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Speaking of Precision is a knowledge preservation and thought leadership blog covering the precision machining industry, its materials and services. With over 36 years of hands on experience in steelmaking, manufacturing, quality, and management, Miles Free (Milo) Director of Industry Research and Technology at PMPA helps answer "How?" "With what?" and occasionally "Really?"

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OSHA Top 10 Citations for 2011

Posted November 18, 2011 9:00 AM by Milo

This Top 10 list is nothing to laugh at... Please note that these Top 10 Citations are for all industries (including construction), not just Precision Machining.

Fall protection - 7,139 violations.

Scaffolding - 7,069 violations. 37 fatalities.

Hazard communication - 6,538 violations.

Respiratory protection - 3,944 violations.

Lockout/tagout - 3,639 violations.

Electrical - wiring methods - 3,584 violations.

Powered industrial trucks - 3,432 violations.

Ladders - 3,244 violations.

Electrical - general - 2,863 violations.

Machine guarding. Number of citations not published, last year there were 2,364 violations.

If you get a visit from OSHA, you can bet they will be taking a look at the items on this list.

And here's an employers rights guide from OSHA that will tell you what to do after their visit.

Image link - Letterman

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#1

Re: OSHA Top 10 Citations for 2011

11/18/2011 12:44 PM

In 2011, I wonder how many citations were written for OSHA 1926.51(g):
Eating and drinking areas. No employee shall be allowed to consume food or beverages in a toilet room nor in any area exposed to a toxic material.

There is a reason I am aware of this particular rule.

When the OSHA guys are in the ticket writing mood, there are hundreds THOUSANDS of things that can be counted as violations. The moral is, run a safe and clean shop: you and your employees are all better off because of that practice.

[post script] Thanks, Milo, for helping out with the deep drawn stainless thread.

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#2

Re: OSHA Top 10 Citations for 2011

11/19/2011 9:26 AM

In re-certifying our SHARP's status this passed summer they were going after the lockout/tag out program a business has. Insuring that all those that job would require to have to secure power for equipment understand and completely follow procedures. That the have the necessary devices available to them to do so. Seems every time this comes up the program mentor concentrates on one general item.

SHARP is OSHA's Safety & Health Achievement Recognition Program

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#3
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Re: OSHA Top 10 Citations for 2011

11/19/2011 5:46 PM

Thanks for sharing your experience.

Milo

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#4

Re: OSHA Top 10 Citations for 2011

11/19/2011 5:56 PM

I kind of like the way it's done in the military. OSHA rules don't apply there unless it's a civilian contractor.

Lock out/tag out is a big one, big trouble if you don't do it, as well as a few others.

Besides those, be careful and get the job done. If you screw up and hurt yourself, you won't be suing anybody. You were born with a brain...............use it.

Or have OSHA inspectors been unleashed in Iraq and Afghanistan?

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#5
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Re: OSHA Top 10 Citations for 2011

11/19/2011 10:54 PM

I ran a little math. Each one of those citations cost the American taxpayer over $13,000, based on the 2012 budget,

Why is there not an OSHA unit embedded in US military? Every ship, every base, every camp, etc.

Is it because our military people don't deserve the same protection as civilians?

Are they expendable?

No. The reason that OSHA isn't in the military, is because they would quickly render us completely inefficient and ineffective as a fighting force. That seems to be reserved for the private sector.

Don't eat a sandwich in the bathroom. This has been a public health announcement. You need us.

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#6
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Re: OSHA Top 10 Citations for 2011

11/19/2011 11:33 PM

We happily send our kids off to war. No OSHA, and yet somehow they survive.

They come home on leave and want to drink a beer after being shot at for 6 months.

NO WAY. You're way too young for that. You're back on American soil now.

Government says you're too young to drink a beer. You're not responsible enough.

I'm sorry guys. Hit the report button and get me banned from here.

