Document 6R9Lm6KvN4OG4abdYKaDEORz6
CONOCO CHEMICALS 1981 Industrial Hygiene Seminar
La Mansion Del Rio Hotel San Antonio, TX
PRELIMINARY AGENDA
WEDNESDAY, MARCH 4, 12:00 .pm
Weicome/Administrati on
Employee Communication Program -- Channel 2 Videotape "Chemicals and Cancer"
Medical Testing Program -- Past and Present: Policies and Procedures
-- Purpose: Management's View
Regulatory Update
THURSDAY, MARCH 5, 8:00-5:00 pm
Industrial Hygiene Policy and Procedures -- Exposure Abatement Program -- Deregulation of Areas -- Written Determinations -- Computerized Data Storage System Update -- Radiation -- New Material Safety Data Sheets
Legal Presentation and Discussion -- Contractor Policies & Responsibilities
-- OSHA Inspection Guide
Air Sampling Methods -- Passive Dosimetry -- Asbestos Identification and Sampling
FRIDAY, MARCH 6, 8:QQ-12:0Qpm
Chemicals Mortality Study Update; NCI Baltimore Study
Industrial Hygiene Audit Program
Roundtable Discussion - EO and Benzene
M. Reynolds J. Withey T. Grumbles J. Hall Dr. Massad R. Lehmkuhl
T. Grumbles
Legal Dept. P. Fetzer
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I.
II.
III.
IV.
V.
VI.
VII.
APPENDIX A APPENDIX B APPENDIX C APPENDIX D
CORPORATE
OSHA INSPECTION GUIDELINES
WHEN THE OSHA INSPECTOR ARRIVES..................................1 PRESENTATION OF A WARRANT.....................................................6
OPENING CONFERENCE ...................................................................... 7
CONDUCT OF THE INSPECTION.....................................................8
TRADE SECRETS.......................................................................................10
CLOSING CONFERENCE ...................................................................... 11
FOLLOWING THE INSPECTION.........................................................11
CORPORATE OSHA INSPECTION FORM FORM LETTERS TO AREA DIRECTOR OF OSHA SAMPLE OSHA INSPECTOR CREDENTIALS SAMPLE OSHA INSPECTION FORMS
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CORPORATE
OSHA INSPECTION GUIDELINES
These procedures should be used in connection with all OSHA inspections at Conoco facilities. There should be established at each facility an OSHA Inspections Coordinator (OIC) and an alternate, both of whom are fully aware of company policy regarding OSHA inspections as well as plant safety. The OIC and alternate should be technically compe tent and knowledgeable about the product and/or processes at that particular facility and trained in the monitoring of substances to which employees may be exposed, the OIC and alternate should be instructed as to the procedures to be followed when an OSHA inspector, known as a Compliance, Safety and Health Officer (CSHO), arrives. They should have a general working knowledge of OSHA rules and regulations and should be thoroughly familiar with the Corporate Inspec tion Guidelines. The Guidelines should be kept in a readily available location at all times and reviewed prior to and during an inspection.
The following procedures are to be exercised whenever an OSHA inspection is initiated:
I. WHEN THE OSHA INSPECTOR ARRIVES
A. In the event any employee receives advance notice of an OSHA inspection, or at a time other than during regular working hours, such notice should be brought to the atten tion of the Department Safety Director, the Corporate Safety Division, and the Legal Department immediately. (Advance notice of inspections is forbidden under OSHA regulations except under specifically stated circumstances.)
When a CSHO presents himself at the official entrance to a facility, he (and any persons accompanying him) should be requested to sign a visitor's register, plant pass or any other book or form routinely used to control the entry and movement of persons upon its premises. The plant manager should be notified immediately. The OIC or his alternate should then be immediately notified of the CSHO's presence at the facility.
B. Immediately upon hearing of the arrival of the CSHO, the OIC should take out the Corporate OSHA Inspection Guidelines and the Corporate OSHA Inspection Forms. The Guidelines and the Forms should NOT be shown to the CSHO under any circumstances. (They need not be hidden. They simply should not be made available for inspection or review.)
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C. The CSHO should be escorted by an "appropriate route" to the office of the already notified OIC or alternate. An "appropriate route" means one revealing as little of the facility as possible, i . e. , the CSHO should be taken outside work areas and through the entrance closest to the IOC's office or the area to be inspected. The CSHO should be exposed to as little as possible of the company facilities
because he may inspect and cite the company for violations within plain view without the necessity of getting a search warrant.
D. The OIC should examine the written identification and credentials of the CSHO and a written record should be made of his name, title and, if possible, the name of his superior. The OIC has the responsibility for requesting CSHO credentials (see Appendix C - Sample OSHA Inspector Credentials). The OIC shall request identification of any expert assistants accompanying a CSHO and, if they are not OSHA employees, a resume should be requested. The Legal Department should then be consulted to determine if any objection to their presence should be made of record.
E. If there is more than one CSHO, more than one OIC may be needed to accompany the CSHOs at all times. It is important that the CSHO be treated courteously and in a business-like manner at all times.
