Two facts about construction safety are each individually well known, and rarely put side by side.
One: struck-by is the second-leading cause of death among construction workers, behind falls, by NIOSH's count (168 construction deaths from struck-by incidents in 2020). It is one of OSHA's Focus Four, and about 75% of struck-by fatalities involve heavy equipment such as trucks or cranes (OSHA's construction struck-by eTool).
Two: the equipment that does most of that killing — forklifts (1910.178), motor vehicles (1926.601), and cranes (Subpart CC) — does not appear anywhere in OSHA's ten most-cited construction standards.
Put those together and you get the struck-by paradox: the hazard that ranks #2 for deaths is nearly invisible in the enforcement record. This piece works through the FY2025 citation data against the fatality record to explain why — and what it means for a contractor who wants to actually manage the risk, not just pass a walkaround.
Struck-by is the second-leading cause of construction worker death after falls, yet the standards for the equipment behind most struck-by deaths, forklifts (29 CFR 1910.178), motor vehicles (29 CFR 1926.601), and cranes (Subpart CC), are absent from OSHA's ten most-cited construction standards for FY2025.
Where OSHA cites in construction
Start with what OSHA actually writes up. These are the ten most-cited standards in federal construction (NAICS 23) for FY2025, by total citations — pulled from OSHA's Frequently Cited Standards data.
Most-cited construction standards — federal OSHA, FY2025
Red = fall family · Amber = struck-by-adjacent PPE / scaffolds. Source: OSHA Frequently Cited Standards, FY2025 (NAICS 23).
Two things jump out.
The fall family owns the list. Fall protection (1926.501), fall-protection training (1926.503), and fall-protection systems (1926.502) together account for 9,608 citations — and with ladders (1926.1053) and scaffolds (1926.451), four of the top six construction standards, and five of the top ten, are fall-related. Falls are both the #1 cause of construction death and the #1 source of citations. Enforcement and mortality line up perfectly there.
The struck-by equipment isn't on the list at all. The standards that govern the machines behind most struck-by deaths — powered industrial trucks (1910.178), motor vehicles (1926.601), cranes and derricks (Subpart CC) — are absent from the construction top 10. The only struck-by-adjacent entries are the PPE that protects against falling and flying objects (eye/face 1926.102 at 1,926; head protection 1926.100 at 852) and scaffolds (1926.451 at 2,152, which straddles fall and falling-object hazards).
Where construction workers actually die
Now the fatality side. Struck-by is not a minor category — it is the runner-up killer.
The 2024 Census of Fatal Occupational Injuries (BLS, released February 2026) recorded 1,032 fatal injuries among construction and extraction workers, with fatal falls down to 370 from 400 the year before. Struck-by sits right behind falls. Forklifts alone were the source of 84 U.S. worker deaths in 2024 (National Safety Council Injury Facts, from BLS CFOI data), and OSHA's own struck-by eTool notes that one in four "struck-by-vehicle" deaths is a construction worker — more than any other occupation.
So the equipment that generates a headline share of construction deaths draws a rounding error's worth of top-line citations. Why?
The paradox explained: citations record what an inspector sees
A citation is not a measure of how dangerous a hazard is. It is a record of what a compliance officer observed and could document during an inspection. That distinction is the whole story.
Look at what dominates the citation list — a missing guardrail, an unsafe ladder, an unplanked scaffold, a worker without eye protection. These are static conditions. They sit still. They are visible from across the site, they are present whether or not anyone is actively working, and they are straightforward to photograph and cite. An inspector walking a site will find them.
Now look at how struck-by kills: a dump truck backs over a worker in its blind spot; a load slips from a sling and drops; a crane's counterweight swings into a spotter; a forklift pins a pedestrian against a rack. These are dynamic events — they happen in the seconds a machine is moving, and then they are over. A walkaround inspection almost never catches one in the act. Unless the equipment has an obvious static defect (a dead backup alarm, a cracked fork, a defective sling on the rack), the struck-by hazard is behavioral and momentary, and it leaves nothing for an inspector to write up on a routine visit.
