Housekeeping toolbox talk: what to cover and how to run it

Last updated 2026-07-09

Why does housekeeping show up on so many OSHA citations?

Housekeeping gets cited because clutter causes falls, and falls hurt people. Slips, trips, and falls are the second leading cause of nonfatal occupational injuries in the United States, accounting for roughly 211,640 cases requiring days away from work in 2022 according to the Bureau of Labor Statistics ^[1]. A large share of those trace directly back to cluttered aisles, wet floors, and materials stacked where they shouldn't be. That's why OSHA keeps coming back to housekeeping violations year after year.

The relevant standards are short. 29 CFR 1910.22(a) requires that "all places of employment, passageways, storerooms, service rooms, and walking-working surfaces shall be kept in a clean, orderly, and sanitary condition" ^[2]. On construction sites, 29 CFR 1926.25(a) mirrors that language and adds that scrap lumber with protruding nails, usable lumber, and other debris must be cleared regularly ^[3]. Neither standard runs more than a paragraph, which is exactly why OSHA inspectors treat violations as easy tickets to write.

Poor housekeeping makes every other hazard worse. A cord running across an aisle is a trip hazard on its own. Add a forklift operating nearby and it becomes a struck-by scenario. Stack flammable rags next to a cutting area and you've stacked a fire risk on top of a clutter problem. Housekeeping is the base layer that keeps every other safety control from being undermined.

Small businesses get cited just as often as large ones. OSHA doesn't scale its enforcement threshold by company size for housekeeping violations, so a five-person shop can receive the same "other-than-serious" citation as a 500-person facility. The average penalty for an other-than-serious violation was $1,116 in fiscal year 2023, and serious violations averaged $4,340 ^[4].

What OSHA standards actually require for workplace housekeeping?

Two standards cover most housekeeping situations. For general industry (manufacturing, warehouses, retail, offices, service businesses), the controlling rule is 29 CFR 1910.22, "General requirements" under Subpart D, Walking-Working Surfaces ^[2]. For construction, it's 29 CFR 1926.25 under Subpart C, General Safety and Health Provisions ^[3].

Here's a quick side-by-side of what each standard addresses:

Requirement	29 CFR 1910.22 (General Industry)	29 CFR 1926.25 (Construction)
Clean and orderly condition	Yes	Yes
Aisle width maintained	Yes (width must be marked)	Not specified
Scrap lumber / nails	Not mentioned	Explicitly covered
Combustible scrap removal	Not in 1910.22 (see 1910.37)	Yes
Wet/slippery surfaces	Covered in 1910.22(a)	Covered in 1926.25(b)
Material storage	Not in 1910.22	1926.25(a): usable lumber stacked

Beyond those two anchors, several related standards feed into a full housekeeping picture. 29 CFR 1910.141 covers sanitation (waste containers, floor drainage). 29 CFR 1910.37 covers egress and requires exit routes to stay clear at all times ^[12]. If your site generates hazardous waste or chemical spills, hazard communication rules under 29 CFR 1910.1200 intersect with cleanup procedures too.

OSHA also reaches housekeeping through the General Duty Clause (Section 5(a)(1) of the OSH Act), which requires employers to provide a workplace free from recognized hazards ^[10]. OSHA has cited this clause for housekeeping-related fire hazards and blocked exits even when a specific standard wasn't squarely on point.

What should a housekeeping toolbox talk actually cover?

A housekeeping toolbox talk needs to be specific enough to be useful and short enough that people stay awake. Ten minutes is the sweet spot. Here's an outline you can read straight through or adapt.

Opening (1-2 minutes) State the topic plainly: today we're talking about keeping the work area clean and why it matters beyond how it looks. Mention one recent near-miss or housekeeping issue specific to your site if you have one. Real examples from their own workplace get attention. Abstract rules don't.

Hazard review (3-4 minutes) Walk through the four main hazard categories that poor housekeeping creates:

1. Slip and trip hazards: cords across aisles, wet floors without signage, debris on walking surfaces, uneven stacking that overhangs into pathways. 2. Fire hazards: combustible materials stored near ignition sources, oily rags left in open containers, cardboard and paper accumulation near electrical panels. 3. Struck-by and caught-in hazards: tools and materials left at height where they can fall, unsecured loads, improperly stored compressed gas cylinders. 4. Ergonomic hazards: searching for misplaced tools adds time and awkward postures; organized workspaces reduce repetitive reaching and bending.