F. The OIC should determine the reason why the facility has been chosen for an inspection. The CSHO is required to explain the nature and purpose of the inspection under OSHA regulation 29 C.F.R. 1903.7(a). If he refuses to disclose why he wishes to inspect the facility, a search warrant should be requested by following the procedure set out in Part I of the Corporate OSHA Inspection Guidelines, para graphs L, M, and N, below and the Legal Department should be notified. Although CSHOs may inspect any factory, plant, establishment, or area where employees perform work, inspec tions are generally for one of the following reasons:
1. complaint.
An inspection resulting from an employee
The nature of the complaint should be speci fically identified. Section 8(f)(1) of the Act requires that a copy of the complaint be given to the employer, but the complainant is entitled to have his name withheld. If the CSHO refuses to give you a copy of the complaint, or if the com plaint relates to a part of the facilities where
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more than one employer is present, request a
search warrant by following the procedure set out in Part I of the Corporate OSHA Inspection Guide lines, paragraphs L, M, and N, below.
2. An inspection following a workplace fatality or accident causing the hospitalization of five or more employees.
The employer is required to report these incidents to OSHA within 48 hours after their occurrence and an inspection will be virtually certain to follow. The nature and location of the incident giving rise to the inspection should be specifically identified.
cited.
3. A follow-up inspection of an item previously
Such an inspection can be expected if the citation was for a serious, willful, or repeated violation or if an abatement plan has been agreed to by the company as the result of an earlier inspection. The previous citation and the item should be specifically identified by the CSHO.
4. A regional programmed or industry group classi fication inspection based upon injury and illness rates.
5. An investigation following a notification of significant release affecting the environment.
G. A multi-employer worksite poses special problems. An employer may be held liable for an OSHA violation on its premises even if it does not control or has not created the hazard. Hence, the OIC should treat an inspection of a multi-employer worksite in the same manner as an inspection directed solely at its company, and proceed in accordance with the Corporate Inspection OSHA Guidelines. Any con tractors on Conoco premises should notify the OIC of any inspection of contractors' equipment or work area.
H. The Legal Department should be notified immedi ately of any citations received if there is any pending OSHA litigation in which the company is presently involved or if the OSHA inspector seeks to conduct an inspection outside of regular working hours. Telephone one of the following
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persons in the order listed below:
Michele Malloy Home
ETN (713) (713)
Thomas D. Montgomery
ETN (713)
672-1101 965-1101 664-3517
672-1088 965-1088
I. If the purpose of the inspection is either (a) an inspection resulting from a specific employee complaint, (b) an inspection resulting from a report of a workplace fatality or accident causing the hospitalization of five or more employees, (c) a regional programmed inspection of the facility, (d) an inspection of an item previously cited which is not being contested in a pending case or (e) notifi cation of significant release affecting the environment, the CSHO should be permitted to commence his investigation. Although you have a right to insist on a search warrant for these types of inspections, generally as a matter of policy you should cooperate and not request a warrant. Except in the case of (c), the inspection should be limited, to the particular machine, equipment, or condition which is the subject of the complaint, accident, or prior citation.
J. Except in the case of I.(c), if it is determined according to paragraph I above that the inspection may proceed without a search warrant, the following written statement of limited consent should be mailed to the Area Director of OSHA during the first day of the inspection and a copy hand-delivered to the CSHO, prior to commencement of the inspection. (See letter #1 of Appendix B):
A Compliance Safety and Health Officer under your supervision has requested to inspect (specific area(s) referred to in the employee complaint, accident report or area(s) previously cited) of
(Plant), ("Conoco") on (date) . Conoco has complied with the request. The inspec tion, however, is with the consent of Conoco only as to the area(s) specified herein. Should the scope of the inspection exceed the area(s) speci fied herein, Conoco hereby reserves any and all of its rights to challenge the validity of the in spection, to seek the suppression and exclusion of any and all evidence obtained directly or indirectly as a result of the inspection, and to seek the dismissal of any citations issued as a result of the inspection on the grounds that the inspection
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violates the rights of Conoco under the United States Constitution and the Occupational Safety and Health Act of 1970.
The following statement should be orally read to the CSHO prior to commencement of the inspection:
Conoco has complied with your request to inspect (specific area(s) referred to in the employee complaint, accident report or area(s) previously cited). Should the scope of the inspection exceed the area(s) specified, Conoco reserves its rights to challenge the validity of the inspection and to seek dismissal of any citations issued as a result of the inspection.
K. If, after being admitted for the purpose of making a limited inspection, the CSHO attempts to broaden the scope of his inspection he should be asked to leave the work area and escorted back to the OIC's office. Do not forcibly stop the CSHO from inspecting any area since such action may result in criminal liability, but tell the CSHO the following:
In my opinion you are attempting to broaden the scope of this inspection. That violates the original conditions of this inspection and I am terminating this inspection in order to seek legal counsel.
