OSHA’s Top 10 Cited Safety Regulations for FY2024—A Repeat Performance
In September 2024, the U.S. Occupational Safety and Health Administration (OSHA) announced its preliminary list of the top ten most frequently cited regulatory violations for fiscal year 2024 (10/1/2023-9/30/2024). The top ten for FY2024 is the same as in FY2023, except for the order in which they appear, as reflected in the table below.
| FY 2023 | FY 2024 |
| 1. | Fall Protection, construction (1926.501) | 1. | Fall Protection, construction (1926.501) |
| 2. | Hazard Communication, general industry (1910.1200) | 2. | Hazard Communication, general industry (1910.1200) |
| 3. | Ladders, construction (1926.1053) | 3. | Ladders, construction (1926.1053) |
| 4. | Scaffolding, construction (1926.451) | 4. | Respiratory Protection, general industry (1910.134) |
| 5. | Powered Industrial Trucks, general industry (1910.178) | 5. | Control of Hazardous Energy (lockout/tagout), general industry (1910.147) |
| 6. | Control of Hazardous Energy (lockout/tagout), general industry (1910.147) | 6. | Powered Industrial Trucks, general industry (1910.178) |
| 7. | Respiratory Protection, general industry (1910.134) | 7. | Fall Protection Training, construction (1926.503) |
| 8. | Fall Protection Training, construction (1926.503) | 8. | Scaffolding, construction (1926.451) |
| 9. | Eye and Face Protection, construction (1926.102) | 9. | Eye and Face Protection, construction (1926.102) |
| 10. | Machine Guarding, general industry (1910.212) | 10. | Machine Guarding, general industry (1910.212) |
While the top 10 list is generally highly repetitive from year to year, though not necessarily identical, fall protection in construction has remained at the top of the list for fourteen consecutive years. It is usually followed by hazard communication in general industry. The annual top 10 lists, and their repetitive content from year to year, both serve as a strong reminder to employers of OSHA’s emphasis on these standards during enforcement activities, and as encouragement to employers to focus on the requirements of these regulations to manage risk and the potential for injuries to their employees.
For 2024, employers should also be mindful that OSHA recently amended its hazard communication standard. The final rule and updated regulation took effect on July 19, 2024, with transition milestone deadlines at 18, 24, 36, and 42 months. Failure to meet timely requirements pursuant to the phase-in schedule could expose employers to violations. For manufacturers, the new rule includes package labeling updates, additional hazard classifications, updates to Safety Data Sheet (SDS) materials, and more disclosure relating to chemical concentrations used in trade secret formulas. For employers, the amendments will necessitate updating of labels, collection of new SDS materials, revisions to hazard communication programs, and employee training. Much of the hazard communication update is intended to maintain alignment primarily with revision 7 of the Globally Harmonized System of Classification (GHS) released in 2017. Notably, revision 10 was issued in 2023 and is the most current, and a revision 11 is scheduled for release in 2025.
If you have questions about OSHA’s revised Hazard Communication standard, or other general inquiries about OSHA compliance, please contact Jason Markel (716.848.1395), Glen Doherty (518.433.2433), or Charles H. Kaplan (646.218.7513).
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