,
with me is Steve Badger, CSP, OHST and safety management
consultant with MEMIC. Steve has more than 20 years of experience
working with the paper, medical, sterilization and construction
industries. He's also an authorized instructor for the OSHA
Institute in Manchester, New Hampshire. Steve's experience in
different industries and workplace safety, as well as his
connection to the OSHA Institute, has allowed him insight into
OSHA's top 10 lists and how they can be used to help us focus on
the right areas [00:02:00] and overcome some of the barriers to
enhancing safety in the workplace. So, Steve, welcome today to
the podcast.


Steve Badger: [00:02:08] Thank you, Peter. Thank
you very much for having me on here today. And just a little bit
about myself and my safety history. I started way back in 1986. I
worked for Johnson and Johnson, and that was my really my first
exposure to safety. And, you know, what we had to do. And the
very first part of it was hazard communications and, you know,
those things called material safety data sheets that just came
out of nowhere supposedly. And, you know, that had to put
together a program. And you have to think about the fact we
didn't have a lot of computers back then. We didn't have a lot of
resources back then to be able to go in and look these things up.
We had to call people. And if we were lucky, we had a thermal fax
that we could have somebody fax something to us. And it was a
very difficult process when you worked in a laboratory like I
did, where [00:03:00] there was a chemical part and there was
also a microbiology part. And, you know, in trying to put these
HAZCOM safety data sheets and programs together. So that that was
that was where I get started with that. And then I moved back to
Maine after that. And I worked for an environmental safety
company doing lots of air testing and air monitoring and
industrial hygiene related stuff.


Steve Badger: [00:03:22] Then I moved back out
of state again, went down to the southern part of the country,
down to Kentucky and Tennessee, and did a lot of work at the
Tennessee Valley Authority Plants doing industrial hygiene,
monitoring and safety related to that. Shortly after that, I came
back to Maine again and did some more work in the environmental
field and started doing a lot of work in the paper industry,
doing safety related job safety analysis and things like that for
the different companies that I worked for. And then a while after
that, I started as the safety director for Fisher Plow, which
gave me some industry related [00:04:00] background, which was
really interesting. You know, to see a snowplow being made is
something that we take for granted every year here in the
northeast part of the country. But there's a lot that goes into
that, a lot of safety and environmental concerns there. So and
then, of course, I've been with MEMIC now for about ten and a
half years as a full time employee. So, you know, I feel my
background has been varied and it really has helped me in the
years.


Peter Koch: [00:04:26] Yeah. It really kind of
rounds everything out when you have that experience in all those
different industries and makes you be able to I think at least
that on my side, to be able to appreciate some of the challenges
that a particular industry might have with either compliance or
managing safety within their particular industry. But tell me a
little bit more, because I know working with you over the last 10
years when I kind of think about OSHA and I want to have kind of
an interpretation of maybe what a standard says, especially
around the environmental [00:05:00] side of things or HAZCOM side
of. Things I tend to think of you and I go back to you and I
start thinking about, well, what would Steve what's Steve's got
some insight into that maybe he can give me a little guidance in
those areas. So talk to me a little bit about kind of your
experience with OSHA and how you became, I guess, as interested
as you are in the standards and then kind of going through their
lists.


Steve Badger: [00:05:24] Sure, absolutely. You
know, my interests have always been and I'm a numbers kind of guy
and I like looking at, you know, these lists and frequencies and,
you know, and how these things tie together with the frequently
cited standards. How do they apply to the real world? You know,
how do they apply to the injuries and incidents of that happened
out there? You know, is there any correlation to it? And we
certainly can talk about that later on as we go through this.
But, yeah, that was my interest was really looking at and trying
to figure out, you know, why are these top [00:06:00] ten
violations? Why are they there? And, you know, is OSHA focusing
on these things or is it these things that they see every day is
they're driving from point A to point B or they get a complaint
or something. And so, you know, trying to figure that out, you
know, is really important. And we certainly can delve a little
deeper into that is as we go through this. But, you know, it
really gives us an insight as to what hazards are out there.


Peter Koch: [00:06:28] Yeah, perfect. And OSHA
has tons of lists as we start to go through. And they really
become a good repository for us for numbers as and they take
numbers from the Bureau of Labor Standards and they pull them
together and they analyze them and try to figure out sort of
where some of the focus's are. And one of those lists we're going
to talk about today is the top 10 most frequently cited
standards. So why don't you tell us a little bit about what are
the top 10 most frequently cited standards and where do they come
from, [00:07:00] where they derived from?


Steve Badger: [00:07:02] Sure. Certainly the
number one and it has been number one most years, certainly
within the last 15 years, is fall protection or the lack thereof.
And most of that comes from the residential construction. And in
a lot of that is because, you know, is you know, is complaints
are made war as OSHA happens to be driving by. They're going from
point A to point B, they see somebody in an imminent danger
situation, meaning that, you know, the worst hasn't happened yet.
They have not been injured, but they are in a situation where
they could be injured or it could be a fatality if the person
should fall. So that's the number one citation that's out there.
Number two, which is near and dear to me, is the hazard
communications and hazard communications for the general industry
side of things. It's always been number one for the last 15 years
in [00:08:00] the overall list. When you combine the two
together, it usually comes in second or third. And typically that
has to do with one not having a written program. It's usually,
number one, not having the safety data sheets, as we now call
them, in place, and people just not being trained. You know what
are the hazards of these chemicals? Number three, this past year
was respiratory protection. And there's a whole host of reasons.
Again, take a look at what was going on in our past year, you
know, with covid-19 and, you know, and other issues and the
difficulty of getting respirators. A lot of people took some
shortcuts with respiratory protection.


Steve Badger: [00:08:41] Maybe, you know, some
of those were things like not having a medical clearance to be
able to wear a respirator. That was a big one. And again, not
having a written program in which would have indicated to them
that they needed to do these things, scaffolding came in number
four. You know, scaffolding is one [00:09:00] of those things in
construction and general industry that people use to get to upper
heights, to be able to access something that they might not be
able to get to from the ground. And there's a lot of rules and
regulations around scaffolding, and it's very easy to make a
mistake when it comes to scaffolding. Ladders was number five and
typically with the ladder use, it was people not using them
appropriately. And as most of us know, there's right ways and
wrong ways of dealing with or handling ladders and how we access
them and how we secure them from falling. And, you know, that
message just doesn't seem to get out there sometimes. Number six
was lock-out tag-out or controlling hazardous energy. And this
one has more than just electrical implications. This has to do
with pneumatics and hydraulics and lots of other types of
hazardous energy that can seriously hurt or killed somebody.
Number seven this past year was powered industrial trucks or
forklifts. And typically [00:10:00] the citations that went along
with that had to do with the, you know, the operators not being
properly trained or the authorization from the employer, even
though they might have been trained, they weren't authorized to
use it, you know, in doing their daily inspections to make sure
that that powered industrial truck is actually safe to operate.