The result is a systematic bias: enforcement statistics over-represent the hazards you can see standing still and under-represent the hazards that move. Falls happen to be both deadly and visible (an unprotected edge is a static condition), which is why falls top both lists. Struck-by is deadly but largely invisible to a walkaround — so it tops the fatality list and misses the citation list.
This is not a criticism of OSHA's inspectors — it is a structural feature of how enforcement data is generated. The lesson is for the contractor reading the statistics: the citation Top 10 is a map of what gets caught, not a map of what kills.
The state-data wrinkle: enforcement intensity, not hazard prevalence
The federal data doesn't break powered-industrial-truck citations out by state for construction, but the State-Plan states that report under federal numbering do — and the pattern reinforces the point. Here are FY2025 construction PIT (1910.178) citations in those states:
Forklift/PIT (1910.178) construction citations by State-Plan state — FY2025
State-Plan states reporting under federal numbering. Source: OSHA Frequently Cited Standards, FY2025 (NAICS 23).
Maryland's MOSH wrote 40 construction forklift citations — nearly three times the next state. That is not because Maryland has three times the forklifts or three times the danger; it is the same enforcement-intensity outlier that shows up in Maryland's HazCom construction citations (MOSH alone accounted for the overwhelming majority of the national State-Plan HazCom total). It tells you how hard a state plan looks for a hazard, not how often the hazard actually occurs. Strip Maryland out and construction PIT citations become vanishingly rare across the reporting states — which is exactly what you'd expect for a hazard that an inspection can't easily catch.
What this means if you run the equipment
The practical takeaway is uncomfortable but useful: you can pass an OSHA walkaround and still be running the #2 fatal hazard on your site unmanaged. The citation record won't warn you, because the citation record is built from what an inspector happens to see. Struck-by asks for a different kind of defense than the one that keeps you off the citation list.
- Manage the dynamic hazard, not just the static one. Separated pedestrian walkways, barricaded travel lanes and swing radii, spotters at blind corners, internal traffic control, and enforced high-visibility apparel are what actually stop backovers and crush events — and none of them is what a routine walkaround cites.
- Make the invisible hazard visible on paper. The pre-use inspection is the one struck-by control that does leave a record — the daily forklift exam (1910.178(q)(7)), the start-of-shift vehicle check (1926.601(b)(14)), the shift crane inspection (1926.1412(d)), the competent-person scaffold check (1926.451(f)(3)). Log them, and the caught defect (a dead backup alarm, a worn sling) becomes documented proof you managed the hazard the statistics don't track.
- Read the Top 10 for what it is. It is a fine guide to what gets cited — put fall protection, ladders, and scaffolds first, because you will be written up for them. But do not read a hazard's absence from the citation list as evidence it is under control. For struck-by, the fatality record is the truer signal.
The full playbook for the equipment behind struck-by — forklifts, vehicles, aerial lifts, cranes, and scaffolds, with the CFR paragraph and the pre-use inspection duty for each — lives in the Struck-By Safety hub.
Measure what the citation record misses
The struck-by controls that work leave records, not citations: the pre-use inspection that pulls a truck with a dead backup alarm, the near miss that triggers a forklift operator's mandatory refresher, the JHA that separates people from moving equipment. Build them with these free tools — then keep them in one dated file.
Equipment & Scaffold Inspection Forklift Operator Certification Near-Miss & CAPA Report Job Hazard Analysis Builder
Method & sources
Citation figures are OSHA's Frequently Cited Standards data for federal construction (NAICS 23), FY2025, as carried in the HazComFast enforcement source of truth (extracted from OSHA on August 15, 2026). The "Top 10 all-industry" rank for powered industrial trucks is from osha.gov/top10citedstandards (FY2025). Fatality figures are the BLS Census of Fatal Occupational Injuries for 2024 (released February 2026) and NSC Injury Facts; the "second-leading cause" ranking is NIOSH's (National Stand-Down update, April 10, 2024), and the "~75% heavy equipment" figure is OSHA's construction struck-by eTool. Citation counts reflect enforcement activity, not a direct census of hazard prevalence — a limitation this analysis is built around, not around. General guidance, not legal advice; OSHA-approved State Plans run their own enforcement programs.