OSHA expectation (1-2 minutes) Tell the crew the plain-English rule: OSHA requires that all walking-working surfaces stay clean, orderly, and sanitary (29 CFR 1910.22 or 1926.25 depending on your site) ^[2][3]. On construction sites, call out the scrap lumber rule specifically: nails must be bent or pulled before lumber is stacked. Combustible scrap has to move off the site at regular intervals.

Your site-specific rules (2-3 minutes) This is where generic talks fall apart. List the actual housekeeping standards for your site. Where are the waste containers? What's the end-of-shift cleanup expectation? Who owns the shared aisle? Who calls the spill response? Name names and locations.

Closing question and sign-off (1 minute) Ask one specific question: "Where have you seen housekeeping slip this week?" Get at least one answer. Log attendance. Keep the sign-in sheet.

Run a version of this talk at least monthly, and again after any incident or near-miss with a housekeeping component. OSHA doesn't mandate a specific frequency for toolbox talks, but documented training helps demonstrate good-faith compliance during inspections ^[4].

How is a construction housekeeping toolbox talk different from a general industry one?

Construction sites have housekeeping hazards a warehouse or shop simply doesn't. The environment changes daily. Trades overlap. Debris piles up faster than on a static worksite. A construction housekeeping toolbox talk has to account for all of that.

29 CFR 1926.25 is the controlling standard, and it's specific about a few things 1910.22 never mentions ^[3]. Scrap lumber with protruding nails must either have the nails pulled or bent over before the lumber is stacked. Combustible scrap and debris must be removed from the work area at regular intervals. Form and scrap lumber can't just sit wherever it lands.

A construction housekeeping toolbox talk should add these points to the general outline above:

Layered trades and shared spaces. When multiple subcontractors work in the same area, cleanup accountability gets murky. Who owns the mess between trades? Spell it out in subcontractor agreements and repeat it in daily talks. The general contractor is ultimately responsible for site-wide conditions under 29 CFR 1926.16, which governs prime contractor and subcontractor responsibilities ^[11].

Material storage at elevation. Tools, fasteners, and cut materials left on elevated decks or scaffolding become falling-object hazards for workers below. This ties straight to struck-by, one of the leading causes of construction fatalities. OSHA's "Focus Four" hazards include struck-by among the four causes responsible for more than half of all construction worker deaths annually ^[4].

Perimeter and floor opening covers. Covers over floor openings must be secured and marked. A piece of plywood set over an opening is not a compliant cover unless it's secured so it can't be displaced by foot traffic or wind.

End-of-day walk-through. On construction, an end-of-shift cleanup expectation should be baked into the crew's routine. Assign it, time it (15 minutes), and make it part of the supervisor's close-out checklist.

Wet weather. Mud tracked in from active grading, wet concrete dust, and standing water from rain all need specific mention in winter and rainy-season talks. Slippery walking surfaces caused 49,000 nonfatal injuries in private sector construction in 2021 according to BLS ^[1].

What does a completed housekeeping toolbox talk form look like?

The form doesn't need to be complicated. OSHA doesn't mandate a specific format for toolbox talk records, but your documentation has to show who was trained, what was covered, and when it happened. If you're ever cited and want to demonstrate good-faith effort, an incomplete or missing sign-in sheet makes that impossible.

A workable form has these fields:

• Date and time of the talk
• Location (project address or department)
• Topic: "Housekeeping" or something more specific (e.g., "Aisle clearance and fire hazard control")
• Name of the person who delivered the talk
• Key points covered (three to five bullet points is enough)
• Attendee signature block (printed name plus signature)
• Space for a near-miss or hazard identified during the talk

Keep completed forms for at least three years. That's the retention period OSHA uses for most training records, and it sits under the OSHA 300 log retention requirement of five years for injury records ^[6]. Some attorneys recommend keeping safety training documentation for the statute of limitations period in your state (often three to six years), since civil litigation can follow an injury long after the OSHA inspection closes.

If you're already running written safety programs, your housekeeping toolbox talk records slot in as supporting documentation for your overall safety and health program. Building those written programs doesn't have to eat a week. Tools like the SafetyFolio program generator produce OSHA-compliant written programs in about 15 minutes, which gives you the scaffolding to attach your toolbox talk records to something formal.