Steve Badger: [00:10:20] We get to number eight,
which was, again, a fall protection related issue. And in this
case, here, it was training requirements and these training
requirements, this had to do with not having a written program,
not doing what we call training that is documented by a competent
person that is not a certified training. And so there was a lot
of citations. So between number one being fall protection and
number eight, there was nearly 7000 citations alone just in those
two areas. Number nine, was eye and face protection, personal
protective equipment and again, these are very important
[00:11:00] ones because we only have two eyes and if we're not
protecting our eyes, you know, we lose something there. And so
there was a lot of those types of citations. And then number 10
this past year was machine guarding. You know, we talk about, you
know, guarding on pulleys and saws and all kinds of different
types of machinery that has nip points and places where people
could get their hands caught or their arms caught or some other
part of their body or something they're wearing gets pulled into
that piece of equipment. So, you know, it certainly is something
that we you know, we could spend a whole day talking about just
machine guarding because there's so many different issues around
that. So that really rounds out that top 10.


Peter Koch: [00:11:44] Yeah. And it sounds like
as we start to look at each of these top fall protection, hazard
communication, respiratory protection, scaffolding ladders, lock
out, tag out forklifts, fall protection again eye and face safety
or PPE and then machine [00:12:00] guarding. You know, as we
start to look at that long list, there's a lot that goes into
each of those standards. And it seems that OSHA is you know,
those citations are coming from particular parts of those
standards that employers tend to miss. And I think that's one of
the important things that we can think of this list as it is a
reminder that, hey, these issues are out there. And, yes, they're
coming from citations and OSHA is doing their enforcement process
and finding these citations that way. But really, it's a good
reminder that this happens all over. You know, if you have
someone that uses ladders within your facility, know that Ladders
was number five this year of the most frequently cited standards
for OSHA. And if you have ladders, there's probably something
that you can do to improve in that section. So ladders or
utilizing [00:13:00] this list as sometimes a guide or a check to
say, hey, how am I actually doing? How would I stand up as an
employer for workplace safety based on this year's standards? So
let's think about this. So this was this was from 2020, correct?
The list that you just read off was from 2020.


Steve Badger: [00:13:23] Yes, that's correct.
This is for fiscal year 2020. So I caution people, if you go out
there and you're looking for these and these lists from other
sources, maybe a magazine or maybe some other online service, you
just have to be careful because sometimes these numbers don't
seem to match up because they're doing fiscal year versus
calendar year. And so the numbers can be a little bit differently
because the fiscal year for 2020 ended in on September 30th. So
we had several months after that to where some of these numbers
may not match up. And [00:14:00] you're looking and you're going,
wait a minute, you know, how can it be that much different? And
it is because of the calendar year versus fiscal year.


Peter Koch: [00:14:06] It's a really good point,
especially if you're trying to prioritize something and say,
well, where do I want to focus? I want to focus on the place that
maybe has the most frequency and it doesn't line up. So that's a
really good point. Let's talk a little bit about because this is
not the first year that has done this. They've done this for
quite a while and have put together these lists of the top 10
most frequently cited standards. How does this year's lineup
match up to say what happened in the past? So are they the same
standards that keep getting cited all the time? Or are there
significant differences from year to year?


Steve Badger: [00:14:45] Yeah, it's a great
question because, you know, when you look back, I mean, just for
an example, in 2011, the top three citations frequently cited
violations were fall protection scaffolding and HAZCOM.
[00:15:00] 2012 fall protection HAZCOM scaffolding, you jump
forward a couple of years to 2016, fall protection HAZCOM
scaffolding. So as you could see, these things do not change
greatly from year to year. That top 10 tend to stay top 10. Now,
there is some movement within that in this particular year, you
know, for fiscal year 2020, the biggest mover within that was the
respiratory protection. And as I mentioned, I think a lot of that
was probably had to do with, you know, covid issues that people,
you know, what are you giving people respirators because of the
fear of somebody catching it or passing it along to someone else.
So there was a lot of those type of issues, and most of those
came because of initially just giving somebody a respirator and
not making sure that they're medically cleared to wear it, which
is, as we all know, could be a pretty dangerous situation for
anyone that has any breathing difficulties,


Peter Koch: [00:15:56] As could many of these
standards. If you think about [00:16:00] it, especially as you
have mentioned, as you're describing some of the citations, many
of those around training or authorization and OSHA as well as
myself. And I think you personally as well think that there's a
responsibility on the employers part to not only choose the
people that should be doing the particular tasks correctly, but
then authorize them to do that task, give them permission to do
that task. And then the employer has a responsibility to provide
the appropriate level of training so that they can be competent
in the task that they're doing. And part of that is understanding
the hazards that they're exposed to and the controls that need to
be in place. And respiratory protection is a really good one.
Because you put a respirator on and you see it all the time, you
know, people will wear a paper mask, respirator, sweep and dust
up in the shop someplace or they'll have a full face respirator
on with. [00:17:00] And what you can see is their beards sticking
out underneath the bottom of it. So they've understood that
there's a hazard. They're utilizing a particular piece of
equipment to help protect them from it. But they're not really
understanding the limitations of that piece of PPE. So they're
using it incorrectly and probably or possibly putting themselves
at greater risk for the hazard that they're exposed to.


Steve Badger: [00:17:28] Yeah, absolutely. With
the respiratory protection, it can give you a false sense of
security that, you know, it's doing something for you. Whereas
like you mentioned, you know, somebody's beard is sticking out
from their respirator. That human hair is many, many times larger
than a lot of the particles in the things that were inhaling.
They get down deep into our lungs and cause the infections and
those type of issues. So wherever that hair is sticking out,
there's that much less protection that we have. And so it does
give us a [00:18:00] false sense of security. Sometimes if we're
not properly fit tested, we're not properly trained. To even put
it on can be a big issue because that was something I always used
to do with respiratory protection training. Was just hand some of
your respirator and tell, OK, put it on. And, you know, probably
half of the people would have it on sideways or backwards or, you
know, upside down because they just didn't understand how that
was to go on. So you can imagine with the covid-19 issues and,
you know, respirators just being handed out, there was probably a
lot of people wearing those incorrectly.