Related
- The hub: Struck-By Safety — vehicles, equipment & falling objects
- Forklift certification & training requirements · Crane & rigging safety · Equipment lifecycle & inspection tracking
- The standards: Powered Industrial Trucks 1910.178 · Motor Vehicles 1926.601 · Scaffolds 1926.451
- Construction Safety hub (Focus Four) · OSHA penalties by state
- Part of the OSHA Data & Research pillar — every analysis in the series, with its sources.
Frequently Asked Questions
Is struck-by the leading cause of construction deaths?
No — falls are the leading cause; NIOSH ranks struck-by incidents second among construction workers (168 construction deaths in 2020). Struck-by is one of OSHA's Focus Four construction hazards, and about 75% of struck-by fatalities involve heavy equipment such as trucks or cranes (OSHA construction struck-by eTool). In 2024, U.S. construction and extraction work recorded 1,032 fatal injuries (BLS Census of Fatal Occupational Injuries). In construction, a vehicle with an obstructed rear view may be used only with a reverse signal alarm audible above the surrounding noise or with an observer who signals that backing is safe (29 CFR 1926.601(b)(4)).
Which OSHA standards are cited most in construction?
In FY2025, federal construction (NAICS 23) citations were dominated by fall and PPE standards: fall protection 1926.501 (6,772 citations), ladders 1926.1053 (2,758), fall-protection training 1926.503 (2,171), scaffolds 1926.451 (2,152), and eye/face protection 1926.102 (1,926). Powered industrial trucks (1910.178), motor vehicles (1926.601), and cranes (Subpart CC) do not appear in the construction top 10.
Why don't forklift and crane deaths show up in the top citations?
Because a citation records what an inspector observes during a walkaround — a missing guardrail, an unsafe ladder, a worker without eye protection are static conditions that are easy to see and cite. Most struck-by deaths come from dynamic events — a backing truck, a swinging load, a rotating crane — that a walkaround rarely catches in the act. Citation counts reflect enforcement visibility, not the true frequency of a hazard. The rules do reach the moving machine through pre-use checks: forklifts examined before being placed in service (29 CFR 1910.178(q)(7)) and construction vehicles checked at the beginning of each shift (29 CFR 1926.601(b)(14)).
What is the most-cited powered-industrial-truck violation?
Powered industrial trucks (29 CFR 1910.178) were the #8 most-cited OSHA standard across all industries in FY2025, and the training provision, 1910.178(l), is the most-cited part. In the State-Plan states that report construction citations under federal numbering, Maryland's MOSH alone wrote 40 construction PIT citations in FY2025 — more than any other.
If citations under-count struck-by, how should a contractor measure the risk instead?
Measure the exposures, not the citations. The struck-by hazards that kill are dynamic — a vehicle reversing, a load swinging, a wall going up — so the honest leading indicators are how often people and moving equipment share ground, whether backing is designed out of the site layout, whether a spotter is actually used, and whether the pre-use inspections that catch a dead backup alarm or a worn choker are getting logged. A clean citation record on a site with no internal traffic control plan is not evidence of safety; it is evidence that a walkaround did not happen while the truck was moving. Those logs are the rules' own: the forklift examination (29 CFR 1910.178(q)(7)), the start-of-shift vehicle check (29 CFR 1926.601(b)(14)), the crane inspection each shift (29 CFR 1926.1412(d)), and barriers marking a crane's swing-radius hazard area (29 CFR 1926.1424(a)(2)(ii)).
OSHA figures and citations here come from our regulatory source-of-truth modules, last checked against the eCFR, OSHA.gov, and the Federal Register on October 5, 2026. Last reviewed October 6, 2026.
About This Article
Published by: HazComFast
Published: July 23, 2026
Last Updated: October 6, 2026
This content is for informational purposes only and does not constitute legal advice.