What are the most common OSHA housekeeping violations and what do they cost?

OSHA's top citation lists show where inspectors actually write tickets. 29 CFR 1910.22(a) has appeared in OSHA's top 10 most cited standards in multiple recent fiscal years, generating thousands of citations annually ^[4].

The housekeeping conditions inspectors document most often include:

• Cluttered aisles and passageways that cut the required clear width
• Accumulation of combustible materials near ignition sources or electrical panels
• Wet or slippery floors without drainage, mats, or warning signs
• Scrap lumber with exposed nails left on construction sites (1926.25 violations)
• Blocked or cluttered emergency exits (cited under 1910.37 but often rooted in housekeeping failures)
• Unsecured or improperly stacked materials

Penalty ranges depend on violation classification:

Violation Class	Penalty Range (FY 2024 adjusted)	Typical Housekeeping Scenario
Other-than-serious	$0 to $16,550	Clutter in non-egress area, minor aisle obstruction
Serious	$1,116 to $16,550	Blocked exit, slip hazard near machinery
Repeat	Up to $165,514	Same condition cited in prior inspection
Willful	$11,524 to $165,514	Ongoing documented failure to correct

Those figures reflect OSHA's 2024 adjusted maximum penalties ^[4]. Here's the practical reality: first-time other-than-serious housekeeping citations usually settle for $1,000 to $3,000, especially for small employers who correct the condition immediately and show prior training documentation. A repeat violation for the same housekeeping condition is where the number jumps hard, which is exactly why running and documenting regular toolbox talks matters.

For context on compliance training options and how they feed into overall OSHA preparedness, the OSHA training hub has a good overview.

How often should you run a housekeeping toolbox talk?

OSHA doesn't set a mandatory frequency for housekeeping toolbox talks. What OSHA does require is that training be "adequate" and that employees be informed of the hazards they're exposed to. The right frequency depends on your actual hazard exposure.

Here's what makes sense for different work types:

• Active construction sites: monthly at minimum, and after any incident with a housekeeping component. Many general contractors run safety talks weekly with housekeeping as a rotating topic.
• General manufacturing or warehousing: quarterly is usually defensible if your site is stable, but monthly is better if you have high turnover or a lot of temporary workers.
• Office and retail environments: annually may be enough unless you have a documented slip-and-fall history or seasonal hazards (holiday inventory, tracked-in moisture).
• After a near-miss or injury: immediately, regardless of your scheduled cycle.

The strongest protection isn't frequency. It's documentation and content quality. An undocumented weekly talk is weaker evidence of good-faith compliance than a documented monthly talk with signed attendance sheets. OSHA inspectors ask for records. If you can hand over three years of signed toolbox talk sheets, that carries real weight during an informal conference over a citation.

Train new hires on housekeeping during onboarding, not at the next scheduled toolbox talk cycle. An employee who trips on day one while you're waiting for the monthly talk is a workers' compensation claim and possibly an OSHA recordable ^[6].

What are the biggest housekeeping hazards supervisors miss?

The visible hazards get addressed. Trash on the floor, obvious puddles, lumber in the walkway. The ones that actually cause injuries are usually the chronic, low-grade conditions that go invisible because they've been there for weeks.

Electrical panel clearance. 29 CFR 1910.303(g)(1) requires 36 inches of clear working space in front of electrical panels up to 150 volts to ground ^[7]. Boxes stacked in front of panels are one of the most common things electrical inspectors and OSHA find together. It's a housekeeping issue and an electrical hazard at the same time.

Chemical storage and spill response materials. Incompatible chemicals stored together because "it's just temporary" is a housekeeping failure with real chemical release potential. Hazard communication standards require storage to follow SDS guidance, which means housekeeping includes where things go, not only whether the floor is swept.

Cord and hose management. Cords draped over machinery, across aisles, or run under mats wear faster, get damaged, and create trip hazards. A cord should never cross a walking path without a cord cover rated for foot traffic or vehicle traffic as applicable.

Compressed gas cylinder storage. Cylinders stored lying flat, near heat sources, or with caps removed are housekeeping violations and potential explosive hazards. 29 CFR 1910.101(b) requires cylinders to be stored upright with caps on when not in use ^[7].

