Will Anything Change with OSHA's MFC Standards?

Each fiscal year (October 1st to September 30th), #osha publishes its list of Most Frequently Cited Standards. There is an overall list, and a separate list just for construction, but very little changes from year to year. I have written about this several times both here and on LinkedIn, but since we are approaching the end of the 2024-25 fiscal year, I thought I would post the 2023-24 fiscal year statistics so we can compare and see if anything at all has changed between 2024 and 2025.

from osha.gov

Here is where we stood:

1. Fall Protection, general requirements (29 CFR 1926.501) [related safety resources]

2. Hazard Communication, general industry (29 CFR 1910.1200) [related safety resources]

3. Ladders, construction (29 CFR 1926.1053) [related safety resources]

4. Respiratory Protection, general industry (29 CFR 1910.134) [related safety resources]

5. Control of Hazardous Energy (lockout/tagout), general industry (29 CFR 1910.147) [related safety resources]

6. Powered Industrial Trucks, general industry (29 CFR 1910.178) [related safety resources]

7. Fall Protection Training, construction (29 CFR 1926.503) [related safety resources]

8. Scaffolding, construction (29 CFR 1926.451) [related safety resources]

9. Eye and Face Protection, construction (29 CFR 1926.102) [related safety resources]

10. Machine Guarding, general industry (29 CFR 1910.212) [related safety resources]

Note that all of these except the last one (Machine Guarding) apply to the construction industry since they are pulled into the OSHA Construction Standards by reference. Its sad, but not at all surprising to see so many of these related to working at heights (Fall Protection, Ladders, Training, Scaffolding). All you have to do is drive around and look at construction sites to see examples. In fact, if you dig deeper into the documentation that OSHA produces (download the PDF) we learn that 5,110 of the Fall Protection citations were in the Residential Construction Industry. Again, not surprising, just go drive to almost any residential construction site in the U.S.

MFC_Construction_FY24.pdf

Download PDF • 649KB

Incidentally, that's one of the reasons we partnered with a company called on3.ai to produce one of the best residential construction safety training programs in the industry.

But do we really need to continue to see Haz Comm in the top three for the last several decades?

There are many things wrong with the fact the Haz Comm has occupied the top three on this list for decades, but its extra troubling if you have ever been involved in an OSHA request for Haz Comm documentation during an inspection. It's extremely lenient, with most requests being just to send them copies of SDSs for products they have observed on-site within 24 hours. With the bar being so low, these citations seem to represent companies that are just simply doing nothing at all. It's just hard to believe that is even still possible, but here we are, and my prediction is that we will see this again in a few weeks when OSHA posts the 2025 MFC numbers. Any thoughts?

---