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34 Pallet C e nt ral • Ma rch -Ap r il 2 0 24 January 1, 2024, however, those pallet companies with 100 or more workers at a worksite will need to upload all three OSHA forms: 300A, 300, and 301. e Bureau of Labor Statistics (BLS) reports injury data by NAICS code, and for 2020, NAICS 321920 (Wood container and pallet manufacturing) had injuries with the following rates (nonfatal injuries involving days away from work per 10,000 full-time workers): • Total Rate: 207 • Sprains, strains, tears: 29.3 • Fractures: 31.7 • Cuts, lacerations, punctures: 60.0 • Multiple traumatic injuries: 4.5 So what are the most-cited standards for FY 2023 in NAICS 321920? OSHA lists the following, and, indeed, my experience representing NWPCA members in OSHA cases supports these being the hot buttons when inspectors show up. In total, the pallet sector had $1.2 million in OSHA penalties assessed during FY 2023! e most cited standards were (all in 29 CFR): 1. 1910.147 – Lockout/Tagout and control of hazardous energy 2. 1910.178 – Powered industrial trucks (forklifts, etc.) 3. 1910.95 – Occupational Noise Exposure 4. 1910.212 – General requirements for machine guarding 5. 1910.213 – Woodworking machine guarding 6. 1910.305 – Wiring methods and electrical components and equipment 7. 1910.22 – General safety requirements for walking/working surfaces 8. 1910.120 – Hazard Communication Standard 9. 1910.134 – Respiratory Protection 10. 1910.219 – Mechanical power- transmission apparatus. What is notable is that these standards do not overlap well with the "Top 10" most commonly cited OSHA standards overall, so this is the list that employer should focus on in their safety efforts, inspections, and training. Other employers in the industry were cited for violations ranging from failing to have fall and falling object protection, safety maintenance of exit routes, lack of adequate portable fire extinguishers, lack of first aid training, and material handling.

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