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#7
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Re: OSHA Top 10 Citations for 2011

11/20/2011 8:03 AM

What's to report? The topic is efficacy of regulatory agency in private sector and you are demonstrating hypocrisy of the regulatory regime when compared to how the govt chooses to run its own operations. I' m not sayin it's a good answer, but it sheds light on regulatory tone, policy, and efficacy. Milo (host of this post) Please forgive typos sent from my iPhone

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#8
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Re: OSHA Top 10 Citations for 2011

11/20/2011 9:16 AM

Just another weekend Milo. I seem to be stuck on finding and exposing government waste and hypocrisy.

Your blog got me off to reading the various government justifications for needing more money for OSHA to keep us safe, more money for everything really.......................................because we are incapable of looking out for ourselves.

OSHA is just one small agency, and any amount of money we give them is not enough.

I wasn't trying to derail your blog, I've just got a very real concern about where we're headed. It's getting to be impossible to pretend that everything is going to be fine.

There was a thread yesterday about what to do with sawdust, that got me reading about waste wood on the internet. I ran into a story about a guy that was grinding stumps and selling the shavings as mulch. Small time operation. The EPA shut him down on the grounds that stumps may contain heavy metals. If it wasn't the EPA, I'm sure it would have been OSHA. So here this poor slob sits, with his equipment that could earn him a dollar......................and he's shut down and broke. The government won't let him work because tree stumps may be hazardous. It's sick.

Here's a quote from the bottom of this page.

"Control your destiny or someone else will!" -- Jack Welch

It's a message we should heed.

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#16
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Re: OSHA Top 10 Citations for 2011

11/21/2011 8:04 AM

Do you have the article on this guy? I would love to look into it.

I studied OSHA Regulations (29 CFR 1926) in college. There are some very ridiculous rules, but they are based on some incident that happened somewhere in this coutry. In my 24 hr HAZWOPER class, the instructor informed us that IOSHA (Indiana's OSHA program which he worked for) is so busy that they only respond to complaints. They don't have enough staff to do inspections of companies subject to the rules on any type of rotating schedule or regular basis.

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#17
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Re: OSHA Top 10 Citations for 2011

11/21/2011 8:22 AM

I'll try to find it again. I'll have to try to retrace my steps, since I went off on a tangent from the sawdust thread. It was the EPA, not OSHA.

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#18
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Re: OSHA Top 10 Citations for 2011

11/21/2011 8:47 AM

I found it. It was just related by a guy on a blog, with no links or citations to back it up. However, I don't think he was lying, what would be the point?

I believe that it happened and that it probably had to do with the definition of debris, here. Which specifically mentions tree stump. I don't know if the EPA is charged with enforcing the RCRA or not. I'm guessing yes.

http://www.mccoyseminars.com/CC/corner-prev.cfm

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#19
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Re: OSHA Top 10 Citations for 2011

11/21/2011 9:48 AM

It's kind of funny and scary at the same time. In the course of my reading, I came across something that said that one of the main things that collects heavy metals besides humans, is tree stumps.

It would seem logical to conclude that dead humans would also be considered hazardous waste. Now it's the stump grinders. Are cemeteries and crematoriums next on the hit list? It wouldn't surprise me.

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#20
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Re: OSHA Top 10 Citations for 2011

11/21/2011 7:57 PM

I ran into this in a TRI class in massachusetts a year or so ago. Lumber company. Sawdust. Exceeded threshold limit for some heavy metal. Apparently "natural" was no defense. Milo

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#26
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Re: OSHA Top 10 Citations for 2011

11/28/2011 9:18 AM

Have friend who does tree work. Have seen the grindings from stump grinder. They don't make the size spec of over 60mm. It's the whole stump that's hazard. Most of these guys grinding stumps don't go much below the surface of the ground. So where do you draw the line. If the last few inches of a tree sticking up out of the ground is a hazard. what about the rest of the tree?

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#27
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Re: OSHA Top 10 Citations for 2011

11/28/2011 10:35 AM

Apparently the heavy metals congregate primarily in the stump itself, which is now considered hazardous debris.

The ripple effect of rules like this aren't noticed by most people, but what about the guys that grind stumps? What about the people that work for the companies that manufacture stump grinders?

