Document 3q6KBzaOkyra28V3pKaep3jO

NO. 58 PLAINTIFF EXHIBIT FD-20M Dec ii c ut December 8, 1983 FEDERAL OSHA INSPECTIONS OF COMPANY LOCATIONS Since the lest OSHA Information Release published in July 1983, Company facilities have been inspected on four occasions. All four inspections resulted from employee complaints. There were no penalties assessed on three inspections. However, OSHA proposed 12,160 in penalties for the citations issued against the Sharonvi'lle Plant. " Sharonville Plant On July 7, 1983, a federal compliance officer made an inspection due to an employee complaint. As a result, the plant received three "serious" citations' -- for the following:_ 1. Employees cngaged_Ja_thg_a2rAEillg-f--aafegaIfl&^-^hg-xepoval or demolition ct nines, structures or em.lament couepd nrin provided with re-ni rsmTM ion or covenqfimere not ____.rcordance Ti/h ?Q "Tht ^5M.1001(c)(2)(iii) and (dH2)(iiU ind spetul clothing in accordance (a) I None of the employees engaged in the removal of insulation containing 1602 asbestos inside the powerhouse were provided with typ^^^upplied lair respirators at any time during the three-day remoy^C5555!^^>o respPraTonnroyTETro^imfSnS^TnSas^sevenemployees who were working inside the powerhouse while the asbestos insulation was being removed. Also head coverings were not worn by a vast majority of the (pproximately fifty-two employees who became involved in the asbestos eeoval project during the three-day July 4, 1983 weekend. Penalty - 720. 2. | Initial monitoring was not conducted in such a manner to determine whether every employees' exposure to airborne asbestos fibers is below the prescribed limits. (a) No monitoring to determine the airborne concentration levels of asbestos fibers was performed during the three-day asbestos removal project in the powerhouse during the July 4, 1983 holiday weekend. Cited under 29 CFR 1910.1001(f)(1). Penalty - 8720. ' 3. Caution signs were not provided and displayed at all locations where airborne levels of asbestos fibers may be in excess of prescribed limits: __ ___ '1 ' ' u (a) Caution signs were ,.no.t ..posted^,at all--approaches to- the' powerhouse'whereremoval of asbestos was being performed. Cited ` under 29 CFR 1910.1001(g)(l)(i) of Federal Regulations. Penalty . ^1720. . . >* *.* 5007 1733 PRODUCED BY FORD SCF-FORD-3411 No. 58 2 December 8, 1983 Chicago Assembly Plant taring Che first quarter of 1983. (February ' 22 through March 4, 1983)-, a federal compliance officer made an inspection due to an employee complaint. As a result of that inspection the plant received on August 18, 1983 three "serious" and seven "willful" citations with penalties of $56,800 for 'the following: The three "serious" citations were: 1. Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use at the body E-Coat and phosphoric lines. Cited under Section 29 CFR 1910.151(c) of Federal Regulations. Penalty - $500. j 2. All persons inside the lead grinding booth, an inorganic arsenic regulated area, were not wearing respirators. Cited under 29 CFR 1910.1018(f)(4) of Federal Regulations. Penalty - $600. 3. A respiratory protection program for employees exposed to lead was not instituted in accordance with Section 29 CFR 1910.134(b), (d), (e) and (f). Air purifying respirators were hanging inside the wall of the lead repair booth with visible accumulation of dust and not stored in a convenient, clean, and sanitary location. Cited under 29 CFR 1910.1025(f)(4)(i) and 29 CFR 1910.134(b)(6) of Federal Regulations. Penalty - $700. The seven "willful" citations were: 1(A) The program for medical removal protection as provided in Section 29 CFR 1910.1025(k) of Federal Regulations for Occupational Exposure to Lead was not followed when a supervisor in the lead grinding and soldering area was not medically removed after two consecutive blood lead levels were in excess of 60 ug/100 g blood. 1(B) Blood lead levels were not determined at least every two months and sine protoporphyrin (spp) levels were not determined at least every four months for ten aolder grind booth employees. Cited under CFR 1910.1025(j)(2)(i)(b) as modified by Part IV, Item 4, of the Company Lead/Arsenic Variance Order. 1(C) Additional blood samples were not obtained for eight solder grind employees within ten days of receipt of laboratory results when blood lead levels exceeded 40 ug/100 g or spp levels exceeded 100 ug/lOOn. Cited under CFR 1910.1025 et seq as modified by Part IV Item 8 of the Variance Order. 