5-Minute Guide to OSHA Compliance - The Top-10 OSHA General Duty Clause Violations

Intended Audience:

Business Owners, Managers, Supervisors and Safety & Health Compliance Personnel.

Arguably, the General Duty Clause is OSHA’s Most Powerful Enforcement Tool:

•  The Clause says that OSHS inspectors don’t have to reference a specific OSHA standard to issue a citation.

•  Just that a hazardous workplace condition or work practice existed and it had the potential to cause death or serious injury.

•  And, that there was a feasible and useful method existed to correct, limit or avoid the hazard.

OSHA General Duty Clause Statistics:

• While GDC citations only represent around 2% of the total OSHA citations issued annually, their numbers have been increasing in recent years.

• Usually, OSHS inspectors tend to avoid issuing significant numbers of GDC citations as they take considerably more writing time, effort and investigative resources than citations based on existing OSHA standards.

• The average penalty for a Serious, GDC violation is around $8,000, compared to a an average non-GDC citation of around $4,500.

• GDC citations are harder for an employer to contest because it can’t be argued they followed an OSHA regulation because there was no exiting standard to follow.

• Contesting GDC citations usually takes more employer time, effort & money, and may require the expensive assistance from attorneys & OSHA compliance experts.

OSHA’s Top-10 General Duty Clause Citations in 2025:

• Heat Stress, when workers are exposed to excessive heat levels without adequate shade, rest or water.

• Workplace Violence, where the employer fails to take adequate measures from the known risks of assaults or violence from customers, patients, inmates or co-workers.

• Animal Handling, where workers are killed or seriously injured because of the lack of adequate safe working procedures, safety equipment or barriers, with both domesticated and wild animals.

• Combustible Dust, where the accumulated dust is of sufficient quantities to potential cause a fire or explosion hazard.

• Hazardous Chemicals, are those chemicals that are no covered under existing Permissible Exposure Limits (PEL), but only where there is a worker exposure.

• Ergonomics, since OSHS has no ergonomic standard, the GDC can be used to cite such hazards as poor workstation design, over-exertion hazards & repetitive motion tasks.

• Carbon Monoxide, is sometimes cited in warehouse and industrial settings using propane powered forklifts, generators & heaters, where the ventilation maybe inadequate to prevent unacceptably high levels of carbon monoxide.

• Unguarded Machinery or Equipment, when no specific OSHA machinery standard exists and an entrapment, pinching or crushing hazard exists.

• Industrial Vehicles, including forklifts, particularly where operator unsafe practices are noted such as operating near the edge of ramps & loading docks and the failure to use seatbelts.

• Radiation or Magnetic Hazards, can be found in some medical or industrial equipment that produces non-ionized radiation.

Best Practices to Prevent OSHA General Duty Violations:

• Train supervisors and employees on workplace hazard recognition.

• Have written policies & programs for the control of non-regulated work hazards and practices.

• Use Industrial and/or consensus guidelines & recommendations such as NFPA, NIOSH, ANSI and ASTM.

• Monitor OSHA enforcement trends on the official OSHS website, ‘www.osha.gov”.

• Conduct written Job Hazard Analyses for early recognition of potentially hazardous workplace conditions & practices.

• Implement & document appropriate & effective engineering, administrative &/or physical controls (like PPE).

• Consult with independent safety & osha compliance experts.

For Additional Information or questions on this Subject, Contact Centurion’s Loss Control Manager, Rob Brooks, at:

(606)434-0739

[email protected]

Disclaimer:

• This publication is intended for general educational purposes only, and is not to be considered as business, financial or legal advice.

• Readers should consult with appropriate professionals before making any decisions based on the content of this newsletter.

• Some of the data &/or statistics referenced within were obtained using artificial intelligence.

• Centurion Insurance Services and the writer make no guarantees or warranties of any kind, express or implied, about the reliability, completeness or suitability of the information contained herein.

• We will not be liable for any losses or damages arising from the use of the information provided.