b'SAFETY CULTURE AND THE ENTREPRENEUR OSHA UPDATEGarys CornerupdateGary Auman, MRCA Legal CounselA t the conclusion of my last article Iwere issued in residential fall protection situations promised to begin providing a list of must Steep roof contractors be AWARE! The next four haves for a roofing contractors safetyfall protection violations were: unprotected sides and programand I will get there. But, several mattersedges; roofing work on low-slope roofs; steep roofs; have come to my attention that I want to touch uponand protection from holes and skylights. There is no before we get to safety programs. First, OSHA has justdoubt that the roofing profession is by far the most published its Top Ten list of citations issued for 2015. visible from an OSHA inspection standpoint. You absolutely MUST have a tightly drawn fall protection OSHA Top Ten List program in our business and one which you do repeat training and about which you are vigilant from an OSHA Has released the top ten standards violated inenforcement perspective. I continue to see reports of 2015. They are in order: citations issued to roofing contractors in the Midwest Fall Protection and east with six figure fines. If you increase those Hazard Communication amounts by 82%, which will occur after August 1st, the cost of non-compliance and taking safety too lightly Scaffolding may start to impact your bottom line from multiple Respiratory Protection perspectives!Lockout/Tagout I know that more and more general contractors Powered Industrial Trucks and owners are, for whatever reasons, taking a hard look at the safety and OSHA compliance records of Ladders prospective subcontractors. I am currently defending Electrical Wiring a case for a small general contractor/subcontractor. Machine Guarding General Requirements The fines are not too high, but one violation deals with an alleged excavation violation and OSHA has Electrical Equipment General Requirements dug its heels in on keeping it as a serious violation. My client has told me that even without a final order they are getting questions from prospective customers and You will note from the list that many of thegeneral contractors about the citation.standards impact construction. Several impact the roofing industry specifically. We are covered by theBy far the heaviest fall protection, hazard communication, scaffolding, and ladder standards. Of the other standards, we maypenalties were issued for be impacted by respiratory protection and poweredfall protection violationsindustrial trucks. Yes, electrical safety standards also have impacts on us, but the electrical standards on theSafety Programs top ten list are limited to general industry electrical standards. This does not mean that we do not haveBeyond the above, the only new information compliance obligations regarding electrical safety, butfrom OSHA is that the agency projects finalizing only that the general industry standards had enoughthe new silica standard and the electronic reporting enforcement action to get them on the top ten list.standard before President Obama leaves office. Also, By far, the heaviest penalties were issued for fallDr. Michaels, the current Administrator of OSHA protection violationsmore than double the totalhas stated that after President Obama leaves office he fines issued in the next closest standard. Of the 7,372will leave OSHA and return to his career as a college citations issued for fall protection violations, 4,071professor. He has stated that he intends to take this step even if a Democrat is elected President.6 www.mrca.orgMidwest Roofer'