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Apr 7, 2010 9:28 AM

Under the Obama Administration, Occupational Safety and Health Administration (OSHA) enforcement officials are taking a much more aggressive stance toward industry and business, Marcel Debruge, Burr & Forman LLP, told attendees at the National Tank Truck Carriers Tank Cleaning & Environmental Council annual seminar that was held April 5 and 6 in Nashville TN.

Using existing regulations, OSHA enforcement officials are striking hard at a broad range of industries—including tank cleaning. Companies are receiving more citations for “willful” and “serious” violations, and there is little willingness to negotiate. Penalties are high, with $100,000 fines now the norm for many violations.

Here are OSHA’s Top 10 cited violations—many of them applicable to tank wash racks and tank fleets—for fiscal year 2009:
• 1. Scaffolding
• 2. Fall protection
• 3. Hazard communication
• 4. Respiratory protection
• 5. Lockout/tagout
• 6. Electrical and wiring
• 7. Ladders
• 8. Powered industrial trucks
• 9. General electrical
• 10. Machine guarding

Top 10 OSHA list of willful violations in 2009:
• 1. Requirements for protective systems
• 2. Fall protection
• 3. Scaffolding
• 4. Specific excavation requirements
• 5. Permit-required confined space
• 6. Lockout/tagout
• 7. Personal protective equipment
• 8. Process safety management
• 9. Machine guarding
• 10. Asbestos