Overhead clutter. Tools and materials left on overhead structure, top shelving, or scaffold decking. These don't show up in a standard walk-through and usually escape notice until something falls.

A good toolbox talk includes a "what did you notice this week" prompt precisely because supervisors can't see everything. Workers engaged enough to report hazards are the best early warning system you have.

How do you make a housekeeping toolbox talk actually stick?

Most housekeeping talks fail for the same reasons: they're generic, they're delivered with all the energy of a safety video nobody watches, and the supervisor is obviously going through the motions. Workers can tell.

A few things that actually move the needle:

Tie it to a real event. If someone slipped near the parts washer last Tuesday because there was hydraulic fluid on the floor, start there. Not to shame anyone, just: "Here's what happened, here's what we're going to do differently." Real events from the actual workplace land differently than statistics.

Walk the area first. Before the talk, spend five minutes walking the work area and note two or three specific housekeeping conditions. Bring those into the talk by location: "the area by press number three" or "the south exit aisle." Specificity signals you actually looked.

Assign ownership, not responsibility. "Everyone is responsible" means no one is. Assign a cleanup zone or task to a specific person or team. Rotate it. When someone's name is attached to an area, that area gets kept up.

Make cleanup visible in the schedule. If cleanup has to happen but there's no time budgeted for it, it doesn't happen. Fifteen minutes at the end of shift for housekeeping belongs in the schedule, not squeezed out by production pressure.

Close with one concrete ask. "Before you leave today, make sure the aisle from the loading dock to the emergency exit is clear" is a concrete ask. "Let's all be more careful about housekeeping" is not. One specific action, stated plainly, repeated at the end.

For supervisors who want to connect toolbox talks to a broader safety structure, a solid written safety program gives you the policy backbone the talks reinforce. If you're building that program from scratch, SafetyFolio's generator produces OSHA-ready written programs in about 15 minutes, so you're not starting with a blank page.

What questions do OSHA inspectors ask about housekeeping during an inspection?

When an OSHA compliance officer walks your site, housekeeping is often the first thing they observe during the opening walk-around, before they even pull out a clipboard. The physical condition of the workplace sets the tone for the whole inspection.

Common questions and records requests to be ready for:

• "Do you have a written housekeeping policy or procedure?" One isn't legally required for housekeeping specifically, but it shows you've thought about it systematically.
• "How do employees know what the housekeeping expectations are?" This is where toolbox talk records matter. Show dated, signed attendance sheets.
• "Who is responsible for maintaining the aisles / spill cleanup / combustible material removal?" Name-and-role clarity in your written program helps here.
• "Has this area been like this during the entire inspection period?" Inspectors document conditions at the time of inspection. If a condition has clearly been present a long time and you can't show corrective action, that's ammunition for a repeat or willful classification.
• "Have employees been trained on housekeeping hazards?" Your toolbox talk sign-ins, new hire training records, and any written program orientation records are the answer.

The best thing you can do before an inspection is walk your own site the way a compliance officer would: slow pace, eyes on floors, aisle clearances, exit paths, storage areas, and overhead. Write down what you find. Fix it. Log that you fixed it. That paper trail is your defense.

For a broader picture of how OSHA inspections work and what triggers them, the OSHA hub covers the process from opening conference to citation. If you have workers who operate powered industrial trucks, reviewing forklift certification requirements is worth your time too, since fork truck operations and housekeeping run into each other constantly in warehouse environments.

Where can you find free housekeeping toolbox talk templates?

Several reliable sources publish free templates you can use directly or adapt.

OSHA's website has a toolbox talk library at osha.gov with downloadable talks organized by industry and topic ^[4]. The quality varies, but they're legally grounded and free.

OSHA's Susan Harwood Training Grant Program produces plain-language worker training materials, some covering housekeeping topics. These are published through grantee organizations and available at no cost.

The National Safety Council (NSC) publishes toolbox talk resources for members and posts some publicly accessible templates.

State plan OSHA agencies often publish their own toolbox talk libraries. Cal/OSHA (California), Washington L&I, and Michigan MIOSHA each maintain training resources that often include housekeeping. If your state operates under a state plan rather than federal OSHA, check your state agency's website first, since the standards may differ slightly from federal rules ^[9].

AGC (Associated General Contractors of America) and NAHB (National Association of Home Builders) both produce construction-specific toolbox talk templates, including housekeeping and scrap cleanup, built for their member trades.