Peter Koch: [00:18:33] Yeah, I can totally
imagine that. And then the same thing happens with fall
protection. You see that often people using ladders incorrectly,
people using harnesses incorrectly. And some of it stems from
inappropriate training or lack thereof. Some of it stems from not
having the right equipment and some of it stems from possibly
ignorance around what the hazards are and the limitations of that
particular equipment that they're handed given or that they've
[00:19:00] brought themselves to the job site sometimes. So it's
interesting if and if you go back to 2011 and fall protection in
2012, fall protection 2016 fall protection, and here we are again
in 2020 fall protection is number one HAZCOM number two. To 2016
HAZCOM number two, 2012 HAZCOM's  number two. Why are we
seeing the same, I know you're not going to have an official, you
know, Nostradamus like a predictive answer here. But I guess in
your opinion, why are we seeing the same citations over and over
and over again?


Steve Badger: [00:19:45] Yeah, I think there's a
few really important reasons that I think sometimes it comes to,
you know, lack of knowledge, you know, people, you know, they
received these citations and they and they're, you know, doing
work. [00:20:00] And so we'll pick one here has the
communications and they  buy a chemical, they don't realize
that, you know, even though you go to, you know, your local
hardware store and you buy this chemical, that you have to train
people how to use it properly. And so there's some of that is
lack of knowledge when it comes to things like fall protection.
Sometimes, you know, people are in that mindset that, you know,
this is the way we've always done it and we haven't had any
serious injuries before. We've never had that, you know, that big
issue that has come up. So they don't tend to change until
there's something to motivate them to change. And so it could be
an injury. It could be a citation. Sometimes people worry about
the cost. You know, these you know, they're always fearful of,
you know, they have their own business.


Steve Badger: [00:20:50] And if we put, you
know, all this money into fall protection, you know, is that
going to leave anything left for the business, you know, profit
wise? And I always talk to people about that [00:21:00] and let
them know, look, you know, can you afford the cost of somebody
getting injured? You know, that's going to be a much greater cost
to you than buying and training people how to wear a harness, you
know, appropriately, you know, that personal fall protection
stuff. So, you know, culture. Culture is always a big one that we
always talk about, because sometimes people just, you know, don't
have that culture within their company that helps them understand
from the top down that, you know, your safety is our number one
goal. You know, it is. And, you know, sometimes people will say
it's number two or number three goal for a company. But, you
know, the companies that have the best cultures, they understand
that their workers, their employees are their number one asset.
And if they don't protect those people, they are going to be in
trouble.


Peter Koch: [00:21:54] Sure. I think that's
those are all good, good insight into why we keep seeing
[00:22:00] it and when you really think about it again. So if you
take those factors, it could be culture, it could be cost, could
be motivation, could be something else that's driving someone to
not take a step in the right direction. We're also seeing, I
think when we can talk about this next here we are seeing the
same citations or the same categories of citations show up
because they're the most frequently people are exposed, the most
frequently to these things in the workplace. And that shows up. I
think, unfortunately, as we start to look at our lagging
indicators, they show up in our injury statistics. So can you
talk a little bit about maybe how these citations correlate to or
these standards, standard citations correlate into injuries and
maybe what BLS or the Bureau of Labor Statistics might show for
us?


Steve Badger: [00:23:00] Sure, [00:23:00]
absolutely. You know, as I mentioned earlier, I'm kind of a
numbers guy, I like to look at the numbers. And in this case
here, if you take the data that came out of the Bureau of Labor
Statistics for 2019, when we look at construction, you know,
residential injuries, fatalities, that happened because people
did not have proper fall protection. There were more than two
thousand seven hundred and ten injuries just in that year of
2000, 19 from people falling to a lower level. There was also
seven hundred and eleven fatalities, which was the number one
thing that caused fatalities in construction and it is every
single year. So 711 people that went to work last year, that did
not come home. So it absolutely correlates to these citations.
Another example of this is exposure to harmful substances in the
environment and which is covered by hazard [00:24:00]
communications. There were over 640 fatalities related to that.
People using chemicals and think bad things happen, whether it
was overcome with the chemical, the vapors or the gases that were
related to that. Or maybe there was a physical hazard, something
exploded or burned and caused that type. And then looking at
respiratory protection number three in 2019, which was where we
started this covid thing, they were five hundred and thirty three
violations just on no medical evaluations. And so when you think
about that and how many people may have been injured from that,
you know, is hard to tell because sometimes those numbers don't
always translate to the Bureau of Labor Statistics. But you can
see from these numbers that they really do tie back to this top
10 citations in a very disturbing way.


Peter Koch: [00:24:59] Sure. And [00:25:00] it's
really interesting. I just I just pulled up while you were
speaking there. I went on to, you know, your favorite site,
Google. Right. And I searched OSHA top 10 most frequently cited
standards for 2019. And so you related that in 2019. And
residential construction falls to the lower level, generated
twenty seven hundred or so injuries and over 700 fatalities.
Well, guess what? The top citation was in 2019 fall protection.
And there are, you know, upwards of 6000 different citations for
fall protection, just the general requirements. So not providing
or not protecting the worker from the unprotected edge at some
point in time. And then number two, so the second point, you had
so exposure to harmful substances and environments of 642
fatalities. Hazard communication was number two in 2019 with 3600
citations. [00:26:00] So it's substantial. There's a strong
correlation between what we're seeing as the top 10 most
frequently cited standards and that lagging indicator of injuries
and fatalities. And you talked about earlier, like, why do we
keep seeing the same ones over and over? One of those was lack of
motivation until there's an injury or a citation and then we come
into compliance or we step up our game a little bit. But
predictively, I think and as a safety guy and I like numbers,
too, maybe not quite as much as you like numbers, but I like
numbers, too. As we start to look predictively, you know, you put
these two things up here, you put the BLS information up in front
of you for the injuries and fatalities around cause. And then you
start to look at the most frequently cited standards. And I think
you've got a pretty good roadmap of where to look in your
business, at least a checklist [00:27:00] of what to look into
and see how do I measure up. So how am I doing on fall protection
where does my HAZCOM program look like if I got scaffolding, how
does that work? And I went, who's authorized to use it? Who's
authorized to set it up, how do I inspect it? Do I even know what
OSHA requires for compliance around scaffolding or did I just buy
it off a buddy and we're working on it because I need it. Which
is not a bad thing by it. However you need it. If you need that
tool to do your job, awesome. But then understand what the
limitations are and where you should be focusing in order to keep
your people safe. And again, so you want to get the biggest bang
for your buck. The top ten might be a place to start for sure.
For sure. Any other thoughts on that, Steve? Any other thoughts
are on correlation between citations and injuries and how the
numbers kind of fit together and places that employers can or
things that employers can use to. Focus on. [00:28:00]