1(D) Five aolder grind employees were not provided semi-annual medical exams to include items specified in paragraphs(n)(2)(i), (n)(2)(ii)(b) and (n)(2)(ii)(d) of the standard for Occuptionel Exposure to . Inorganic .Arsenic. Cited under CFR 1910.1018(n)(3) as modified by Part IV, Item 10 of the Varience Order. . - .. BOO? 1734 V* I i PRODUCED BY FORD K. December 8, 1983 1(B) A,pr*entttion of the written training program had not been provided to . all solder application, grinding and finishing employees to supplement the required annual training. Cited under. 29 CFR 1910.108 et aeq and '1910.1025 et seq as modified by Part IV, Item 15, of the Variance Order. ' Penalty for Items 1A thru C of the citation was 88,000. 2(A) The employer did not assure that employees, "prior to exiting the solder grind booth, removed surface dust from their clothing by use of vacuuming or by use of fixed-in-place overhead air showers while respirators were connected to an air supply. . (a) Employees in the solder grind booth used hand held air hoses to blow off surface dust from their clothing after disconnecting their respirators from the air supply. (b) Employees exiting the solder grind booth had visible accumulations bf surface dust on their clothing. Cited under 29 CFR 1910.1018(m)(5) and 29 CFR 1910.1025(g)(2)(viii) of Federal Regulations as modified by Part IV, Item 6, of the Variance Order. * 2(B) A clean 'and readily accessible eating facility for solder grind booth employees was not provided, Employees ate in the locker room located over the solder line. Cited under 29 CFR 1910.1018(m)(3)(i) and 29 CFR 1910.1025(i)(4)(ii) as modified by Part IV, Item 14, of the Variance Order. Penalty for Item 2 of the citation was 88,000. 3. The solder grind booth was not maintained in such condicion that airborne lead and inorganic arsenic were contained within the booth. When the air shower was used, air blew out of the solder grind booth door into the main plant. Cited under 29 CFR 1910.1010 et seq and 29 CFR 1910.1025 as modified by Part IV, Item 5, of the Variance Order. Penalty - 88,000. 4. Employees working in regulated areas, or subject to the possibility of skin or eye irritation from inorganic arsenic, were not required to shower at the end of the shift. Employees in the lead grind booth did not shower at the end of the shift. Cited under 29 CFR 1910.1018(m)(2)(i). Penalty - 88,000. 5(A) Three employees assigned to the lead grinding booth were not provided with a medical examination at the time of initial assignment to the lead grinding booth, where they are likely to be exposed to inorganic arsenic over the action level at least thirty days per year. Cited under 29 CFR 1910.1018 (n)(2) of Federal Regulations. 5(B) Training was not provided for employees at the time of initial assignment to an area where employees are aubject to inorganic arsenic exposure above the action level or for whom there is a possibility for skin or eye irritation from inroganic arsenic: (a) Pour employees assigned to the lead application and grinding areas did not receive training as required by the arsenic standard prior to ' initial work in these areas. .` (b) Training on an annual basis was not provided to all employees in the . lead solder application and grinding' areas. Cited under 29 CFR 1910.1018 (oXlXii) of Federal Regulations. Penalty for Items 5(A) and (B) was .17,000. ' ' &0C7 1735 PRODUCED BY FORD No. 58 4 I* camber 8, 1983 < Vf'>' - 6lA) food oi bevcrages wk toted iii areas exposed to . tonic aeteirail. lunches vctc stored oil oi ntsr heated surfaces ued to Belt lead. Cited vfidci 79 Ok 1910.14] (}H4) of federal Regulations. 6(b) Viittcti compliance programs fot lead did oot include items iti a work practice program required utidei paregtaphs(g)(h) and (i) of the regulation. (a) Tne iited foi cleaning of the locker root- and lunch room on a frequent baaei vas not included. (b) Ine requirement foi employees to ahos'er at the end of ehift vet not included. (c) Inc requirement foi eaployees to eat in an approved lunch area vet not included. Cited undet 79 OK 1910.10?5(e)(3)(ii)(f) of federal Regulations. 6(C) All auifaces. vere not Baintained aa free at practicable of accumulation of lead dust. An'.accu-ulatiou of lead dust vat found on a bench in the locker root- located ovei the lead aolder line. Cited under 39 OK 1910.1075(h)(1) of federal Regulations. 