Document Zn9jeenzd9B3ex2pGqMgNJn7
CU*wvmww E. I. du Pont dc Nemours & Company
WC>WWIl>tO
. Wilmington, Delaware 19898
INDUSTRIAL CHEMICALS DEPARTMENT
Wt W. {!. Kelso
L. D. Greenberg R. S. Wannelin T.-T. Chase C. C. Quarles R. . Jackson, SabinePlant N. R. Uallner,Houston Plant G. A. Cato, Belle Plant
August 8, 1973
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A. W. BEASLEY, AUGUSTA PLANT
C_ _E. WATKINS, BEAUMONT PLANT
H. A. ROSCOS, BURNSIDE PLANT
R. J. MC AULIFFE, CLEVELAND PLANT
H. S. BOYLE, DELAWARE RIVER PLANT
V. G. KOPPIN, EAST CHICAGO PLANT
W. F. 3RINT, FORT HILL FLANT
E. C. BELL, FCRTVILLE PLANT
R. D. TURNER, GRASSELLI PLANT
R. P. ALLEN, HEALING SPRINGS PLANT
A. SINNICKSOK, JAMES RIVER PLANT
D. A. DUNCAN, MARATNON PLANT
W. E. ELTING, MEMPHIS PLANT
J. M. LOaTKER, NIAGARA FALLS PLANT
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S. HYDE, PINZVILLE PLAINT
R. W. BAYRER, REPAUHO PLANT
L. A. BIDE2, TOLEDO PLANT G.. I*i#. ^>rT?T.TT*./Are;T Tw.T-LT-TuTxj-^vi -m.uA/tiirxrifv Tf^*jP^fmt*Tmu
R. J. ROUSII, VrURTLAHD PLAINT
OSHA ITEMS
Attached are several items of interest in connection with
OSHA:. (1) Excerpts from the minutes of the latest Departmental'.
Coordinators Meetina. (2) A coDy of a revised form intended
for reporting on OSHA or NIOSII visits to S & F. Please review
and send mp any comments you jni^ht have.
A. chronolorr,r of
events with respect to a Repauno OSHA visi""' " ........... ~0*'
121!! slab Attach.
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DUP 1000077
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EXCERPTS FROM MINUTES OF DEPARTMENTAL OSIIA COORDINATORS MEETING
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7/31/73
NIOSH - Contract Contacts
If our units arc contacted by a contractor holding a NIOSH con
tract to prepare a criteria document, we should cooperate if we have an interest in the subject. Such contacts should be han
dled as if the contractor were NIOSH. If, however, the contrac tor desires to visit a Du Pont site to take readings, etc., we are not legally obligated to permit this. If we have an interest, we should cooperate; nowe\er, .it is suggested th?.t cite manage
ment be given an opportunity to view the NIOSH contract in either of the above cases. Copies (2) of any material given to a NIOSH contractor.should .be forwarded to the Safety & Fire'Protection Division. Our Division will forward one.copy to NIOSH.
Houston OSHA Inspection
A complaint to OSHA on the part of the Engineering Department .Con
struction Division contractor's employee .prompted several visits
to the Site. The OSHA compliance office made his contacts- with
plant management instead of the Resident Field Project Manager.
All departments are urged to follow proper communication channels
and, in this matter, the compliance officer should have been re
ferred to the Field Project Manager. On this inspection, the
compliance officer requested that he be permitted to tape his _
conversation with employees. Good judgment should be exercised
when this request is mace. It is conceivable that a compliance
officer would use a tape recorder to record his observations; -
however, unless good judgment indicated otherwise, we should not
Oermit on-dant +.a.rnner of Du Pnnt Pimlnveos.
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Form 103
Paragraph V(2) of this form requires entering the principal products manufactured and the approximate percentage of the annual value of such products. It has been normal plant practice to merely indicate, for example, organic chemicals--1*000. The __ Beaumont Plant was recently requested for a more detailed break down. The Plant complied as follows:
Elastomer Chemicals 55*5
Industrial Chemicals 400
Organic Chemicals
55S
This answer was accepted and the lesson learned if a'similar re
quest is received by another site, it is not necessary to get very detailed.
DUP 1000078
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Status of Noise Standard
The DOL Noise Committee continues to meet.' Current indication is that the 90 asi.\ will remain as the standard until the Sataloff Study is.complete.
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DUP 1000079
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RCPAUNO OSHA VISIT AND FOLLOW-UP
CHRONOLOGY ' May 29 30
June 4 June 11
Rcpauno Plant visited by Walter E. Wilson,
Federal Compliance Officer, in response to a complaint filed by the Union "Safety and Health Officer".