Your friend may be safe for now, maybe not. Who knows what the fines will be if he gets caught, now that he's an enemy of the State?

As these rules and regulations become more pervasive, where exactly do they expect the regular Joe to go to work and earn a living?

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#29
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Re: OSHA Top 10 Citations for 2011

11/29/2011 7:12 AM

My friend is a tree expert he just takes them down he contracts someone else to grind the stump. Still then regs in the link have it debris listed to have to be over 60 mm. Grindings from a stump grinder look like shredded wood they are not even chips

My question now where do these heavy metals come from but in the ground. Isn't mulch put on the ground. Wouldn't the heavy metals leach out of the chips back into the ground or the chip decay so whats the deal. Are they saying that the heavy metals in the chips ground from a stump are so hazardous they should not be handle. In that case why just the EPA why not OSHA some these guys grinding stumps are just employees. They clearing some of the chips way to level the ground. Most are place in trucks with the chips from branches of the tree which some are taken to be used as mulch anyway. Can't really tell much of difference between the two once they mixed together.

Not having information on the case at hand. More inclined to believe he pissed some one off that had the power to pull some strings. Using gray areas of the regs. to get even.

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#31
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Re: OSHA Top 10 Citations for 2011

11/29/2011 7:51 AM

Yeah, the heavy metals are a natural occurrence. I suppose some could be absorbed through the leaves.

In the story I read about the guy that got shut down, he was grinding up stumps specifically, that had been pulled from the ground, and was selling the chips as mulch.

Like any regulation, they can be as pushy or as lax as they want to.

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#34
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Re: OSHA Top 10 Citations for 2011

11/30/2011 8:19 AM

I believe the problem with that is the heavy metals that leach out of the stumps end up in the soil below the stump pile and around where it was ground up. Over time, this causes the soil concentration to be very high and the heavy metals start leaching out of the soil into our drinking water. Also, as the soil erodes from wind and vehicle traffic, it creates breathing problems for those that work and live near the site.

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#35
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Re: OSHA Top 10 Citations for 2011

11/30/2011 8:33 AM

Is there any data available that can attribute known health or environmental occurrences to tree stumps? i.e. How many sick people and poisoned water incidents?

Has a causal relationship been shown, or is this just another in the perpetual search by the EPA to justify their existence, and find things that may possibly be harmful?

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#36
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Re: OSHA Top 10 Citations for 2011

12/01/2011 8:47 AM

Here are some great links that discuss this in depth. I found them using 4 Google searches (tree stump heavy metal bioaccumulation, soil heavy metals, soil heavy metals pollution, and soil heavy metals pollution on humans).

http://envismadrasuniv.org/Bioremediation/pdf/Phytoremediation%20of%20heavy%20metal.pdf

http://www.aweimagazine.com/article.php?article_id=213

To answer the question about statistics, I found the following:

http://en.wikipedia.org/wiki/Soil_contamination This one states that "The immense and sustained growth of the People's Republic of China since the 1970s has exacted a price from the land in increased soil pollution. The State Environmental Protection Administration believes it to be a threat to the environment, to food safety and to sustainable agriculture. According to a scientific sampling, 150 million mi (100,000 square kilometers) of China's cultivated land have been polluted, with contaminated water being used to irrigate a further 32.5 million mi (21,670 square kilometers) and another 2 million mi (1,300 square kilometers) covered or destroyed by solid waste. In total, the area accounts for one-tenth of China's cultivatable land, and is mostly in economically developed areas. An estimated 12 million tonnes of grain are contaminated by heavy metals every year, causing direct losses of 20 billion yuan (US$2.57 billion)."

http://www.lenntech.com/processes/heavy/heavy-metals/heavy-metals.htm

I couldn't quickly find any studies on the U.S. even though it is still a problem in this country.

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#37
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Re: OSHA Top 10 Citations for 2011

12/01/2011 3:43 PM

I appreciate you going to the trouble of finding those links.