L. If the purpose of the inspection is either (a) an inspection pursuant to a general employee complaint that does not allege specific violations or (b) an inspection of an item previously cited which is being contested in a pending case, the CSHO should be required to get a warrant. The following statement should be orally read to the CSHO:
It is the continuing policy of Conoco to offer its complete cooperation to any governmental agency seeking to lawfully enforce federal, state or local laws or regulations. On the other hand, it is equally important to Conoco that such laws and regulations and the enforcement thereof be within the safeguards of the United States Consti tution. We have been advised by our legal counsel that the United States Supreme Court has held in Marshall v. Barlow's, Inc., 436 U.S. 307 (1978), that inspections of a company's facilities, without
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the employer's consent, are unconstitutional in
the absence of a valid search warrant. In view the Barlow's decision and in view of Conoco's desire not to waive its Fourth Amendment rights under the United States Constitution, we are refusing to admit you to our plant.
of
M. If admission of the CSHO has been refused pursuant to paragraph L above, telephone the Area Director of OSHA, whose telephone number can be obtained from the CSHO, and explain that as a courtesy you are calling him to explain the company's position. Thereafter, read the OSHA Area Director the same statement and read to the CSHO (See Part I, paragraph K) and mail the Area Director a letter setting
N. Also, after admission of the CSHO has been refused, the employee representative(s) should be immediately advised of the company's position.
O. Notify the Legal Department of actions taken.
II. PRESENTATION OF A WARRANT
A. If the CSHO presents a search warrant, ask to see the warrant. Read the search warrant carefully, especially noting the specific machine, equipment, or condition to be inspected. Copy the contents of the search warrant.
B. Immediately call the Legal Department and the Department Safety Director (See Part I, paragraph H). Again, the CSHO should be advised you are calling your lawyer.
C. The following written statement of protest should be mailed to the Area Director of OSHA during the first day of the inspection and a copy hand-delivered to the CSHO, prior to commencement of the inspection (See letter #3 of Appendix B):
A Compliance Safety and Health Officer under your supervision presented a search warrant and requested to inspect Conoco premises on (date). Conoco has complied with the request. The inspec tion, however, is totally without the consent of Conoco and it is permitting the Compliance Safety and Health Officer to enter its premises under a general protest. [A specific protest may be made at this point depending upon the particular facts
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involved in any given inspection. Such optional language, which should be inserted only with the advice of legal counsel, begins as follows: "Without in any way limiting the foregoing general protest, Conoco specifically protests . . . "] Conoco hereby reserves any and all of its rights to challenge the validity of the inspection, to seek the suppression and exclusion of any and all evidence obtained directly or indirectly as a result of the inspection, and to seek the dismissal of any citations issued as a result of the inspec tion on the grounds that the inspection violates its rights under the United States Constitution and the Occupational Safety and Health Act of 1970.
The following statement should be orally read to the CSHO prior to commencement of the inspection:
Although Conoco has complied with your request to inspect its premises, the inspection is totally without its consent. Conoco is permitting you to enter its premises under a general protest, and it reserves its rights to challenge the validity of the inspection and to seek dismissal of any cita tions issued as a result of the inspection.
D. Allow the CSHO to enter. Refusal of entry may result in criminal liability or a contempt of court charge.
III. OPENING CONFERENCE
A. During the opening conference the CSHO may request to examine records that the company is required to keep under the Act, such as OSHA Form 200 (Inquiry and Illness Records), vinyl chloride monitoring, welding equipment inspections, etc. No other records should be provided on request or volunteered without first securing Legal Department approval. CSHOs may not examine personally identifiable employee medical information, except for the sole purpose of verifying employer compliance with OSHA medical record keeping requirements, without first obtaining a written access order approved by the Assistant Secretary of Labor or specific written consent of the employee. 29 C.F.R. 1913.20.
B. OSHA has previously supplied the company with notices informing employees of their protections under the Act, and the CSHO may check to see that such notices are
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posted in conspicuous places where employee notices are usually posted. Since the notice informs employees that they may contact their employer for copies of the Act, regulations and specific safety and health standards, the OIC should have a copy of the Act, regulations and standards readily available.
C. The following statement should be orally read to the CSHO during the opening conference:
Conoco has a number of highly confidential products and processes. We will attempt to iden tify these as the inspection proceeds and once identified, we expect OSHA to treat them confiden tially pursuant to OSHA rules and regulations. In the event we overlook a confidential product or process during the inspection, Conoco reserves the right to bring these to OSHA1s attention at a later date with the expectation that OSHA will treat them with confidentiality.
D. The OIC shall take the necessary steps to be sure that the CSHO complies with all company safety and health rules and practices at the facility and that he correctly wears and uses the appropriate protective clothing and equipment.
E. The OIC should request that the CSHO resolve any issues as to how the inspection is to be conducted prior to starting the inspection.
IV. CONDUCT OF THE INSPECTION
A. The OIC should bring along the following items on the inspection tour:
1. Corporate OSHA Inspection Guidelines.
2. Corporate OSHA Inspection Form to be filled out for the Legal Department. (Appendix A)
3. Note pad. (Do NOT show any notes written prior to, during, or after the inspection to the CSHO under any circumstances. They need not be hidden. They simply should not be made available for inspection or review.)
4. Pre-selected camera and flash equipment. The camera should take good quality photographs and be readily available at all times. Since ordinary flash equipment cannot be used safely in certain flammable atmospheres, the
VVc 000009562 8
flash equipment must be carefully selected so that its use does not violate any OSHA standards.