Steve Badger: [00:28:01] Yeah, I you know, I
think the you hit it, kind of hit it on the head there about not
knowing, you know, kind of not knowing what they don't know. And
that's where I think, you know, we you know, we can certainly
help with that. You know, when companies come to us and say, you
know, we use scaffolding and but we're not sure what we're
supposed to be doing or with hazard communications, what are we
you know, I can read the standard and I get very confused by it,
which we hear a lot. You know, what do I have to do? So that's
where, you know, we do some training. You know, we sit down with
our insureds and talk about these things and, you know, try to
put it into terms that people can understand, because that's all
about, you know, when we talk about hazard communication, they
you know, that's a that rule, that law that is in effect is the
right to know law. And so you have that right to know, but you
also have the right to understand. And so, you know, for the
employee that's working with this stuff, they need to understand
that if they do something inappropriate, [00:29:00] that bad
things can happen from that.


Peter Koch: [00:29:03] Sure. Perfect. I think
that's great. So a couple of places to look. Look at the Bureau
of Labor Statistics, their information. Look at the top 10. And,
you know, certainly use your insurance carrier, MEMIC. If you
have a different carrier, use them or your trusted agent partners
to look out. Or maybe you're some of the industry experts that
are out there to kind of get some more information on some of
these areas that you might not have full knowledge of. And they
can be complicated. I was looking at you know, workplace safety.
There's really two components. There's the moral component to it
of like I really want to make sure that all my employees go home
in the condition that they came in. I don't want them to get
hurt. They could be sore. They can be tired just from physical
activity and labor. But I wanted to get hurt. I want them to be
safe so there's their moral component. And then sometimes that
moral component, you get [00:30:00] to a point where I don't
really know how to do it. And the compliance side of it, the
standards that OSHA put out together put there is that tends to
help with that because it gives you a baseline. Here's the
minimum that you can do to try to mitigate the exposure to the
hazard that your employees have while they're in the workplace.
So those two pieces together and certainly the OSHA top ten gives
you an idea of where to focus and what's going to give you the
biggest bang for your buck generally. And obviously, if you're
operating a company that doesn't have hazards that are
encompassed by the top ten, it's not going to give you a whole
lot of help. But certainly if you do if you use any of those
things, the top 10 is going to going to give you an idea of where
to look and then what standards to focus on. So not a bad deal.
Well, let's talk a little bit about how Osha comes up with these.
You mentioned earlier that [00:31:00] there were there are
different ways that, you know, OSHA might drive by or OSHA might
come to your business to inspect or to look for how you're doing
on the compliance piece. And it's that partnership of helping
keep the American workers safe by working with the employers out
there to get them to understand where some of the gaps are within
their safety process. So how does OSHA come by the citations and
how do they come by citing businesses for not following the
standards?


Steve Badger: [00:31:38] Yeah, that's great, and
I'm glad you mentioned the partnership part of this, Peter,
because that's how we absolutely need to look at this. This is a
partnership. OSHA's job is to protect that worker, your employee,
just like it is yours. And that's why it's a partnership. It's
not and it should never be an adversarial type of relationship.
They're [00:32:00] not there to cite you. They're not there to
fine you. They don't get their you know, their funding from the
number of citations that they give out. They're there to help you
keep your people safe. So, you know, it should be treated as a
partnership, not as a bad thing. You know, I always use the
example. You know, it's like police. Their goal isn't to write
tickets. Their goal is to keep people safe. And with OSHA is to
ensure a safe and healthful workplace that's written into their
preamble, into their you know, this is their purpose is to help
create that environment. So moving on to, you know, what do how
they go about these inspections is, you know, they really it
breaks down into two different types of inspections. There's
programmed inspections. We'll talk a little bit about that in a
minute. And then there's unprogrammed ones. Now, these
unprogrammed ones can be anything from an imminent danger
situation, meaning that they happen to be driving from point A to
point [00:33:00] B, they see somebody on a roof or maybe they're
working in a trench where they're not being protected. If that
trench should collapse, they could they could be crushed or
killed in there. Those they call those imminent danger situations
where they have to stop at those because the worst has not
happened yet. But potentially it could. And so that their number
one, you know, unprogrammed is these imminent danger type of
situations or somebody may call them and say, hey, you know, if
you know these you know, this is this roofing project going on
somewhere. And, you know, there's a bunch of people working
without fall protection. They absolutely are going to respond to
that because we know what those outcomes of those falls can be,
that they can be fatalities.


Peter Koch: [00:33:51] No, I just I was
thinking, as you're talking about imminent danger, there's an
interesting video on YouTube, and I'm sure you've seen it. An
[00:34:00] OSHA compliance officer had driven past road
construction that's going on. And there's an open trench
happening there. And all you can see in the video is he's already
come on site and he's introduced himself and he's asking just
questions like, hey, what do you doing how long you've been
working there? He's asking the guy to get out of the trench,
pretty unstable. The guy is pretty much standing on a pipe in the
middle in the middle of the trench and within. I don't think the
video goes for longer than maybe 40, 45 seconds. Within that 45
second time frame, the size of the trench start to sluff and the
guy jumps from where he's standing to another pipe to get out of
the way of the collapsing trench. And had the OSHA guy not been
there, the person might have might have been in a lower segment
of the trench and not able to jump out of the way had been
buried. So that imminent danger piece is [00:35:00] helpful. And
I think it highlights sometimes As an employee or as an employer,
we might not recognize the danger that we're in, which is why we
have standards there. So I might be really comfortable with that
risk up until the time that I get crushed or I do fall or I am
exposed to very hazardous chemical and all of a sudden I'm not in
a place where I can work anymore.


