OSHA’s FY2026 Top 10 Looks Exactly Like Last Year’s. September’s Citations Show Why.

Blog Issue #58 - Article 1

OSHA put out its preliminary list of most frequently cited standards for fiscal year 2026 on September 15, presented by Prent Cline, acting deputy director of the agency’s Directorate of Enforcement Programs, at the National Safety Council’s Safety Congress & Expo in Indianapolis. The numbers come from the OSHA Information System and cover October 1, 2025 through August 31, 2026.

Fall Protection – General Requirements finished first. It has finished first for sixteen straight fiscal years.

The FY2026 List

  1. Fall Protection – General Requirements (1926.501): 4,041
  2. Hazard Communication (1910.1200): 1,961
  3. Control of Hazardous Energy, Lockout/Tagout (1910.147): 1,863
  4. Scaffolding (1926.451): 1,725
  5. Ladders (1926.1053): 1,659
  6. Respiratory Protection (1910.134): 1,608
  7. Powered Industrial Trucks (1910.178): 1,379
  8. Fall Protection – Training Requirements (1926.503): 1,273
  9. PPE – Eye and Face Protection (1926.102): 1,120
  10. Machine Guarding (1910.212): 1,072

The ten standards are the same ten that made FY2025. A few swapped places. Lockout/tagout moved up to third, scaffolding climbed two spots to fourth, and powered industrial trucks gained one. Respiratory protection and fall protection training each dropped a place. Ladders fell two.

Every category came in lower than last year, which is less encouraging than it sounds. Citation counts follow inspection activity as much as conditions in the field, and when all ten drop at once, the likeliest explanation is fewer inspections. Watch the rankings, not the totals.

Two caveats. The data is preliminary and won’t be final until spring 2027, and each total covers every subsection of a standard, so one inspection can add several citations to a single line.

Then September Happened

Three enforcement actions closed out the month, together worth $878,246. Not one of them involves a hazard anybody would call new.

ModWash LLC: $446,864

On September 23, OSHA cited ModWash LLC, an express car wash company with locations around the country, including five in Sicklerville, New Jersey. Workers serviced equipment that hadn’t been locked out, and the company had no energy control procedures in place. OSHA called that willful. Two repeat violations followed, covering the missing written procedures and the training that should have gone with them.

Five serious violations dealt with something else entirely: no noise monitoring program, no baseline audiogram within six months of exposure, and no training for employees working above 85 decibels. Two more covered lockout devices the company didn’t supply and didn’t attach.

The noise findings are worth a second look. They have nothing to do with the lockout problem. They turned up because an inspector was already on the property, which is usually how the second and third problems get found.

Araujo Construction Corp.: $265,868

On September 15, the same day OSHA announced the Top 10, the agency cited Martin Araujo, doing business as Araujo Construction Corp. of Calumet City, Illinois, after two separate investigations.

Carpenters and laborers were setting roof rafters and sheathing 25 feet up with nothing to catch them. OSHA issued two willful violations for the missing fall protection and nine repeat violations covering head and eye protection, stairway handrails, and ladders that stopped short of the three feet they’re supposed to extend above a landing. A serious violation addressed unsafe access to a platform, and an other-than-serious one covered training certifications the company couldn’t produce. Araujo has now drawn fall protection citations across several inspections over several years.

T & T Pipeline Co. Inc.: $165,514

Also on September 23, OSHA cited T & T Pipeline Co. Inc. of Orlando over a death at a New Smyrna Beach jobsite. On March 17, 2026, a crew was changing a drill bit on a horizontal directional drilling machine when the pipe stem started turning. It struck and killed one of the workers. OSHA issued a single willful violation for struck-by exposure, at the statutory maximum for one willful citation.

What the Three Have in Common

Araujo is numbers one, five, and nine on the list. ModWash is number three. T & T doesn’t carry a Top 10 standard, but the situation is familiar enough: somebody had hands on equipment that could still move.

Sixteen years is longer than a lot of safety careers, and a standard doesn’t stay at number one that long because it’s obscure. Fall protection is among the best-publicized requirements OSHA has, with a national emphasis program behind it, an annual stand-down, and free material in several languages.

So the problem isn’t that employers don’t know the rule. It’s the distance between knowing it and having anchor points installed, harnesses issued, and a foreman who checks before anyone goes up. That’s a management job, and it’s where these three companies came apart.

If you want something to do with the list, treat the top five as an audit sequence. For each one, ask whether your written program actually matches the equipment you run today, whether training is on file with names and dates, and whether anyone has watched the job done in the field in the past year. The gaps you find will look a lot like the citations above.

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