Wilson expressed concern about following:
"1') Failure to require respirators for asbestos insulation removal
. work.
2) Failure to use blotter on port- able air grinder.
~
3^ Adequacy of DMT oxidizer barri
cade design for protection of
workers in bays adjacent to
operating bays,'
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4) Possible excessive noise expo sures in some plant areas.
- SO "Possible dust exposures in some plant areas.
60 Failure to use shields to pro tect passersby and adjacent workers from welding arc flash
in boiler shop.
Meeting at Rcpauno to prepare strategy, for supplying information on areas of concern.
Plant received letter from Area Director re questing additional data as follows:
` - Design basis for DMT barricades.
- Medical records of Pete Miskofsky
(employee interviewed by compliance officer).
Reply requested by June IS..
DUP 1000080
June 13
June 14 June 19 June 20
* June 28 July 2
- C. P.. Baker and A. C. Matteson from riant _ staff visited Wilson in his office in Trenton, New Jersey, to discuss the follow ing items:
Plant policy of using safety
'
glasses
protect against
welders arc flash injury to
those near welding work.
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.*
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Plant asbestos monitoring program.
DMT barricade design.
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- Medical records for Miskofslcy.
- Reply to Area Director mailed.
- Meeting of Legal, Safety g Fire Protection, Engineering, and Industrial Chemicals to
discuss information to be provided on DMT
:i barricade design.
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4
- C. E. Baker called Area Director and learned:
-- - Wilson was no longer involved.
OSHA accepted our approach on .asbestos monitoring but would want to take some asbestos - dust samples.
^
- A tentative citation on DMT
barricades had been sent to area solicitor for legal opinion.
A citation will be issued on - failure to provide welding
screens or appropriate goggles . to protect against welders
flash. "
- Letter on DMT barricade design sent to Area Director.
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- Industrial Hygienist Rufolo.and Compliance Officer Moore visited Plant to make dust and noise measurements.
DUP 1000081
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July 11
July 12
July 17 July 17 July 19 July 23 July 23 July 27
Notice of proposed penalty for citations received by Plant. Plant called Area Director to learn nature of citations.
They were told:
- ' Citations were in the mail.
DMT barricade matter would be dropped. *'
Plant received citations for three alleged violations:
. 1) *
Failure to provide welding screens or shields to protect
.workers adjacent to welding areas.
2) Failure to provide blotter or
other compressible material between wheel and flange on .air grinder.
. 2jJ
*4
Failure to give affected employces reasonable opportunity to observe monitoring and see records of asbestos surveys.
.Meeting of `Employee delations, legal, 'Engineer
ing, and Industrial Chemicals Department person
nel to discuss strategy on welding screen citation,
Industrial Hygienist returned to Plant to sample at those operations which were shut down during his July 2 visit.
Letter indicating action on citations 2 and 3 sent to Area Director.
Meeting of Legal, Safety 5 Fire Protection, ' and Industrial Chemicals Department personnel
held to review strategy on welding screen citation.
Notice of Contest and request for informal conference sent. Copies attached.
Telephone call from Barden, Assistant Regional Administrator, to DcRicmcr advised us the citation on welding screens would l*c vacated.
DUP 1000082
July 27 July 30
Letter sent to Area Director withdrawing notice of contest. Copy attached.
- Plant received amended citation vacating item on welding screens.
STATUS
The only open item at this date is the disposition of dust sample taken in Nitrite and Diamond areas. Indication is that no violation "-exists -and no -action is Tteed-tni.
DUP 1000083
CONCLUSIONS FRQM THE INSPECTION
1. Cooperative attitude is important.
2. Work informally with OSHA personnel when ever possible. Phone conversations and visits were very beneficial.
3. Higher organization levels in OSHA were more willing to reason and interpret the standards.
7/31/73
DUP 1000084
REPORT ON OSHA-llEW VISIT
1. Date of Visit>_' Time
2. Employment Unit (Name plant, laboratory, warehouse, construction)
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*3. 0SI1A region in which your unites located
______ '
(City)
(Region No
Name(s) and Title(s) of Visitor (s):________________________________ -
4. Was the visitor(s) from OSHA NIOSH_, FEDERAL, STATE
5. What prompted the Inspection?_________ |___________ _______
If a complaint, were you given written copy?______ Was it necessar:
request copy?___________________
Note: Attach copy.