B. Allow the CSHO to conduct his inspection of the equipment or condition specifically mentioned in the search warrant, employee complaint, accident report, or prior cita tion. Section 8(e) of the Act gives walk-around rights, i.e. , the right to accompany the CSHO during the inspection, to both a management representative and an employee representative.
The management representative should be an OIC or alternate and should accompany the CSHO on the inspection tour. If there are more than two CSHOs, additional manage ment representatives should be considered. Separation of the CSHOs should not be permitted.
C. The OIC should take detailed written notes of all remarks and questions asked by the CSHO. Describe the "appropriate route" the CSHO takes through the plant in these notes (See Part I, paragraph B). The OIC SHALL NOT:
answer questions posed by the CSHO or expert assistants requiring more than a short response; or
provide access to management for CSHO's or expert assistants' interview purposes; or
volunteer information.
D. The OIC should photograph every condition photo graphed by the CSHO. The CSHO should contact the Legal Department if the CSHO attempts to take pictures of pro prietary processes or equipment. Note the type of camera, flash equipment and any special attachments used by the CSHO. At the conclusion of the inspection, request copies all photographs taken by the CSHO.
of
E. The OIC should measure, sample and observe whatever conditions the CSHO measures, samples and observes. Any variances between the monitoring results reached by the OIC during concurrent monitoring and those recorded by the CSHO should be immediately brought to the CSHO's attention and described in written notes provided, of course, the results of the OICs are more favorable to the company. Also, de scribe in detailed written notes the type of monitoring equipment and the monitoring procedure used by the CSHO.
9 VVC 000009563
F. If a CSHO seeks to attach a monitoring or sampling device to an employee, the OIC should ask the CSHO to stop his inspection so that the OIC can call his lawyer. The Legal Department should be notified immediately. (See Part I, paragraph H)
G. The CSHO has the right to confer privately with employees under Section 8(a)(2) of the Act, so long as that right is exercised in a reasonable manner. Although the OIC does not have an absolute right to be present during a conversation between the OIC and an employee, he should request to be present. The names of any employees who had private conversations with the OIC should be recorded. If the CSHO would like to talk privately with an individual employee who cannot reasonably be allowed to leave his work station at that time, the CSHO should be informed of this and told that the employee will be made available as soon as possible. NOTE: It is a violation of the law to retaliate against any employee who cooperates with an CSHO.
H. The OIC should not volunteer information or docu ments, or offer additional areas for inspection. Statements made by the OIC could be used as admissions against the company in a subsequent OSHA hearing. The company has the right to have a lawyer present during extensive questioning.
V. TRADE SECRETS
A. Section 15 of the Act requires OSHA to treat any trade secret in confidence. The OIC should know in advance any areas which contain or might reveal a trade secret. Any information obtained by the CSHO in such areas, including all photographs and samples, should be labeled "confidential trade secret". 29 C.F.R. 1903.9.
-
B. If the CSHO requests to inspect any areas which contain or might reveal a trade secret, the following written statement should be mailed to the OSHA Area Director during the first day of the inspection. (See letter #4 of Appendix B). A copy of the statement should be hand-delivered and orally read to the CSHO prior to inspecting any areas which contain or might reveal a trade secret:
A Compliance Safety and Health Officer under your supervision has requested to inspect (specific areas which contain or might reveal a trade secret) of Conoco on (date). Since the described areas contain or might reveal a trade secret, we are
VVC 000009564 10
requesting that any information obtained by the Compliance Safety and Health Officer in such areas, including all photographs and samples, be labeled "confidential - trade secret", and we trust that OSHA will treat them confidentially pursuant to OSHA rules and regulations. In the event we have overlooked a confidential product or process during the present inspection, Conoco reserves the right to bring these to OSHA's atten tion at a later date with the expectation that OSHA will treat them with confidentiality.
VI. CLOSING CONFERENCE
A. The primary purpose of the OIC in the closing conference shall be to LISTEN; however, the CSHO should be questioned as to all areas of possible and probable viola tions. If the CSHO indicates that a citation will be issued, he should be questioned specifically as to what constitutes abatement, as an alleged violation cannot be established unless OSHA proves not only what constitutes abatement, but both the feasibility and likely utility thereof. This should give the OIC a good reading as to those items that a citation will contain. Also, it will enable the company to take evidence and begin preparing our case while the evi dence is still "fresh". Often, citations are not received for days or even weeks.
B. A request should be made for copies of all photo graphs taken by the CSHO during the inspection as well as all samples and results.
C. Immediately following the conference, the informa tion received in the closing conference should be relayed to the Legal Department. (See Part I, paragraph H).
VII. FOLLOWING THE INSPECTION
A. The OIC should complete the Corporate OSHA Inspec tion Form (Appendix A). The Corporate OSHA Inspection Form and any notes taken during the inspection should be mailed promptly to:
Michele Malloy Conoco Legal Department Suite 1630 P. O. Box 2197 Houston, Texas 77001
VVC 000009565 11
One copy of the Corporate OSHA Inspection Form and any notes
taken during the inspection should be kept confidentially until notified of receipt of the originals by the Corporate Legal Department or Corporate Legal Counsel. Such copy should then be destroyed. Under no circumstances should the Corporate OSHA Inspection Form or any notes be shown or given to the CSHO.