6(0) fj>p]oyees exposed to lead in excess of the pcto.i saible expoaute lio.it without regf-td to the use of respirators vere not requiied to sbovei at the end of the shift. Cited under 79 Ok 1910.1075(i)(3)(i) of fedeial Regulations. 6(f) f*ployees exposed to lead in excess of permissible expoaute limit, without tegatd to the use of icspitatois were not requited to wash then hands and face ptioi to eating, dr inking, so.oking or applying cosmetics. An en.ployee did not wash his hands and face after leaving the solder grind booth prior to sa-oking. Cited under 79 Cf'K 1910.1075 (i )(4)(iii) of federal Regulations. Penalty fot Items 6A through t vas 16,000. 7(A) lntee employees on B-edical ret).ova3 fro&> the lead grinding booth were not aMiitoted at least ooothly for blood lead and rpp. Cited under 79 Cf'K 1910.1075(j)(7)(i)(c) of federal Regulations. 7(b) Medical examinations and consultations for lead were not e>de available to each employee covered under 79 Cf'K 1910.1075 (j)(l)(i) at least annually vhen their blood lead exceeded 40 B.g/100 g blood at any tis.c during the proceeding tvelvc sonths. 7(C) Medical examinations and consultations for lead were not B>sde available to thtee employees in tht aolder grind booth prior to initial assignment to an atea where the airborne concentration of lead are at or above action levels. Cited under 79 CfK 1910.10?5(j)(3)(i)(6) of federal Regulations. 7(I>) Initial training vas not provided for four employees assigned to the lead grinding and application area prior to job assigm-enta where employees vere subject to lead espoaure at or above the action level ot for whom the possibility of akin or eye irritation existed. Cited under 79 CfK 1910.1D75(i)(l((iii) of federal Regulations. " 600^ 17>6 PRODUCT.!) HY fORD No. 58 . -5- December 8, 1963 ... ' 7(E) A training program wu aot repeated at least annually for each employee assigned to the lead solder and grinding area subject to lead exposure at or above the action level or for whom the possibility of skin or eye irritation existed. Cited .under 29 CFR 1910(i)(l)(iv) of Federal Regulations. Penalty for Items 7A through E of the citation was 66.000. The entire citation is being contested. No hearing date has been scheduled " * ..S'1 PLANT INSPECTIONS CONDUCTED BY STATES _________WITH APPROVED OSHA PLANS Michigan Since publication of the last OSHA Information Release in July 1983, the State of Michigan inspected Company facilities on eight occasions. Six "serious" citations and 137 "other than serious" citations were issued with proposed penalties of' $2,010. . Woodhaven Stamping Plant On August 8, 1983, a MI-OSHA compliance officer made a routine inspection. As a result of that inspection, the plant received three "serious" and forty-one "nonserious" citations. The "serious" citations were: 1. The employer failed to establish, maintain and assure the utilisation of lockout procedure to prevent unexpected motion or contact with an energy source that could cause injury during suchine repair, service or set-up. Lockout was not utilised while an electrician testing circuits in the ssin power panel box for press 16-1. Cited under General Rule 11(C), 32(1)(2) of MI-OSHA Regulations. Penalty - $280. 2. The employer failed to repair a partially missing and defective lower blade guard on DeWalt radial arm saw in the carpenter shop. Cited under Part 27 Woodworking Machinery. Penalty - $280. 3. Employer failed to provide point of operation guard or device in accordance with the requirements of the power press standard. Two power press guards had excessive openings. Cited under Part 24 Mechanical Power Presses, Rule 2461(1), 2462 and 2463 of MI-OSHA Regulations. Penalty - $280. As a result of an informal conference, the first violation and penalty were withdrawn by the State. Dearborn Engine Plant '. On August 15, 1983, a MI-OSHA compliance officer made a routine inspection. As a result of that inspection, the plant received two "serious" and fifty-one "nonserious" citations. The serious citations were: ,,. 1 80:7 1737 PRODUCED BY FORD ' No. 58 December 8, 1983 1. The employer failed to establish, maintain and assure the utilizatibh'ofa lockout procedure to prevent unexpected motion or contact vich an energy source that could cause injury during machine repair service or set-up. Repair work was being done on a grinder and a power press without the power being locked out* Cited under Part 1, General Rule 11(c), 32(1)(2) of MI-OSHA Regulations. Penalty - $360. This citation is being contested. 