A few honest caveats about free templates. Most generic ones are fine as a starting point, but they cover OSHA minimums and nothing specific to your site. A talk that says "keep aisles clear" won't tell your crew that the problem aisle is the one between the welding station and the parts cage. Adapt every template to your actual work environment before you use it. A customized talk takes ten extra minutes to write and is five times more useful.

Frequently asked questions

What is a housekeeping toolbox talk?

A housekeeping toolbox talk is a short (5-15 minute) safety meeting focused on keeping the workplace free of slip, trip, fire, and struck-by hazards caused by clutter, debris, and improper material storage. It covers OSHA requirements under 29 CFR 1910.22 (general industry) or 29 CFR 1926.25 (construction), site-specific rules, and specific cleanup responsibilities. The talk should end with signed attendance documentation.

Is a housekeeping toolbox talk required by OSHA?

OSHA doesn't mandate toolbox talks by name or set a specific frequency for housekeeping training. What OSHA does require is that employees be informed of the hazards they're exposed to and that workplaces meet the cleanliness and orderly condition standards in 29 CFR 1910.22 and 1926.25. Documented toolbox talks are the most practical way small employers demonstrate that training obligation was met during an inspection.

What OSHA standard covers construction site housekeeping?

29 CFR 1926.25 covers housekeeping on construction sites. It requires form and scrap lumber to have nails removed or bent before stacking, combustible scrap to be removed at regular intervals, and all areas to stay in a clean, orderly condition. It applies to all construction, alteration, and repair activities covered under Part 1926. General contractors are ultimately responsible for site-wide compliance under 29 CFR 1926.16.

How long should a housekeeping toolbox talk be?

Ten minutes is the practical target. You need enough time to cover the four main hazard categories (slip/trip, fire, struck-by, ergonomic), your site-specific rules, and at least one question-and-answer exchange. Talks shorter than five minutes tend to feel rushed and miss site-specific content. Talks longer than 15 minutes lose the crew's attention unless there's been a serious incident that warrants extended discussion.

What are the top housekeeping violations OSHA cites?

29 CFR 1910.22(a) is one of OSHA's most cited standards annually. The most common specific conditions cited include cluttered or blocked aisles and passageways, combustible scrap accumulated near ignition sources or electrical panels, wet or slippery floors without drainage or signage, blocked emergency exits, and on construction sites, scrap lumber with protruding nails. Penalties range from roughly $1,100 for other-than-serious to over $165,000 for willful or repeat violations.

How do I document a housekeeping toolbox talk?

Your documentation needs to show the date, location, topic covered, who delivered the talk, and the printed name and signature of every attendee. A simple one-page form works. Keep records for at least three years. If OSHA issues a citation and you want to argue good-faith effort during an informal conference, signed attendance sheets with specific topics listed are your primary evidence. Missing or vague documentation removes that option.

What should a construction housekeeping toolbox talk specifically include?

A construction housekeeping toolbox talk should cover scrap lumber nail removal under 29 CFR 1926.25, combustible scrap removal frequency, floor opening cover security, overhead material storage at elevation, multi-trade cleanup accountability, end-of-shift walk-through expectations, and wet weather slip hazards. Generic talks that don't address the layered-trades scenario common on construction sites miss the most common sources of housekeeping failures on those projects.

Can housekeeping violations trigger a willful OSHA citation?

Yes. OSHA can classify a violation as willful if the employer knew about the hazard and made no reasonable effort to correct it. A documented inspection showing the same condition in a prior cycle is the classic path to willful classification. Willful penalties reach $165,514 per violation as of fiscal year 2024. Running and documenting toolbox talks, then correcting identified conditions, is the clearest way to avoid that classification.

What's the difference between a toolbox talk and a safety meeting?

A toolbox talk is a short, informal, topic-specific conversation held at or near the work area, typically 5-15 minutes. A safety meeting is usually a longer, more formal session held in a conference room or break room, often covering multiple topics, policy updates, or incident reviews. Both generate attendance records. Toolbox talks are more practical for daily hazard reinforcement; safety meetings are better for policy training and program updates.

Do office workers need a housekeeping toolbox talk?

