OSHA’s Agenda for 2019

With so much recent talk of the Occupational Safety and Health Administration (OSHA) rescinding regulations, Walden is taking this opportunity to review OSHA’s primary agenda items for 2019 with regard to general industry facilities and inspections.

There are approximately 2,000 OSHA inspectors nationwide.  Approximately 65% of OSHA inspections are programmed, i.e. they set out to inspect “X” number of random sites in a week; this leaves the remaining 35% as unprogrammed inspections which occur based on complaints or due to injury incidents. 


This year’s active national and special emphasis programs include:

  • Combustible dust;
  • Federal agencies;
  • Hazardous machinery;
  • Hexavalent chromium;
  • Lead;
  • Silica
  • Primary metal industries;
  • Process safety management;
  • Shipbreaking; and
  • Trenching and excavation.

In addition, OSHA’s local emphasis programs for New York State include:

  • Fall hazards in construction;
  • Heavy highway and bridge construction and maintenance;
  • Warehouse and refuse handlers and haulers;
  • Construction worksites;
  • Health high hazard (top 50);
  • Gut rehabilitation and demolition; and
  • Dairy farm operations.

In particular, when OSHA arrives to inspect your facility, here are some key items the inspectors will be looking for:

  • Crane operator training, certification and evaluation: Revisions to 1926.1427 became effective 12/9/18; Evaluation and documentation requirements became effective on 2/7/19;
  • Temporary/part-time workers: Are they trained in the same topics and manner as full-time employees (i.e. lockout/tagout)?; Are they supplied the proper equipment (including hearing and respiratory protection, when appropriate)?;
  • Injuries/fatalities: Have there been any?; Are they being properly recorded and reported?;
  • Secondary containment: Are there labels identifying the containerized material is and the associated hazards?;
  • Eye-wash stations: If corrosive chemicals are stored on-site, is the eye-wash station appropriate and does it get inspected weekly?; Are inspection records properly maintained?; and
  • Is there a swing gate on any ladder hole or is there a chain (no longer allowed)?.

And as always, be sure to be in compliance when it comes to the following FY2018 top ten most frequently cited OSHA standards violations during inspections (nationwide):

  1. Fall protection – general requirements;
  2. Hazard communication;
  3. Scaffolding;
  4. Respiratory protection;
  5. Lockout/tagout;
  6. Ladders;
  7. Powered industrial trucks;
  8. Fall protection – training requirements;
  9. Machine guarding; and
  10. Eye and face protection.

Of note, OSHA has set new penalty levels for violations, with maximums set at:

Type of Violation New Maximum

Serious and other-than-serious posting requirements

$13,260 per violation

Willful or repeated

$132,598 per violation

Failure to abate

$13,260 per day (beyond the abatement date)


Walden Expertise

Walden has worked extensively in the construction industry for over 25 years.  Walden is well versed in safety requirements and has multiple trained “competent people” who can help your project stay in compliance with OSHA regulations.  If you want additional information on environmental health and safety rules or regulations or have questions on how Walden can help your project stay in compliance, please call us at (516) 624-7200, (845) 253-8025 or (518) 698-3012. Make sure to check out our other Environmental Health and Safety capabilities.