B. All applicable letters to the OSHA Area Director (Appendix B) should be mailed during the first day of the inspection in accordance with the following provisions of the Corporate OSHA Inspection Guidelines:
Limited consent to inspection Insistence on a warrant Inspection under protest Trade secrets
Part I, paragraph J Part I, paragraph L Part II, paragraph C Part III, paragraph C
One copy of each letter mailed to the Area Director of OSHA should be mailed simultaneously to the attorney designated above.
421a
VVC 000009566 12
APPENDIX A CORPORATE OSHA INSPECTION FORM
In anticipation that this inspection could lead to legal proceedings, you are to fill out this form during every OSHA inspection to assist our company lawyers in protecting the company's rights during any hearings, trials, or other legal proceedings which might arise as a result of this inspection.
For further explanation, see the applicable provisions of the Corporate OSHA Inspection Guidelines set out in parentheses. Please attach additional pages when needed to complete any question(s) and copies of the requested documents.
1. OSHA Inspection Coordinator (OIC):
Name
2. Date of Inspection:
3. Identity of OSHA Inspector (CSHO): _________________ Name
4. OSHA Area Director: ___________________ Name
Title Telephone No.
Address
5. Answer one of the following:
A. Did OSHA receive an employee complaint? (Part I, F.l) ____
If so, describe the nature of the complaint, the machine, equipment or condition it specifically relates to, and the type of problem it involves:
Attach a copy of the complaint to this form.
1 vvc 000009567
S
B. Has there been a workplace fatality? (Part I, F.2) If so, describe the nature and location of the incident which resulted in the fatality:________________
Attach a copy of the report supplied to OSHA within 48 hours of the incident. C. Has there been an accident which resulted in the hos pitalization of five or more employees? (Part I, F.2)
If so, describe the nature and location of the accident and the resulting injuries:
Attach a copy of the report supplied to OSHA within 48 hours of the accident.
D. Is this a follow-up inspection of an item previously cited? (Part I, F.3)
If so, identify the previous citation, proposed penalty and abatement plan, if any:
Attach a copy of the previous citation and the CSHO's worksheets relating to the citation, if available.
-2-
00009568 VVC 0
E. Is this a regional programmed inspection? (Part I, F.4)
If so, describe the inspection program and the criteria used to select this particular facility for inspection:
F. Is this an inspection following a notification of significant release? (Part I, F.5)
6. Is this an inspection of a multi-employer worksite? (Part I, G) If the contractors were involved in any way in the in spection, list the names of all other employers and the number of workers employed by each employer who are present on the worksite, with a brief description of the nature of the work being performed:
7, Is there any pending OSHA litigation in which the company is presently involved? (Part I, H) __
8. Did the CSHO seek to conduct the inspection outside of regular working hours? (Part I, I) ___
If so, state time of requested inspection and regular working hours:
If so, was the Legal Department notified?
Name of Lawyer notified ____________________________
Title and date of notification
_____ ___
3
Vvc 00009569
9. If no search warrant was presented, did you consent to a limited inspection? (Part I, J)
A. If so, did you read an oral statement of limited consent to the OSHA inspector? (Part I, J) ________
B. Describe the specific machine, equipment or con dition you permitted the CSHO to inspect in your oral statement of limited consent:
C. If so, did you hand-deliver a copy of a letter of limited consent addressed to the OSHA Area Director to the CSHO? (Letter #1 of Appendix B)
Time and date letter was delivered ___
Attach a copy of the letter of limited consent which was mailed to the OSHA Area Director during the first day of the inspection.
D. Did the CSHO attempt to broaden the scope of the in spection after being admitted for the purpose of making a limited inspection? (Part I, K)
If so, describe the machines, equipment or conditions which you refused to allow the CSHO to inspect and the reason(s) given for such refusal:
If so, did you contact the Legal Department before objecting to the inspection? ___________________________________
Name of Lawyer notified ___________________________________________
Time and date of notification
___________
-4-
vvc 000009570
..a
10,
If no search warrant was presented, did you refuse the CSHO entry? (Part I, L)
A. If so, did you read an oral statement to the CSHO explaining the company's position? (Part I, L) ______
Time and date oral statement read
B. If so, did you telephone the OSHA Area Director and explain the company's position? (Part I, M)
Time and date of notification
Attach a copy of the letter explaining the company's position which was mailed to the OSHA Area Director. (Letter #2 of Appendix B)
C. If so, did you advise employee representative(s) of the company's position? (Part I, N)
Name of employee representative(s) notified
Time and date of notification
11.
Did the CSHO present a search warrant upon arrival? (Part II)
A. If so, describe the contents of the search warrant and the specific machine, equipment, or condition to be inspected:
Attach a copy of the search warrant if it was given to you.