Office environments have real housekeeping hazards: cords across walkways, boxes stacked blocking fire exits, cluttered stairwells, wet floors near building entrances in rain or snow. 29 CFR 1910.22 applies to all general industry employers including offices. A brief annual housekeeping reminder for office staff, documented in writing, is minimal effort and covers your obligation. Slip-and-fall injuries happen in offices at meaningful rates, particularly during weather changes.

What are the Focus Four hazards in construction and how does housekeeping relate?

OSHA's Focus Four are falls, struck-by, caught-in/between, and electrocution. These four causes account for more than half of all construction worker deaths each year. Housekeeping directly affects three of them. Poor housekeeping creates trip-and-fall conditions, allows tools and materials to be left where they can fall and strike workers below, and contributes to electrical panel access being blocked. Addressing housekeeping reduces exposure across multiple hazard categories at once.

How do I hold workers accountable for housekeeping without creating a negative culture?

Assign cleanup zones by name rather than relying on general responsibility. Build end-of-shift cleanup into the schedule with dedicated time so it doesn't compete with production. Lead with what you observed during your own walk rather than assigning blame. When a worker reports a hazard, act on it quickly and acknowledge it. Workers stop reporting when reports go nowhere. A toolbox talk that ends with one specific ask, followed by a supervisor who actually checks, builds accountability without punishment culture.

Is a housekeeping toolbox talk the same as a housekeeping written program?

No. A toolbox talk is a recurring verbal training event documented with a sign-in sheet. A written housekeeping program is a formal policy document that defines responsibilities, inspection schedules, cleanup standards, and corrective action procedures. OSHA doesn't specifically require a standalone written housekeeping program, but having one strengthens your defense during inspections and provides the framework your toolbox talks reinforce. The two work together, not as substitutes for each other.

Where can I find a free housekeeping toolbox talk template?

OSHA's website at osha.gov has a library of free toolbox talk materials. State plan OSHA agencies like Cal/OSHA, Washington L&I, and Michigan MIOSHA also publish free templates that reflect their state-specific standards. The Susan Harwood Training Grant Program produces plain-language materials available at no cost. AGC and NAHB publish construction-specific templates for their industries. Whatever template you start with, adapt it to your specific site conditions before using it.

Sources

1. Bureau of Labor Statistics, Injuries, Illnesses, and Fatalities program, 2022 data: Slips, trips, and falls accounted for roughly 211,640 cases with days away from work in 2022; 49,000 nonfatal injuries from slippery surfaces in private sector construction in 2021
2. OSHA, 29 CFR 1910.22 Walking-Working Surfaces General Requirements: All places of employment, passageways, storerooms, service rooms, and walking-working surfaces shall be kept in a clean, orderly, and sanitary condition
3. OSHA, 29 CFR 1926.25 Housekeeping (Construction): Scrap lumber with protruding nails must have nails removed or bent; combustible scrap must be removed at regular intervals from construction sites
4. OSHA, Top 10 Most Cited Standards and Penalty Information: 29 CFR 1910.22(a) appears in OSHA top cited standards annually; FY2024 penalty maximums are $16,550 for serious and $165,514 for willful/repeat violations; average other-than-serious penalty was $1,116 in FY2023
5. OSHA, Recordkeeping Rule 29 CFR 1904, Retention Requirements: OSHA 300 logs and related records must be retained for five years; training records generally retained three years as standard practice
6. OSHA, 29 CFR 1910.303(g)(1) Electrical Working Space and 29 CFR 1910.101 Compressed Gases: 36 inches of clear working space required in front of electrical panels up to 150 volts to ground; compressed gas cylinders must be stored upright with caps on when not in use
7. OSHA, State Plans program overview: 28 states and territories operate OSHA-approved state plans with standards that must be at least as effective as federal OSHA standards; state agencies publish their own training resources
8. OSHA, General Duty Clause Section 5(a)(1) of the OSH Act: Employers must furnish a workplace free from recognized hazards likely to cause death or serious physical harm; OSHA has cited this for housekeeping-related fire and egress hazards
9. OSHA, 29 CFR 1926.16 Contractor Responsibilities (Construction): General contractors are responsible for site-wide OSHA compliance including housekeeping conditions created by subcontractors
10. OSHA, 29 CFR 1910.37 Maintenance, Safeguards, and Operational Features for Exit Routes: Exit routes must be kept free of obstructions at all times; OSHA cites 1910.37 for blocked exits regardless of whether the blockage results from housekeeping failures