The problem is, that they address contaminated soil..............................anything grown in soil that has been contaminated with heavy metals from industrial waste will contain heavy metals.........................including a head of cabbage.

Correct me if I'm wrong, but it appears to me that the EPA has labeled all tree stumps as hazardous debris, not just those coming from contaminated soil.

From my perspective at this point, this looks like another "feel good" ruling from an agency that is running amok. It sounds just great, unless you happen to be one of the poor schmucks that makes his living manufacturing stump grinders or grinding stumps.

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#38
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Re: OSHA Top 10 Citations for 2011

12/01/2011 3:54 PM

So you are captain of a tugboat, and your permit says you can't let anything spill from the vessels in your charge into the navigable water way.

A terrible storm blows tree bark off a large tree on the bank onto one of your tied off barges.

You can not let that bark spill into the River!

As you are paying a crewman to shovel that bark into special containers to off load back on shore, You notice a big dead tree floating by and...

Milo

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#21
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Re: OSHA Top 10 Citations for 2011

11/21/2011 8:27 PM

kramarat - in the US Navy we had the NAVOSH and it was in many places more stringent than OSHA. All of our rules were written in blood and we followed them or suffered the consequences. Some of those consequences were in blood, but as they say in the military, downward mobility is wide open. I saw quite a few men busted in rank for not following the NAVOSH rules and more than a few shipyard workers fired outright. Each branch of our military has their own version of OSHA and they follow it.

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#22
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Re: OSHA Top 10 Citations for 2011

11/22/2011 6:13 AM

I guess it varied by where you worked. I was in the Navy too, and worked in the engine room of a guided missile destroyer that was commissioned in 1945. I was in from 80-84.

Tagging out electrical equipment before working on it was a biggie. As was isolating pumps, etc. from the loop, while repairing. Other than that, we did what was necessary to keep things running.

Of course, working in the "hole", was hot, dirty work. We were able to ignore lots of little rules. Dress codes, saluting officers, etc........only while underway though. Plus, it was hot enough in the space, that the higher ranking people rarely came out there. We did what we wanted, and kept everything running. No safety police necessary.

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#9

Re: OSHA Top 10 Citations for 2011

11/20/2011 10:38 AM

Between 2009 and 2011 OSHA's budget has increased by $60,000,000. I have to wonder if the cost of safety is an infinite number. Bear in mind that a $30,000,000 per year increase is what they expect to remain functional. In the government, the motto is, "use it or lose it", and every year beg for more.

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#10
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Re: OSHA Top 10 Citations for 2011

11/20/2011 1:20 PM

Thanks for your contributions. Milo

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#11
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Re: OSHA Top 10 Citations for 2011

11/20/2011 6:03 PM

I am on the road. Is this FTE full time equivalents? People?milo

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#14
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Re: OSHA Top 10 Citations for 2011

11/21/2011 7:40 AM

I don't know. I could only find a couple of charts. I started to try to read the 2012 OSHA budget proposals, increases, etc., but it's like reading a novel.

One would think that with the work force shrinking, OSHA would shrink proportionally. Not so. They continue to grow.

The only reason I said to hit the report button, is that I'm sounding like a broken record on govt waste/abuse. Figured people are getting sick of it.

Maybe I'm wrong, but I think that with or without OSHA, most employers work hard to ensure a safe work environment. I always did. Nobody wants their people getting hurt.

It seems to me that OSHA is just another agency that works on the assumption, that if they're not there, and steadily increasing in size, that all companies will behave badly and throw the safety rules out the door. I don't buy it.

What do you say Doorman and Milo? Would your company put it's employees in peril if not for the looming presence of OSHA?

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#28
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Re: OSHA Top 10 Citations for 2011

11/28/2011 6:40 PM

Sorry kramrat. I hadn't realized you addressed part of this comment to me.

You asked "Would your company put it's employees in peril if not for the looming presence of OSHA?"

Willingly or knowingly, of course not. I have been scolded a few times in the past by managers/owners for cutting up and discarding cords or hoses they thought were serviceable (they weren't), ordering new machine parts instead of rigging another patch on a required guard, ordering task lighting, not bypassing safeties...