Peter Koch: [00:35:28] Let's take a quick break
so I can tell you about MEMIC online instructor led training for
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class. Check out the full schedule of MEMIC workshops at
www.MEMIC.com/WorkplaceSafety. Now let's get back to today's
episode.


Peter Koch: [00:36:28] So it's an interesting
it's an interesting video, I think it really does highlight how a
compliance officer can, especially in an imminent danger
situation, be able to help. But unfortunately, there's not that
many compliance officers and they're not going to be able to
drive by every workplace in order to help you be safe. So there's
other ways that OSHA has from a priority standpoint in these
unprogrammed inspections. And you talked a little bit about
someone [00:37:00] maybe calling in a complaint or a referral
that be another one of those ways to for them to be called to an
inspection, correct?


Steve Badger: [00:37:09] That is correct.
complaints, they may be called in complaints. They maybe somebody
has filled out a form and submitted it, you know, through the
through their website. Those complaints they do take seriously
and they certainly take more seriously those ones where someone
has taken the time to fill out a form and put it in. It can be
done anonymously. They get a lot of calls, quite frankly, people
maybe disgruntled former employees or maybe somebody didn't get a
job bid that they were hoping to get. You know, they get a lot of
these complaints. So they, you know, being not many people to be
out there and do these inspections, they have to pick their
battles, they have to pick, you know, what ones, you know, mean
the most. And if somebody fills out that form, they're going to
take that seriously. Referrals can come [00:38:00] from a number
of different sources. They can come from here in the state of
Maine. We have safety works they may have gone into and done a
walk through of a certain facility or a business and found some
hazards and made sure that the employer knew about those hazards.
And if they have chosen not to fix those or not to correct those
hazards, they may refer that, you know, further on other
referrals come from places like EMS, fire, police, where they
maybe they've had to go and take somebody, you know, to a
hospital to get care because they fell off a roof. So sometimes
those referrals can come from those directions as well. The
second most common of the unprogrammed inspections are the
fatalities and catastrophes. That's where the worst has happened.
Something bad has happened. Somebodies fallen off a roof. They've
been killed or somebody has been put into the hospital because of
a situation. And that's also one of those things where, you know,
you as [00:39:00] an employer have to make sure that OSHA is
aware of these things. OSHA requires that any fatalities that
happen on your job site, you have to notify them within eight
hours of that fatality catastrophes such as somebody being put
into the hospital, you have up to 16 I mean, sorry, 24 hours
excuse me, to be able to put that in. But you have to let them
know that is part of the rules as part of the law, that you have
to let them know about those. And so they will absolutely follow
up on those things. You know, anything whether there's an
amputation or somebody loses an eye, they're going to investigate
that. They're going to require you to, you know, talk to them a
little bit about that and what you're doing to prevent that from
happening again.


Peter Koch: [00:39:45] And I think for those
specifically, I meant obviously imminent danger is something
that's pretty obvious from a fatality and catastrophe. You know,
something has happened. Like you had said, the worst has
happened. And OSHA now [00:40:00] is trying to work with you not
so much to point fingers and say, hey, you're doing something
wrong. But, hey, let's look at your process. And what did you do?
How did you, how did this come to be? Why did it happen? Because,
you know, honestly, not that the OSHA standard covers all of the
situations that could be out there from a workplace hazard
standpoint, but in particular for the most frequent causes of
injuries and fatalities. The standard if you apply the standard
well, it will cover the majority of the potential problems that
would cause injuries or fatalities that are out there.
Catastrophe's serious enough injuries to put somebody in the
hospital for a period of time. And they're really there to help
you figure out how to prevent this from happening again. And
obviously, they're doing it from a compliance standpoint, but
they have to that's part of their mission [00:41:00] standpoint.
And you can you know, if you took the OSHA top 10 standard or top
10 most frequently cited standards to begin with and started to
go through your business. And how are you doing on the compliance
piece? You may never get to the imminent danger inspection, the
complaint or referral inspection or the fatality or catastrophe
inspection. So, you know, one of the other, they can help you get
to a place where the injury or fatality, either will never happen
again or won't happen in the first place. Awesome. So there's one
more type of inspection out there we talked about the
unprogrammed, the inspections. And why don't you talk a little
bit about the programed, inspections, because I think that's a
pretty interesting piece because it does have more numbers
involved in it and how they determine where they go.


Steve Badger: [00:41:49] Absolutely. With the
programed inspections, there are different. A couple of different
kinds that we want to talk about first is sometimes they have a
local emphasis [00:42:00] program where the local will say state
of Maine, OSHA taking statistics from the Bureau of Labor
Statistics or, you know, taking them from other sources that
there are a lot of particular injuries in a particular
occupation. And so they will take those and say, OK, we're going
to focus on that this particular year here in the state of Maine.
You know, at different times we've had sawmill's we've had things
in the health care industry for local emphasis in what they will
do is they will focus on those because they're higher than, you
know, the average types of the numbers of injuries and the
frequencies. The other type that goes kind of goes along with
that are national emphasis programs where OSHA as a whole is a
federal agency is focusing on a particular subject, in this case,
one really common one is silica. The exposure to crystalline
silica is a huge one for [00:43:00] them at this point, because
silica is one of those things that, you know, it's naturally
found mineral in the ground. People, you know, people get exposed
to crystalline silica through, you know, cutting of concrete and
things like that and dust and so, you know, as more time goes on,
they're finding out that the levels of exposure are higher than
what they should be. So as they are going along in time, they
ended up, you know, doing more of these inspections and keeping
the exposures down so that people aren't getting sick from this.
Again, that partnership, you know, helping those employers, you
know, realize that, wait a minute, this is something that is
serious can make people sick prematurely and have breathing
difficulties, which, you know, with silica, a good example that
once you have it, you know, you once you have silicosis, it
doesn't go away. It's something you have for life. So we
certainly want to try to avoid that as much as possible.


Peter Koch: [00:43:58] Yeah, for sure. Now, with
[00:44:00] the program inspections, if I wanted to find out what
emphasis programs were, were in my area, in my state or maybe
what national emphasis programs were and what I would be affected
by, where would I go? Where do I look that up? Because it's not
something that you see a lot in the newspaper or find unless
you're following safety publications, you're not going to see it
all the time. So as a business owner, how do I find out what
those national or local emphasis programs are?