2. The employer failed to provide a guard for a Delta Radial arm saw. Cited under Ceneral Rule 27, Woodworking Machinery 2730(1)<23(3)(8) of MI-OSHA Regulations. Penalty - $360. Dearborn Assembly Plant On August 22, 1983, a MI-OSHA compliance officer made a routine inspection. , As a result of that inspection, the plant received one "serious" and* forty-five "nonserious" citations. The serious citation was: The employer failed to establish, maintain and assure the utilization of a lockout procedure to prevent unexpected motion or contace with an energy source that could cause injury during machine repair, service or set-up. An employee was observed working inside a body buck machine without the power locked out. Cited under Part 1, General Rule 11(c), 32(13(2) of MI-OSHA Regulations. Penalty - $450. This citation is being contested. INFORMATION Contact Lens Rumors Not True, OSHA Says Reports that contact lenses have been fused to workers' eyes are false, according to experts from OSHA, the American Academy of Ophthalmology, Che American Optometric Association, the Contact Lens Association of Ophthalmologists, and the National Society to Prevent Blindness. Bogus safety alerts -- which supposedly describe incidents at Duquense Electric and United Parcel Service, both of Pittsburgh -- have been widely circulated in industry. The alerts allege that two workers had contact lenses adhere to their corneas as a result of exposure to electrical sparks and arcs. When the workers removed their contact lenses, sccording to the scare stories, they also removed their corneas. Both companies have denied any such incidents or injuries ever happened to their employees. Eye experts sgree that the kind of accident described is physically impossible. OSHA chief Thorne Auchter urged employers and workers to ignore thebe unfounded alerts, but to redouble their efforts to eliminate genuine workplace eye hazards. . OSHA Instruction on 1984 High Rate Industry Safety Inspection Planning The Fiscal Year 19B4 High Rate Industry' Inspection Planning Guide ~f&t 'Safety" was transmitted as Appendix E of OSHA Instruction PAE 1.1A CH-1 on October 1, 1983. Designed .to assist OSHA managers in planning and scheduling programmed 5007 1 73 B i 4 I 1 1 PRODUCED BY FORD Ho. 50 - 7- December -8, 1983 ' * ' v yttMm ~ V' * * *C* ^ inspections, the guide lists industries and establishments in rank-order beginning with the industry with the highest lost workdsy injury rste. Only those industries with- an injury rate of 3.7 or greater per 100 full tine ' eaployees are included. Establishments with 10 or fewer -employees are not included. Job-Related Injuries and Illnesses Declined in 1982 The 1982 all-industry incidence rate for injuries and illnesses per 100 full-time workers declined to 7.7 as compared to the 8.3 rate for the previous year, the Bureau of Labor Statistics announced November 4. The Bureau attributed 0.1 of the incidence rate declined to a disproportionate drop in hours worked in high-risk industries in 1982. Work-related injuries, where illnesses are excluded, occurred at a rate of 7.6 per 100 full-time workers, down from 8.1 in- 1981. The Bureau also reported a reduction for injuries involving lost work time from 3.7 per 100 workers in 1981 to 3.4 in 1982. Among industry divisions, the injury incidence rate declined in the agriculture, * forestry and fishing, mining, construction, manufacturing, transportation and public utilities and wholesale trade industries. Small increases were reported for retail trade and finance, insurance and real estate. The race for establishments in construction~the highest for all industry divisions--was 14.5 in 1982. For injury esses involving lost workdays, decreases were shown in agriculture, forestry and fishing, mining, construction, manufacturing, transportation and public utilities, and wholesale trade. Injury incidence rates fell from 1981 to 1982 in all employment size groups, except for establishments with fewer than 50 employees, which showed no change. About 105,600 occupational illnesses were recorded in 1962, as compared to 126,100 in 1981. Skin disorders continued to account for about 40 percent of illnesses. Physical disorders associated with repeated trauma showed the largest percentage increase in total illnesses, rising from 18 percent in 1981 to 21 percent in 1982. ` 5007 1739 PRODUCED BY FORD