B. If so, was the Legal Department notified? (Part II, B)
Name of Lawyer notified
Time and date of notification
-5-
0000
C. If so, did you read an oral statement of protest to the CSHO? (Part II, C)
Time and date oral statement read
D. If possible, did you hand-deliver a copy of a letter of protest addressed to the OSHA Area Director to the CSHO? (Letter #3 of Appendix B)
Time and date letter was delivered
Attach a copy of the letter of protest which was mailed to the OSHA Area Director during the first day of the inspection.
E. If so, did you permit the CSHO to enter?
12.
List any records, documents or notices reviewed by the CSHO (Part I, A and B):
13.
Describe in detail any remarks made during the opening conference, including any oral statements made to the CSHO regarding confidential products and processes. (Part III):
000009572 vvc
6
State the names and titles of management representatives who accompanied the CSHO during the inspection tour (Part IV, B):
State the names and titles of employee representatives who accompanied the CSHO during the inspection tour (Part IV, B):
In the case of a limited inspection, describe the route taken by the OSHA inspector during the inspection tour (Part IV, C) : ____________________________________________________________________
Describe in detail any particularly significant remarks made during the inspection by the CSHO or any employees and identify the speaker (Part IV, C):
7
0000^573 VVC 0
18.
Identify any photographs taken by the CSHO, including location, time of day, date, and the names of any employees in the photograph (Part IV, D)s
A. Describe the type of camera, flash equipment and any special attachments used by the CSHO:
B. Did you request copies of the photographs taken by the CSHO?
19.
Identify any photographs taken by a management repre sentative, including photographer, location, time of day, date, and the names of any employees in the photo graph (Part IV, D):
A. Describe the type of camera, flash equipment and any special attachments used by a management repre sentative:
20.
Describe any monitoring conducted by the CSHO, including the equipment used, monitoring procedure, time of day, date, and the results of such monitoring, if known (Part IV, E):
VVC 000009574
8
aa
21.
Describe any monitoring conducted by a management representative, including the equipment used, moni toring procedure, time of day, date, results and any variances between results of monitoring conducted by the CSHO and management. Indicate which monitoring, if any, was conducted concurrently with the CSHO's monitoring (Part IV, E):
22. Did any CSHO seek to attach a monitoring or sampling device to an employee? (Part IV, F)
If so, was the Legal Department notified? _____________
Name of Lawyer notified
Time and date of notification
23.
List the names of any employees interviewed by the CSHO and state whether a management representative was present during the interview. If a management representative was present, state his/her name and a summary of the interview (Part IV, G):
-9-
VVC 000009575
24.
Describe any area(s) identified as containing or possibly revealing a trade secret (Part V):
A. Did you read an oral statement identifying such area(s) to the CSHO? (Part V, B)
Time and date oral statement read __
B. Did you hand-deliver a copy of a letter identifying trade secrets addressed to the OSHA Area Director to the CSHO? (Letter #4 of Appendix B)
Time and date oral statement read
Attach a copy of the letter identifying trade secrets which was mailed to the OSHA Area Director during the first day of the inspection.
C. List any materials, such as photographs and samples, which were labeled "confidential-trade secret" (Part V, A):
25.
If the closing conference was held at the end of the in spection, attach a detailed description of any remarks made during the closing conference and identify the speaker. If the conference is held at a later date, forward the closing conference summary to the Legal Department as soon as it is concluded (Part VI)
vvc 000009576
10
26.
This form, additional pages needed to complete this form, copies of requested documents, and any notes taken during the inspection should be mailed to:
Michele Malloy Conoco Legal Department P. 0. Box 2197 Suite 1630 Houston, Texas 77001
One copy should be kept confidentially until notified of receipt of the originals by the Legal Department. Any subsequent distribution will be solely handled by the attorney designated above.
- 11 -
QOOO09577
APPENDIX B LETTERS TO BE MAILED TO THE OSHA AREA DIRECTOR
Letter #1 Letter #2 Letter #3 Letter #4
-- Limited Consent to Inspection
- Insistence on a Warrant - Inspection Under Protect
_ Trade Secrets
VVC 000009573
LETTER #1
Area Director Occupational Safety and Health Administration
U. S. Department of Labor
Dear
A Compliance Safety and Health Officer under your super
vision has requested to inspect (specific area(s) referred
to in the employee complaint, accident report or area(s)
previously cited) (plant)
("Conoco") on
(date)
Conoco has complied with the request. The inspection,
however, is with the consent of Conoco only as to the
area(s) specified herein. Should the scope of the inspec
tion exceed the area(s) specified herein, Conoco hereby
reserves any and all of its rights to challenge the
validity of the inspection, to seek the supression and
exclusion of any and all evidence obtained directly or
indirectly as a result of the inspection, and to seek
dismissal of any citations issued as a result of the
inspection, on the grounds that the inspection violates
the rights of Conoco under the United States Constitution
and the Occupational Safety and Health Act of 1970.
A copy of this letter was hand-delivered to the Com pliance Officer before he began the inspection.
Very truly yours.