Steve Badger: [00:44:30] Yeah, absolutely, the
best place to take a look for these are is at the OSHA.gov
website, www.OSHA.gov for government is absolutely the best place
to go. And if you do a search when you go in there, they have a
very, very good search engine for their website. And you go in
there and you plug in local emphasis or national emphasis
programs, you will see you there will pop up and tell you
different [00:45:00] ones and even some past ones that they've
looked at, you know, previously. And then maybe now they put an
end to it. You know, maybe they're focusing on something
different to, you know, a different type of industry or
something. But that is by far the best place to look. Some of the
trade magazines will have some of that information, but it
doesn't really go into why they're focusing on those particular
things as much as OSHA does.


Peter Koch: [00:45:25] Good. I think that's a
good place. So. OSHA.gov, good place to go. I know I go there
fairly often as part of my job and I guess as a safety, as a
safety consultant, you're going to go there as a safety person at
a particular facility. It might be a good place for you to check
out to. I know quite a while ago here in Maine, I know that one
of the, I Can't remember if it was a local emphasis program or a
national emphasis program, it was an emphasis program around
amputations for metal [00:46:00] fabrication facilities or metal
fab businesses. And the employer that I was working for at the
time had fabrication shops. So we had employees that were
actually working under that classification. And I remember
getting a letter saying that, you know, chances are because of
the national emphasis program or because of the emphasis program
for metal fabrication facilities, an inspection may occur. So you
get notice right in the program inspections. If you have
employees that fall under that classification for the work that's
happening and you may get a letter in the mail saying that you
might get inspected, it doesn't mean you're going to get
inspected, but you very well might get inspected.


Steve Badger: [00:46:50] Absolutely. And, you
know, if you do get that letter, that doesn't necessarily mean
that you've done something wrong. I always like to point that out
as well. Just because [00:47:00] you're in that particular class
code or that particular industry, they're going to try to see as
many of those industries as many of those businesses as possible
within that period of time that that emphasis program is open.
So, yeah, I always like to stress that, that it's not just
because you've done something wrong, it's just because you're in
that particular industry.


Peter Koch: [00:47:22] Yeah, right on. I think
it's worthwhile just spending a minute or two here about if an
inspection does happen, if she shows up on your job site for
whatever the inspection priority is, could be imminent danger
could be because you called them for a fatality, could be because
it was a referral or you might be part of the program inspection,
sort of what happened. So I guess if they show up, they're going
to provide proof of who they are. They are they're required to
produce their identification, their badge and state the purpose
of what's going to happen and then really have an opening
conference with you to tell [00:48:00] you what's going on, why
they're there. And one of the things that will probably happen, I
mean, it doesn't happen all the time, at least in my perspective.
But you might actually have a request from the OSHA compliance
officer for you to hand over, give them five years of your OSHA
logs. Now, I think it's there's some pretty good data in those
OSHA logs. But do you have any insight of why OSHA wants to look
at those OSHA logs and maybe how those OSHA logs can be used as
the employer as a as a good place to continue their safety
efforts?


Steve Badger: [00:48:41] Yeah, absolutely, you
know, and I'm glad you again mentioned about the partnership
thing, because that is where, you know, that partnership, you
know, begins when they come on the site after they've been
identified themselves. And, you know, in that, you know, that
relationship is very important to build on from the beginning,
that, again, they're not they are their [00:49:00] purpose is not
there to fine you or to berate you or, you know, make you feel
bad about what happened. It's to find out what did happen. And so
that's kind of where this the OSHA logs come into play as well as
because they want to know, you know, they want to look at these
five years, you know, sometimes they don't. But they want to see
what types of injuries you've been having as a business and are
there like repeated numbers of injuries of certain types, like,
for instance, you know, if you have a large number of hand cuts,
we'll say each year. You know, you you've had, you know, in this
department or that department year after year, you're seeing that
that's going to kind of indicate to them that you are not
controlling that hazard as well as you should be.


Steve Badger: [00:49:47] And so they're going to
look for those type of things and point those out and say, OK,
let's focus on this a little bit. I see I see them also look at
like hearing related issues where, you know, there's been hearing
loss. And [00:50:00] if there's multiple people that have had a
hearing loss within your industry or within your company, what
are you doing about that? You know, that kind of opens the door.
They'll ask some, you know, some questions about that. But again,
it's all in that spirit of partnership that they want to help you
try to identify what those issues are and how to help control
them. They're not going to offer you and say, OK, you need to do
X, Y, Z. That's not their purpose. Their purpose is to, you know,
say, hey, you know what? This is an issue. You know, they don't
authorize pieces of equipment. They don't you know, that's not
their job. It's to try to help identify what those things are.


Peter Koch: [00:50:40] Nice. And it seems that
they're really using that OSHA log in the same way we should be,
not we being safety consultants, but we as the employers should
be using that OSHA log to really look at it for trends. They're
looking OSHA looking for insight into how's that business doing?
They might not have experience [00:51:00] in that particular
business or that well in that particular industry, but they're
going there and they're looking for clues as to What is the what
are the challenges, what are the problem. Not so much problems.
What are the challenges that the company is having around
workplace safety? And then and then pointing out maybe here are
some places where you can step it up a little bit and do a better
job for workplace safety. And again, there's a list. It's an OSHA
list. It's a list you keep for OSHA, but it's certainly a list
that OSHA requiring of the injuries and illnesses that you're
going to have in the log. Another pretty good list for us to use
to help get ahead of the curve from a workplace safety
standpoint. There's a lot more on inspections, we can do a whole
podcast around OSHA inspections and what the process is and what
the rights are of employees and employers, I don't think this is
the place to talk about those now. I thought [00:52:00] it was
important to kind of get an idea of some of the paperwork that
might go around those OSHA logs.


Peter Koch: [00:52:05] But let's talk a little
bit about now that we Know about the OSHA top 10 list and where
it comes from, that we see repeated citations year after year. We
have many of the same standards are in the top 10 list year after
year. And sometimes, like fall protection is going to be number
one in years running. What can we do with that? Like, how do we
get to a place where we can take the OSHA top 10 or even some of
the other information that OSHA provides us in the lists and
develop solutions around injury prevention and hazard mitigation?


