DANA R. BREWER
Workplace Safety Division
Directorate of Assessments and Prevention
U.S. Army Combat Readiness Center
Fort Rucker, Alabama

Occupational Safety and Health Administration (OSHA) standards describe the requirements employers are legally required to follow to protect their workers from hazards. Each year, OSHA compliance officers visit and inspect worksites nationwide to ensure employers are complying with these standards. Noncompliance to a cited OSHA standard could result in a Notice of Violation (NOV). OSHA averaged slightly more than 33,500 inspections per year over the last five years. These inspections covered construction, general industry, maritime and agriculture industries, focusing enforcement of occupational safety health rules and regulations.

Fiscal 2019 OSHA inspections

OSHA inspected 74 Army facilities in fiscal 2019 and issued 47 NOVs. The Army averaged 3.11 violations per inspection from the 146 total violations received for the year. There are currently two inspection cases under contest with a total of nine violations. The average number of days from open to close date was 74 business days/103 calendar days (excluding those still open).

The OSHA top 10 violations for fiscal 2019 are compared to the Army top 10 violations cited for all industries. The comparison revealed only two violation standards cited on both lists. These include 1910.1200 hazard communications and 1910.212 machine guarding — general requirements for all machines (see yellow highlights in tables below). Additionally, four of the top 10 violation categories were associated with electrical standards. See Table 1 below for a side-by-side comparison of OSHA and Army top 10 violations for fiscal 2019.

The Department of the Army established procedures to track and manage OSHA inspection results to prevent repeat violations, stemming from the recent change to the OSHA Field Operators Manual (August 2016). Commanders, Army commands (ACOM), Army service component commands (ASCC) and direct reporting units (DRU) are required to report OSHA inspections to the U.S. Army Combat Readiness Center (USACRC) within two duty days of the closing conference.

The USACRC tracks all OSHA violations received from the field and compares the reported data against the OSHA database for completeness. Additionally, the USACRC performs analysis on the OSHA top ten most cited violations to monitor how the Army compares to industry trends (e.g., Corp of Engineers versus construction). The OSHA top 10 workplace violations for the Army are summarized in a fiscal year timeframe, recorded from October of the previous year to the end of September of the current year.

Army five-year data

For the years 2015-19, the Army experienced 408 total inspections with 807 violations, as illustrated in Table 2 below. Total Army violations trended downward over the five-year period with a rise in 2018 and 2019. The average days to close a violation with OSHA has continued to decrease, but is still averaging 75 working days to reach resolution. Table 2 below shows the rate of violations to inspections increased over the last two years.

In the past five years, 2015 had the highest number of inspections and violations reported, while 2017 had the lowest number of inspections and violations reported. Chart 1 below shows the inspection rate compared to violations sites for each year represented.

Conclusion

There is an overall downward trend in the number of inspections, violations and average days to close a case with OSHA in the past five years. Fiscal 2019 OSHA data shows an increase in violations over the previous two years, moving away from the 2017 benchmark year with a lower number of inspections and violations. The five-year overall decline may have been due to the Army’s initiative to correct past violations and prepare for future inspections. The Army, as a whole, exercises best practices to be in compliance with OSHA regulations and attempts to avoid repeat violations by training and education. Commanders, ACOM, ASCC and DRUs need to continue to provide service members with safe workplaces and emphasize the importance of reporting OSHA events when they occur.