Vvc 00000957,
Letter #2
Area Director Occupational Safety and Health Administration U. S. Department of Labor
Dear
The following statement was read today to a Compliance Safety and Health Officer under your supervision:
It is the continuing policy of the
(plant)
("Conoco") to offer its complete cooperation to any
governmental agency seeking to lawfully enforce fed
eral, state or local laws or regulations. On the other
hand, it is equally important to Conoco that such laws
and regulations and the enforcement thereof be within
the safeguards of the United States Constitution. We
have been advised by our legal counsel that the United
States Supreme Court has held in Marshall v. Barlow's,
Inc., 436 U.S. 307 (1978), that inspections of a com
pany's facilities, without the employer's consent, are
unconstitutional in the absence of a valid search
warrant. In view of the Barlow1s decision and in view
of Conoco's desire not to waive its Fourth Amendment
rights under the United States Constitution, we are
refusing to admit you to our plant.
Very truly yours,
VVC 000009580
Letter #3
Area Director
Occupational Safety and Health Administration
U.S. Department of Labor
Dear A Compliance Safety and Health Officer under your
supervision presented a search warrant and requested to inspect (plant)_________ ("Conoco") premises on (date) Conoco has complied with the request. The inspection, however, is totally without the consent of Conoco and it is permitting the Compliance Safety and Health Officer to enter its premises under a general protest. [A specific protest may be made at this point depending upon the parti cular facts involved in any given inspection. Such optional language, which should be inserted only with the advise of legal counsel, begins as follows: "Without in any way limiting the foregoing general protest, Conoco specifically protests...".] Conoco hereby reserves any and all of its rights to challenge the validity of the inspection, to seek the suppression and exclusion of any and all evidence obtained directly or indirectly as a result of the inspection, and to seek the dismissal of any citations issued as a result of the inspection on the grounds that the inspection violates its rights under the United States Constitution and the Occupational Safety and Health Act of 1970.
A copy of this letter was hand-delivered to the Compli ance Officer before he began the inspection.
Very truly yours,
VVC 000009581
Letter #4
Area Director Occupational Safety and Health Administration U.S. Department of Labor
Dear
A Compliance Safety and Health Officer under your
supervision has requested to inspect
(specific areas
which contain or might reveal a trade secret)
of
(plant) ("Conoco") on (date)
Since the described
areas contain or might reveal a trade secret, we are re
questing that any information obtained by the Compliance
Safety and Health Officer in such areas, including all
photographs and samples, be labeled "confidential - trade
secret," and we trust that OSHA will treat them confiden
tially pursuant to OSHA rules and regulations. In the event
we have overlooked a confidential product or process during
the present inspection, Conoco reserves the right to bring
these to OSHA's attention at a later date with the expection
that OSHA will treat them with confidentiality.
A copy of this letter was hand-delivered to the Compli ance Officer before he began inspecting areas which contain or might reveal a trade secret.
Very truly yours.
ooo958Z
Sample OSHA Inspector Credentials
Appendix C
PiniouStg
Jiparimen! o! ^GaBor JBaalpngfpn, JL C.
This is to certi
. LESLIE
whose signs ^Nhereon has
W COMPL
United Stat \> authorized X duties of 4 N^abor.
as such is perform the Secretary of
/,WV~
Auistont StcTtlaiyef Lsbor
5720
vvc 000009583
^ pp cl r> d ,* i
Occupational Sa'eiy and Health Administration Complaint
U.S. Oepertment of Labor
Th* form it proidob to' (ft* eueetAce a/ any comp(f"w end n not intended *p cenrrrlvre (ft* mciuov* mmm by which compAeinr mar bo renrratf _rft me V S Oapermenr o'teAer
f om Approved n ti a kin ruia luo O M B No OA*n*MW
Sc SKI (11 d( the w>iii*irx Steqer Occvpeiionei Se*ety end Heath Act. 30 U.S.C 651. provide! at 'o'lowi Any employee! or re*e"t#1ive o' employee! vfto b*iwv tr>ai a volition o' a te'ety or naan* Mengero ensti iftai imeetem oiyiioi narm. o> in*i an immmeni danger *nii nxy 'aouni an inspection by giving notice to me Secretary or tut authorize* reoreeaniaiiva o' iuch viol*non or dinger Any uch noi<* mu H reduced to wrung. n*n iat forth with raetonao'e oartmjlar u y tne ground! (or the noire* and Mil be signed by the employee! o* representative o' employee! ana a copy mu be providad (he employer o' htl agent no later than ai the time el impact >on. aaceot that, upon requeit o' the oerion giving Kicn relief, nit name and tha nemai o* individual employee* referred to therein MU not aOCX*' in tuelt copy or on any record pubUMd. rfleeted 0' made lyeiiebit pu'tuant to lubacnon igl o' this weten It upon receipt o' iuch noti'mtion the Secretary deter mine* there are <ea*oneQie ground! to believe that *ucn violation o' danger t>i>H. he tnati make a ceciei imoecnon m accordance with the provnem o' thrt aeciton a* non at practicable, to determine tuch violation or danger eaill K the Scretary determine! there are no raaionabW ground to believe that a violation o< Oangc eaiirt ne MU noti'v tne employee* o' rxewntat.v o' the employee! in writing o' tuch determination
NOTE: Section 11 (cl 0< tne Act prmOBenplicil protection fo< emptoveM eiercrtirg their right!, Including making iffety and haeilh complaint*
for OHkt* Um Only
Area
Date Received
Tima
Tl>* undamgnad (Me* one'
Region
Racewad fly
Formal
0
Non Formal 0
D Enokryae
Rapraentftwe of Employee*
O Othw
bauevei that violation at the following place o' employmam o' an occutationpl **(*tv dt halth ttandard niri which job Employs'* Name
or health hocem
Employer'! Aztd<a* ttra/
/Crty;
tSmrol
tfrpCMfJ
Telephone
1. Kind o' bunnaaa
2. Speei'y the particular building or worketa whore theallaged vioWnon located, inciudug addrew
3. Speerly the neme ire) phone number ai amoloyar't agent 1*1 in charge 4. CXtcribe brafiy tha hazard which eaitu there including tha *cproimet* nuntjar o' empioveat expoaad to or threetanad by tueh hazard.