Steve Badger: [00:52:44] Sure. That's great to
be able to follow up with this, because, you know, really, you
know, first and foremost for me is the employer's mindset that,
you know, I mentioned when we started out that, you know, that
philosophy, you know,  [00:53:00]it's too costly or, you
know, it can't be done that changing that mindset to it can be
done. And how are we going to do it that that is key to changing
that company culture, which goes hand in hand with that. And as
IO mentioned, that's going to be a top down. That's going to
start with the ownership, the management. And just saying, you
know what, we've had enough of this. We are going to change our
belief in how we approach safety. And taking a look at this list
and other lists are going to be the way to do that, to change
that culture, to stop thinking about it from a lagging
perspective. As you mentioned earlier, those lagging indicators
changing it from reactive to proactive. How can we do these
things initially? How can we prevent these things from happening?


Peter Koch: [00:53:51] Have you had experience?
I don't mean to interrupt. I'm just thinking about this from
changing that mindset from a can't be done to a can be done. I
expect you've had stories [00:54:00] with the employers that you
work with where they've had a significant injury or maybe even an
unfortunate fatality within their workplace. And they've had to
deal with family and co-workers of the injured or the severely
injured employee or the employee that's passed and their mindset
changes. It goes from it can't be done to a can be done because
they have a mission that's really not we see that happen often.
But what we would rather have is them use these proactively, like
you said, like don't wait for the problem to happen. Like, if all
protections your gig, if that's what you do day in, day out
within your industry, it could be construction, it could be
roofing, it could even be maintenance. It could be as an
arborist, it could be whatever it is. If you have a fall
protection component to your business, know [00:55:00] that it's
going to happen to you. So be proactive with. So have you seen
that happen within the employers that you work with where you
have a significant event that changes the mindset?


Steve Badger: [00:55:12] Yeah, yeah, I've seen
it in more than one time, you know, with more than one of these
in this top 10 where either a fatality or a serious injury has
happened. And that really has changed the culture, which, you
know, you hate to see it happen because of that. But you're glad
to see that it's being taken seriously at that point where all of
a sudden, you know, somebody says, you know what, we've got to
stop thinking about this the way we did 30 years ago or 40 years
ago. We have to come into the 21st century and say, OK, this can
be done. How can we do it? You know, I've worked with companies
that work again fall protection is one of the big ones where it
used to be that to put up trusses, they'd be walking the plate,
you know, meaning that they're on the top and they're doing this
balancing act [00:56:00] and they're trying to hold these trusses
up and nail them together. And, you know, having the mindset, is
there a better way? Is there a better way to do this? Well, maybe
it's putting together on the ground and lifting all up in one big
piece. So you've eliminated that fall hazard. And that's how we
always want to approach these things, is can we eliminate them
first or can we reduce that hazard to the point where it's going
to be negligible or something we can better wrap our hands
around?


Peter Koch: [00:56:29] Yeah, that's great and
again, proactively looking at it and using this list to go there
and then moving further through the solutions piece, the employer
is a critical part of this, like their mindset, like you said,
and moving in that company culture from top to bottom. But then
we get to the employees and they play a significant part in this,
too. So how does the employee piece fit into injury prevention
and hazard mitigation?


Steve Badger: [00:57:00] Certainly [00:57:00] we
want to you know, obviously when the employer wants to start
with, you know, the employee awareness, so what the hazards are
in the workplace. You know, these are, you know, what the hazards
are. And this is what we are going to do to prevent these from
happening. It may be, you know, training. It may be, you know,
proper fall protection, it may be scaffold, you know,
construction, training, all of these different types of training.
And then, you know, the important thing is there is that the
employee sees that this culture is changing, that, you know, it's
really a positive step. And that's going to give them that buy in
that place where they understand that. You know what? It really
is up to me. My boss isn't going to be there every minute of the
day. But, you know, I had this conversation with somebody
recently about having respect for themselves so that they're not,
you know, injuring themselves or worse, but also respecting the
company as well. You know, that even though I may not have
somebody, [00:58:00] you know, standing over me, making me wear
this harness, that I'm going to do it because it's the right
thing to do.


Peter Koch: [00:58:06] Yeah. For them to get by.
And I kind of think about that from an awareness standpoint. How
do you use the top ten list? Well, maybe you end up using that in
a safety meeting or a toolbox talk or it gets posted up in the
break room. And maybe you can put up a history of showing the
last three years of OSHA top ten and look at where the top ten
standards are and then what am I doing or what is the employer
doing about this and what are the employee's responsibilities
around what we're doing? So, again, awareness, you can use the
lists that OSHA puts together to help with some of that awareness
to get some buy in and start some of the training, possibly with
your employees. What part do supervisors play in this process,
Steve?


Steve Badger: [00:58:57] Sure, absolutely.
Supervisors are critical [00:59:00] to this because they're kind
of that middle management level where, you know, they're the ones
that may be in charge of this job site or they may be in charge
of a crew. And doing inspections are absolutely critical. You
know, doing a walk through and making sure people are doing the
right thing, that they're using their equipment, they're using
their ladder properly, they're using their scaffolding properly.
That's been inspected and those sorts of things. And when not
which does happen, you know, when they find something being very
consistent and how they enforce that, I can't stress that one
enough because, you know, just because someone's been there 15
years doesn't mean that they have any special rights or, you
know, or are free pass because they've been there 15 years. It's
got to be a consistent enforcement, you know, just not the new
guy that comes in the door or the new gal that comes in the door.
It's got to be everyone. It's got to be consistent because other
than that, if it's not, people are not going to have that buy
[01:00:00] in. And it is critical.


Peter Koch: [01:00:03] True, very true. You
bring up a really good point that 15 or 30 year or, you know, 10
year employee who's been there for forever and now all of a
sudden you have maybe a new supervisor who's come in, come in
from a different company, doesn't have the same longevity with
that company or, you know, you might have to two people that have
worked together for the last 10 or 15 years. And one of them
moves into a supervisory position. That consistency of
enforcement or application of the standards for what you're
seeing is really important. And it helps, I think, with that buy
in. Right. So the employee buy in. If I see someone being treated
a little bit differently than I am, if I'm getting told to wear
my harness or put on my respirator or put on my seatbelt in the
fork truck, but the other guy is not. Chances [01:01:00] are when
the supervisor is not around, I'm not going to use it because
chances are the employee is going to think that and supervisor
doesn't really care that much. They're just picking on me. And so
why should I why should I do it?


Steve Badger: [01:01:15] Exactly.


Peter Koch: [01:01:16] Awesome, and all this
kind of fits in with continuous improvement. So talk a little bit
about the importance of continually moving your safety program
forward and maybe how the OSHA lists the top 10 list can be used
for that.


