This report summarizes the enforcement activity for the water and wastewater utility sector. During this period, 63 citations were issued across 18 inspections, resulting in $830,945 in penalties.
Executive Summary of Penalties and Citations
The data indicates that while Hazard Communication and Respiratory Protection are frequently cited, the vast majority of the financial impact stems from Permit-Required Confined Spaces and Excavation Safety.
| Category | Standard | Citations | Penalty Amount |
| Highest Financial Impact | 1910.146 (Confined Spaces) | 18 | $624,215 |
| Most Frequent Inspection Type | 1926.652 (Excavation/Trenches) | 6 | $122,573 |
| Total Enforcement | All Standards | 63 | $830,945 |
Primary Risk Areas
1. Confined Space Entry (29 CFR 1910.146)
This is the most critical area of concern for NAICS 2213.
- Citations: 18
- Total Penalty: $624,215
- Analysis: With an average penalty of approximately $34,678 per citation, OSHA is aggressively penalizing failures in confined space safety. This standard accounts for roughly 75% of the total penalties issued to the industry this year.
2. Excavation and Trenching (29 CFR 1926 Subpart P)
Work involving water and sewer lines frequently requires excavation.
- Protective Systems (1926.652): 7 citations ($122,573)
- Specific Excavation Requirements (1926.651): 4 citations ($22,819)
- Combined Impact: Excavation issues represent the second-highest risk category, emphasizing the need for proper shoring, sloping, and trench boxes.
3. Health & Communication Standards
- Hazard Communication (1910.1200): 6 citations ($5,200). Focuses on the labeling of chemicals and the availability of Safety Data Sheets (SDS).
- Respiratory Protection (1910.134): 5 citations ($16,788). Focuses on fit testing and medical evaluations for workers using respirators.
Top 10 Cited Standards by Penalty Amount
| Rank | Standard | Description | Citations | Penalty |
| 1 | 1910.146 | Permit-required confined spaces | 18 | $624,215 |
| 2 | 1926.652 | Requirements for protective systems (Excavation) | 7 | $122,573 |
| 3 | 1926.651 | Specific Excavation Requirements | 4 | $22,819 |
| 4 | 1910.134 | Respiratory Protection | 5 | $16,788 |
| 5 | 1926.417 | Lockout and tagging of circuits | 1 | $14,518 |
| 6 | 1910.1053 | Respirable Crystalline Silica | 1 | $8,867 |
| 7 | 1926.1053 | Ladders (Construction) | 1 | $6,600 |
| 8 | 1926.100 | Head protection | 1 | $5,675 |
| 9 | 1910.1200 | Hazard Communication | 6 | $5,200 |
| 10 | 1910.022 | General Requirements (Walking-Working Surfaces) | 3 | $1,809 |
Key Observations
- High Severity, Low Frequency: Standards like 1926.417 (Lockout/Tagout) and 1910.1053 (Silica) had only one citation each, but they carried significant individual penalties ($14,518 and $8,867, respectively), suggesting “Serious” or “Willful” designations by inspectors.
- Administrative & PPE Gaps: Several standards, including Slings (1910.184) and Eye/Face Protection (1910.133), were cited but carried $0 penalties. This often indicates “Other-than-Serious” violations where the employer was warned or the hazard was corrected immediately, but documentation was still recorded.
- Construction vs. General Industry: The industry is being held to both General Industry (1910) and Construction (1926) standards, complicating compliance requirements for managers.
Recommendations for Compliance
Priority One: Audit all Confined Space entry permits and training. Ensure that atmospheric testing and attendant protocols are strictly followed.
Priority Two: Review Excavation Safety. Ensure a “Competent Person” is on-site for all trenching operations and that protective systems (trench boxes/shoring) are used for any trench deeper than 5 feet.
Priority Three: Update the Hazard Communication program, ensuring all chemicals used in water treatment are properly inventoried and staff are trained on the 2024 updated GHS standards.
Source: Gemini Plus was used to analyze the OSHA data to generate this summary