The OSHA of today is MUCH kinder and gentler than, say, 20-25 years ago. We recently had a multidiscipline inspection (fire dep't, OSHA, City building dep't... ) The visit was not unpleasant, and they left us with a number of violation notices that made more of a 'fix-it' list than a bunch of citations. Someone returned a few weeks later, checked thru the list for progress, and left us with no tickets. I like this technique much better than fining us into compliance. That sucked. A lot.

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#30
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Re: OSHA Top 10 Citations for 2011

11/29/2011 7:33 AM

It was back in the mid 80s that they swarmed the job I was on........................yeah, it sucked bad.

I'm just a one man show now, so I don't have to deal with any of them........................................just the IRS.

I just have to wonder how much OSHA is needed.

The other day as I was driving around, I think I kind of put things in perspective.

As I was looking at all the cars on the road, I thought to myself. Here we are, we allow anyone over 16 years of age to pump 20-30 gallons of highly volatile gasoline into a vehicle that weighs a couple of thousand pounds and is capable of doing well over 100 MPH, and everybody is just turned loose on the roads. What, in manufacturing, could be more dangerous than that?

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#23
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Re: OSHA Top 10 Citations for 2011

11/22/2011 9:03 AM

Milo, you seem to have an FTE of about 1.6.

CR4 is certainly getting their money's worth.

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#12

Re: OSHA Top 10 Citations for 2011

11/21/2011 2:35 AM

I wonder how many of these alleged safety breaches were simply a lack of certification?

No hazardous practices, no malfunctioning or missing safety apparatus, or any hint of reckless behavior. Just no certification or documented qualification from some controlling clique.

We're being regulated to death faster than any potential accident can kill us on the job it seems.

What sort of dangers do the OH&S dudes face in the execution of their duties I wonder?

There will come a time when nothing can get done. Ever.

I believe that safe working practices make for a better and faster job, but I can also determine what is and isn't right without having to be harassed into compliance.

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#13
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Re: OSHA Top 10 Citations for 2011

11/21/2011 6:51 AM

I worked on a job back in the mid 80's where a female laborer fell to her death. It was a high rise building, and the floor slabs were in place, but no exterior walls, just 2 x 4s around the perimeter of the floors. It's inherently not safe. The girl leaned backwards against one of the 2 x 4 rails, it popped loose, and down she went. I'm sure she was new to construction. These rails were not in place to support human weight.

Anyway, it was a tragic accident. OSHA swarmed the jobsite for the next several months, and it became almost impossible for anybody to get anything done. It drastically slowed progress, and cost everybody lots of time and money.

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#15
In reply to #12

Re: OSHA Top 10 Citations for 2011

11/21/2011 7:59 AM

I was in a 40' JLG basket lift years ago. A new, unmarked septic tank was under the base of the lift, broke, caved in, and I was catapulted/jumped out of the basket.

I landed on my feet and broke some bones, but lived. OSHA has since made it a requirement to be strapped into the basket.

Well, in my case, the basket slammed into the ground and bounced, I landed about 10' in front of it. Had I been strapped in, I don't think I would be here to write this.

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#24

Re: OSHA Top 10 Citations for 2011

11/23/2011 2:13 PM

Lockout/tagout is big, but arcflash protection is their next big money maker.

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#25
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Re: OSHA Top 10 Citations for 2011

11/23/2011 4:01 PM

Yes it is being emphasized.

Milo

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#32

Re: OSHA Top 10 Citations for 2011

11/29/2011 6:08 PM

Thought this might be useful to some of you guys:

http://ehstoday.com/health/ehs_imp_37144/

Also, it's hard to pin down numbers, but I was able to find some for 2004.

In 2004 OSHA had just over 2000 full time employees. That sounds reasonable right?

The 2004 budget? $469,700,000

WTF?

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#33
In reply to #32

Re: OSHA Top 10 Citations for 2011

11/30/2011 6:18 AM
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