OSHA states that "de minimis conditions are those where an employer has implemented a measure different from one specified in a standard, that has no direct or immediate relationship to safety or health", and the entry describes multiple examples of de minimis violations. I thought I should contrast that with a brief discussion of SDS violations that OSHA classifies as serious and the penalties involved, but the last data I had on the penalty figures was from 2015: https://www.ilpi.com/msds/faq/partd.html#penalties
I was able to get that data by querying the OSHA citation database; all citations are recorded as a matter of public record even it the specifics are not available. And the way I got that data was sending my AI agent to find all 160,973 SDS citations out of the 3,848,182 recorded OSHA citations to date. Based on that finding, we can say that 4.04% of OSHA inspections have found an SDS violation worth citing (not de mininimus - those are not entered into OSHA's online database). Not all of those citations result in penalties.
But we can break that down by year and so much more. Therefore, I made this new web page with the information. Not only can you look at the data by specified year, you can look at it by scope of violation (serious, repeat, willful, other) in either a chart or table format:
https://www.ilpi.com/msds/osha/citations_g.html
As well as the inspection volume and percentages by industry:
And an annual table:
And you can even browse all 160,973 SDS citations which link to the data on OSHA's web site:
You can see a lot of neat things in the data. For example, HCS took full effect in January of 1989 and you can see that the percentage of serious violations of the HazCom Standard peaked in 1993 as companies realized they needed to take that seriously:
Looking at the numbers, serious and repeat violations peaked in 1990 while the willful ones peaked in 1990:
And that the 4.04% overall figure reflects a significant bolus at the onset of HCS enforcement:
But more recently, the SDS citation rate has been between 2 to 2.75%:
If anyone sees any other neat trends or correlations, reply to this post!
Best of all, I've made these (rather large) datasets used for this analysis available for download right from the bottom of page.
And, finally - and this is a hoot - when you look at all that data, the analysis, and functions, realize that I literally did this all yesterday, starting with a simple prompt to ChatGPT, which did all the heavy lift of pulling the data and creating the chart/table displays.
I could repeat this exercise for the other portions of the HazCom Standard - paragraph (e) - Written Hazard Communication Program, paragraph (f) - Labels and Other Forms of Warning, and paragraph (h) - Employee Information and Training if anyone is interested in those.
