Welcome to the OSHA Top 10 Violations Series, a breakdown of the most common workplace safety violations and how to prevent them. In each piece, we’ll explore what the violation is, why it continues to appear on OSHA’s annual list, and what practical steps, tools, and processes you can implement to stay compliant. Every violation is preventable, and this series is designed to equip you with the knowledge to keep your team safe, your job sites compliant, and your operations running smoothly. Let’s dive into Part 1, the overview of violations, lessons learned, and the impact of non-compliance.

Most industries in the United States have their own labor code from the US Department of Labor’s Bureau of Labor Statistics (BLS). This allows them to search the BLS database, based on their code, and see what injuries are the most common in their industry. In turn, this gives them insight into areas or tasks they should focus on to prevent injuries to their employees, since others in their industry are already experiencing them. 

Unfortunately, the Restoration Industry does not have a labor code, meaning we don’t have access to industry-specific injury data. Groups like the Restoration Industry Association (RIA) are actively pursuing getting a code for our industry. In the meantime, there is data from OSHA that is tallied for all industries. Specifically, OSHA’s Top 10 violations are published every year. Much like the common injuries within a specific industry code, but on a grander scale, OSHA’s Top 10 violations allow restorers to see what safety topics others struggle with to implement and use to stay compliant, safe, and minimize injuries. 

While OSHA’s Top 10 list reflects violations across all industries, many of these hazards such as fall protection, ladders, respiratory protection, and hazard communication are routine parts of the restoration industry. Whether you’re responding to a water loss, fire damage, or mold project, you encounter these risks daily which are often in uncontrolled environments.  

According to OSHA, the most frequently cited standards for fiscal year 2024 (Oct. 1, 2023 – Sept. 30, 2024) were:

1. Fall Protection – General Requirements (1926.501): 6,827 violations
2. Hazard Communication (1910.1200): 3,121 violations
3. Ladders (1926.1053): 2,789 violations
4. Respiratory Protection (1910.134): 2,698 violations
5. Lockout/Tagout – Control of Hazardous Energy (1910.147): 2,655 violations
6. Powered Industrial Trucks (1910.178): 2,440 violations
7. Fall Protection – Training Requirements (1926.503): 2,243 violations
8. Scaffolding (1926.451): 1,959 violations
9. Eye and Face Protection (1926.102): 1,929 violations
10. Machine Guarding (1910.212): 1,676 violations

Lessons Learned

What can we do with this information? We can take the approach that “If everybody else has problems with these topics, then we will probably have problems with them.” Meaning this – we can use the OSHA Top 10 as our own list of safety topics that need our attention. Restorers can be proactive and do the following:

• Get training or certification on applicable Top 10 topics
• Make sure these topics are in your Written Health & Safety Plan
• Train employees on how to manage these topics at jobsites 

Let’s take for example Hazard Communication, which was the second most common violation in 2024. This OSHA topic requires a written program, employee training, and other efforts (e.g. SDS’s for every chemical you have). Restorers can find examples of a Written Hazard Communication Program in the resources section at the end of this article. Some state OSHA programs have specific templates that comply with their requirements, and some insurance carriers even have them for their clients. Restorers should adopt and complete the appropriate program for their company.  

The OSHA Top 10 list isn’t a compliance checklist; it’s a warning system. Each violation represents thousands of companies that thought they were “close enough.”

Impacts of non-compliance

The first impact of not complying with one of the Top 10 violations is the potential cost and efforts to correct the issue. Maximum OSHA penalties are over $15,000 per violation. As mentioned, you will likely need to correct the issue, such as implementing training and creating a written program.  

Some OSHA violations may be linked to an employee injury. We all recognize the impacts of an employee injury, some of which include:

• Impact to your greatest asset – your employees
• Need to replace lost labor if injury results in restrictions or lost time
• Potential increase in workers’ comp premium 

Finally, there are potential impacts lying under the surface (see resources at the end of this article for a link to my article on the hidden cost of injuries). Some of these can include:

• Employee lawsuits and insurance disputes
• Having to answer “Yes” to bid questions on if your company has had employee injuries.
• Potential increased customer-perceived risk that their employees or tenants could be injured by your work. 

For restorers specifically, there are two direct impacts:

• Increased scrutiny from carriers, TPAs, and large commercial clients
• Higher Experienced Modification Rate (EMR) scores, which can quietly disqualify companies from preferred vendor programs.

This creates additional risks for your business and cashflow, not just regulatory exposure. 

Why this Matters Moving into a New Year

The industry continues to evolve amid increased insurance scrutiny, tighter margins, workforce shortages, and rising expectations around professionalism and risk management. Safety and documented compliance play a huge role in how restorers are evaluated by insurers, property managers, and your customers. 

Summary and Future Articles

There are certainly other resources and guides available to help restorers with compliance. For instance, ANSI/IICRC and the RIA publish industry standards that provide specific regulatory guidance for common restoration topics. These should always be utilized and incorporated into standard processes and procedures. However, OSHA’s Top 10 violations can also serve as a guide for Restorers based on the simple fact that others are struggling with these topics. In turn, Restorers can verify they have each of these topics in their Written Health & Safety Program and are training employees on them.  

This marks the beginning of our ongoing safety series examining OSHA’s Top 10 violations through a restoration-specific lens. In future articles, we’ll break down each violation, explain where restorers get tripped up, and provide practical steps to stay compliant without slowing down your production and most importantly avoiding additional violations. 

Resources

OSHA Hazard Communication Program Template: https://www.osha.gov/sites/default/files/2019-03/sample_hazcomprogram.doc 

The Hidden Costs of an Injury, Barry Rice, September 6, 2024, R&R Magazine Online. https://www.randrmagonline.com/articles/90959-the-hidden-costs-of-an-injury