OSHA Instance by Instance Citations for Workplace Injury Prevention Memorandum

Tips to Keep Your Business off Their Radar

In early 2023, OSHA issued a memorandum providing their guidance on issuing Instance-by-Instance citations. The guidleines went into effect on March 26, 2023. This new plan aims to reduce injuries and fatalities in the workplace. “The scope of this guidance is limited to high-gravity serious violations specific to falls, trenching, machine guarding, respiratory protection, permit required confined space, lockout tagout, and other-than-serious violations specific to recordkeeping. The scope applies to general industry, agriculture, maritime, and construction industries,” according to the release.

OSHA Plan Overview

The plan includes several key areas that attempt to improve working conditions:

1. Strengthening Enforcement: OSHA will be strengthening enforcement efforts by increasing the number of inspections and citations issued for workplace violations. OSHA Regional Administrators and Area Directors also now have the authority to cite certain types of violations as “instance-by-instance citations” for cases where the agency identifies “high gravity” serious violations of OSHA standards.
2. High Risk Industries: The agency is increasing its focus on high-risk industries and employers who repeatedly violate safety regulations. These employers should expect more frequent and aggressive inspections, as well as stiffer penalties for violations.
3. Prevention is Key: OSHA is placing a greater emphasis on preventing injuries by encouraging employers to identify risks before an injury occurs.
4. Improved Data Collection: Tracking trends will become more prevalent as OSHA improves their data collection of workplace injuries.

The current administration is taking steps to increase their investigation and enforcement activity in the coming year.

Tips to Avoid Citations

How can employers stay off of OSHA’s radar? Wakefield Equipment has a few tips for employers addressing workplace safety.

1. Review Safety Plans
   We’ve covered reviewing safety plans before in detail. Your machine safety plans should be reviewed at a minimum annually and updated every time new machinery is added, you experience an increase in your number of employees and any other significant business change.
2. Conduct Safety Inspections and Training
   Take the time to properly train all employees on how to stay safe on the job, how to spot hazards and how to use all equipment. We also suggest walking your machine floor regularly to look for potential hazards. Our experience is that employees are the best source of this information—if you ask them for it.
3. Maintain Proper Recordkeeping
   There is no way around it—OSHA likes a paper trail. Make sure you are keeping accurate records of all workplace incidents and are complying with all OSHA regulations for tracking injuries and illnesses. One of the most cited safety issues is poor record keeping!
4. Invest in Proper Equipment
   Wakefield offers a variety of equipment designed to reduce workplace hazards. From adding TigerStop automated cutting devices to back-saving racks and dollies, our experts can work with you to review your manufacturing floor and identify potential hazards.
5. Create a Culture of Safety
   Any safety program is only as beneficial as the people implementing it. Ensure your employees feel valued and know that safety is your priority. With regular safety meetings and open communication, your workplace environment can go a long way in preventing accidents.

OSHA is continually updating their guidelines and Wakefield Equipment is ready to help you ensure you avoid the headache and cost of an OSHA citation.