Steve Badger: [01:01:37] Absolutely. Yes. And I
think, again, is this is a critical part of safety programs, is
that it's not something you write once you put it on the shelf
and blow the dust off it once a year, you know, to bring it out,
it's got to be something that you're visiting regularly, that as
technology improves, as you know, training improves and, you
know, different types [01:02:00] of things that are out there
improve that you're updating that program to meet those new you
know, that new equipment. You know, respirators is a big one that
they always talk about where, you know, they specifically say in
the standard that they want you to go back at least annually to
update your program. You want to have a program administrator
that takes a look in. Is there something better? You know, and
there's several of the standards that are out there that actually
have that component to it that they don't want. You just having
this being a static document that, you know, you sit it on the
shelf and, you know, it never changes. It's going to be something
that's improved. And as this top 10, you know, tying it into that
is that, you know, as you know, maybe there's better and, you
know, more improved lock-out tag-out devices, you know, that are
out there. There's you know, it used to be that you had a lock,
you had a tag and you would throw that on anything. Well,
nowadays, there's  equipment that you can lock [01:03:00]
and tag out almost anything that's out there. So things have
changed over the years. And so should your program.


Peter Koch: [01:03:07] Nice. And again, using
that list as a way to almost as a checklist and again it doesn't
go through that list, doesn't highlight all of the standards,
only the ones that are most frequently cited, which again
correlates into the most frequent causes of injuries and
fatalities. So it's a good list to start looking at and say, all
right, in my continuous improvement process, how am I doing in
all of these? And at least it gives you some sort of barometer
and way to check. So maybe you have that when it comes out every
year. Take a look at it, use it as a focus for a while in your
safety toolbox talks. And then if you are the EHS guy or gal at
the business that you're working for, maybe use that as the
checklist, how we do it. Like if OSHA comes today, am I going to
[01:04:00] be part of that number of the most frequently cited
standards or are they going to come in and look at it? Go nope
your fall protection program looks good or nope your respiratory
protection looks good or HAZCOM looks good.


Peter Koch: [01:04:14] And then knowing that if
you miss the piece, that's OK, Continuous improvement, make a
change, add that to the process and move forward. That's really
great advice. Excellent. We're kind of coming to the end of the
podcast time here. And I do want to ask you this question, Steve,
because you've had quite a bit of experience with OSHA over the
years. You're an authorized trainer for OSHA. What do you know
now about OSHA that you wish you had known when you started out
back in the 80s doing workplace safety and work in an industry?


Steve Badger: [01:04:51] That's an interesting
question, Peter. I tend to look at it the other way around.
Really. There's things that I know now that I wish I didn't know
then, you [01:05:00] know, you know, types of things, you know,
think things like, you know, the dollar numbers that are thrown
out there with the citations. I mean, to me, that that's a very
unimportant number when we're talking about lists, it's not as
important as, you know, what is that violation in and how do we
fix it? You know, too often I see people focusing on those
numbers that, oh, I got this fine for 5000 or I got this fine for
10000. Yeah, that's the least important part. It really is. And
that's why I say I tend to wish that I didn't, you know, back
then when I first started in safety in 1986, that wasn't a
factor. That was you know, it was doing it for the right reason.
And rather than worrying about those money issues, are the money
issues important? Sure. But it's not something that should be the
focus.  You know, that's not that you know why we should be
doing this.


Peter Koch: [01:05:56] Right. And I think, like
with any good partner, there's some accountability [01:06:00] in
there. And I think from an OSHA standpoint, they have little to
do around accountability. So there needs to be you need to have
some skin in the game. Right. As an employer. And part of that
skin in the game is going to be dollars and cents. But like you
said, and I think that's a really, really great point, is the
dollars and cents are not the important part of this. The focus
is what part of the standard what part of that compliance? Aren't
you following? Because in that non-compliance, there's a gap
someplace in your program where one of Those employees that you
hire, which may not have the same understanding that the rest of
your employee employees do, is going to fall or is going to use a
piece of equipment incorrectly. And you're going to be in that
position as the supervisor or the manager or the vice president
or the owner of the company to make that call to the significant
other to say, hey, you know, Judy fell today and [01:07:00] I'm
not sure if she's going to make it home. That's never a place
where you want to be. And that's not the time to decide to make a
change. I mean, it is you certainly want to stand up, recognize
that and make a change, however. Do it before that, use these
lists to help recognize where some of the gaps are. I guess
that's might be a good place to kind of a good way to think about
it for sure. Right. So we're kind of getting again, like I said,
we're getting to the end. One more question for you, Steve. If
someone had more questions about OSHA and their top 10 lists,
where can they go for more information?


Steve Badger: [01:07:40] Yeah, certainly the
again, going back to the OSHA.gov website is really good because
one of one of the things they do is they give you this top 10,
but then they also break it down into the top five violations
under each of those top 10 so that you can kind of see, OK, when
like number one [01:08:00] here says fall protection, general
requirements. But what does that really mean? You know, in the
case, you know, when they're talking, you know, when they break
that down, they're looking at the residential construction as
being the number one within that particular area. Unprotected
sides and edges is the second largest. And so it kind of breaks
down for you what individually within those sections are the
points of pain that we're looking at that, you know, you take a
look at that list, that secondary list, and you say, OK, are we
protecting our people from unprotected sides and edges? You know,
we work on roofs that are low sloped. Are we protecting our
people? This gives you an idea of one. You know what they're
looking for. But two what are hurting people falls from those
heights.


Peter Koch: [01:08:50] Yeah, that's great. So
perfect, Steve. I think that's great. So recommending people go
back to OSHA and there's lots more information. We've just kind
of scratched the surface there [01:09:00] of what that top 10
list can break down for us. So thank you for that. This about
wraps up this week's Safety Experts podcast. Thanks for sharing
your expertise with us today, Steve.


Steve Badger: [01:09:12] Very welcome. Thank
you. Thank you for having me, Peter.


Peter Koch: [01:09:14] Yeah, beautiful.


Peter Koch: [01:09:15] So thanks again for
joining us. And thank you to all of our listeners out there.
Today on the MEMIC Safety Experts podcast, we've been speaking
with Steve Badger, safety management consultant with MEMIC, about
OSHA's top 10 list and how they can be used to improve your
company's safety in the workplace. If you have any questions or
I'd like to hear more about a particular topic on our podcast,
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