(
OSMA 7 (flrv October IB771
continuciTon reverse SiDE
VVC 000009584
U1 DEPARTMENT OP LAAOR OCCUPATIONAL SAFETY ANO HEALTH ADMINISTRATION
). Employ*' Noma: 4. Typ* Ol Lagal Entity
NARRATIVE 5 Typa Of Butina* Or Pant
i. aHO No.
2. Aaeon No.
6 NAMES AND AODRESSES OP ALL ORGANIZED EMPLOYEE GROUPS
Noma Local No. Addrm
Noftw Local No. Aaaf--
Tala. No. Zip Coda To*. No. Zip Coda
7 AUTHORIZED REPRESENTATIVES OF EMPLOYEES TiH No.
OfMn,<ation
Tita
Hama AddrHt
Z Coda
Ntma Oi^ntastion Homo Addraa*
Taa. No. Tita
Zip Coot
w A V
N
Y
N
S. EMPLOYER REPRESEN TATIVES CONTACTED
Noma
1 Tula
evprm
C ' GtOT^C*m' Ml Function
10. COVERAGE INFORMATION
W A S. OTHER PERSONS CONTACTED
Nana. Occupation A Affiliation
Y
D Homo AdtPaa
V Y
Mama. Oecupation A Affiliation
Y Nona Addro*
Nama. Occupation A Affiliation Hema Adprgtt
Taa. No. Zip Coda
Taa. No. Zp Coda
Taa. No. Z Coda
11. Dot* Tima of Entry:
12. Data A Tima Waltaround Atgtn.
IS. EVALUATION OP SAFETY AND HEALTH PROGRAM ICodil
12. Data A Tima CtoimgConltranoa Sagan: (1) (21
14. Data A Tima e< E*it
0 Nonnimnt t * Inadaquatt 2Ai*ryg* 3 Afceva AnoragtI
Compr*hyntian**ao1 Safety A Haattfi Pro^am
01 22
HaaHh Monitoring Program HatM?
0
Copy En<tod?
Y
Cwimuniatitn of Program to Etabyat
N
Si'tiv Mviirnoi
0 23
Madiegl Program* Fraouancv? Aaant? Extant? ContaniT
0
IvWtomr Enlorcamant
0 22
Sa'aty Training Program hfcaKh Training Program
SafaiyStalf
Y
HaaPP Staff
Y
Aceidantflniiifv Inyaatipafioni Performad
N
0 23 0 23
01 23
Hazard Control - Enginaaring A Admcwnration -- Panonal Protactno Eguipmani - Ragulatad Araat - Emargancv Procadma
0 0 0 0
Raaardf too - 101 - 102 - SutMNmantary HaaRti
If SH. Modify
Noticato Emptoyaot IPoatar)
YN
Pravantativi Action Taka* Y
1A. FOLLOW-UP INSPECTION RECOMMENDED: Vat No Rotton:
23 22
23 23 23
IT. CSHO Sg#<u<t A D*t#
IE. Acaompofiiod Ey
vvc 000009585
Farm OSMA-1A
m/ni
1 CSHO No 9. Ham No lit SAVE ID CM*
3 RPOOtt No.
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION US DEPARTMENT OF LAROR
WORKSHEET
3. Daia/Timc
4a Tvm
4b. Nuanbar
Inaianc*
7. SlaMaro All*9*dly ViOlataO
| B. Abatamani Rattod
Tim Rf No
b. AVO/VatiaM* Infonnition:
0*
/ 9 No. of IfMt. 10 BEC
12 INSTANCE DESCRIPTION la HaJ*dOor /Cond.'Acc: b. Eovip.c LocatMft;and d lnjw>v>IH-)
Corn'd
19. EMPLOYER KNOWLEDGE IS. COMMENTS lEirioloyar. Employ--. Ootinp Coni. I
IT OTHER EMPLOYER INFORMATION
Cont'd
18 CLASSIFY
..,,r *!
\ a. Ptob.of IniuryflU.
< X
No. Cal. Davi Uncan.
&
*
b G'avirv-ftaMd Fanaitv
c. Tima* Bap--'ad/ O--r-- Of Willful
1iS.a
d. Adtuatmeot FactOft 31 Good Faith 3) Hittory
41 Total
a. Propoiad Arfi--fad Fanafiv
Form OSHA'16
VVC 0000095