Had the complaint been discussed with management at your locatio;
before being filed?________ No-Yes. Remarks
6. . Was advance notice given? 7. Duration of visit__________ 8. What was inspected?_______
What measurements were made (e.g., air sampling for toxic vapors, noise, etc.)?`
9. What violations were alleged?
DUP 1000085
10. Wctc citations issued? *
_____________________ Note: Attach cop
11. Citations which might warrant contesting- ________ '_________
12. Were penalties assessed?______ Wote: Attach 13. How was the initial contact handled?
a. Officer first appeared at________ ' liariiioiis.e_, Main -Office^ ..et-cO
b. Asked to see* c. Presented credentialsvoluntarilyupon request. d. Did your unit have an established protocol for this eventual:
e. Miscellaneous remarks about ease or difficulty in handling is contact.
14. Did officer talk with Safety Supervisor, Work's Engineer, Compan:
Physician, or comparable people about overall safety and health of installation either before or after inspection? (Give brief s-
IS. Did officer request to see any of the. Company safety "and health
records or records of occupational hazard measurements (e.g.~, to
vapors, dusts, noise, etc.)?NO
YES. Remarks
16. What other materials did he ask for and receive?
17. What representative(s) of employees accompanied officer on inspc
(Union Steward, complaince, etc.) How was employee representative determined?
DUP 1000086 r
18. Names and titles of Corn,.any representativeQs) who accompanied
officer on inspection.____________
' ' _________________________
19. Were questions directed to employee representative(s) and Compan; representative(s) alike in presence of one another? NO Yi Give some examples of what you consider to be most leading quest.
20. Were photographs i*r."
--- ' - . - i.. i- - .* i.' -- - -- accessary?Who took them?
2^, Comment on closing -inference.
22. Do you have any general comments to make in way of a summary?
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Signed t;
Unit He
DUP 1000087 !
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Date 2/20/74
DISTRIBUTION LIST OCCUPATIONAL SAFETY & HEALTH INFORMATION
TO: FROM:
C. S. Beburn )
D. G. Cushing s
W. O. Jewett )
J. R. Pailthorp
A. F. Myers P. B. Vernon H. L. Lawrence R. H. Walsh R. A. Kurtz J. S. Hickman R. A. Hammond H. E. Serenbetz P. E. Dobbs W. H. Ayscue R. Pariser -
H. Jungk - Chambers S. W. McCune - Chestnut Run
D. E. Andersen - Exp. Sta. G. L. Chaikin - Beaumont H. P. Child - Chambers
W. J. Cartledge - Louisville J. N. Montgomery - Pcntchartrc G. Doukas - Eeaumont J. E. Robinson - Pontchartrain B. C. Anderson - Chambers W. K. Witsiepe - Louisville H. L. Dey - Maydown
Fmhs - Beaumont A. M. McConnell - Louisville
B. T. LaMaster - Pontchartrain
M. K. Richards
Attached is a copy of OSHA inspections at Company locations.
DUP 1000088
SAFETY AIID HEALTH INSPECTIONS COMPLAINT
November 23, 1971 - Houston Construction Site
OSHA inspectors appeared as result of complaint by formerconstruction employee. Inspectors were very complimentary of conditions and had no violations to cite.
December 1, 1971 - Beaumont Construction
Visited by OSHA Compliance Officer as result of a complaint by employee of contractor at this location. Complaint was
not recognized as justified and no citation was issued.
--
April, 1972 - Cape Fear Plant
Result of employee complaint on lifting, OSHA Compliance Officer visited plant. _No citation.
June, 1972 - Houston Plant
. OSHA inspection by Compliance Officer as result of complaint ji by employee cf electrical contractor on site. Very satisfied
with our procedures and stated employee had no basis for his complaint.
September 11 & 12, 1972 - Beaumont YJorks
Inspected by OSHA Compliance Officer as result of two complaints
by a Natkin employee (Natkin is a contractor employed by Engineer ing Dept. Construction Div. on plant site). No citations.
September 29,
- Cleveland IC Plant
Visited by OSHA Compliance Officer as result of employee complaint, and Ribbon Mixer in Zinc Chloride Department was inspected. Mo citation issued. Violation - must avait results of air sample taken. Officer said he did not think the complaint was justified and thought the results of the sample taken would so indicate. -=
November 3, 1972 - Repauno Plant
Inspection was made as result of employee complaint. No violations No citation.
February 23, 1913 - Repauno Plant
.OSHA inspection by State Industrial Hygienist because of a widow's clain that her husband died from occupational exposure at the plant.
,
April 12, 1973 - Niagara Works
OSHA Officer appeared as result of erployce complaint.
May 29, 1973 - Hcpauno Plant
Plant inspection by OSHA Inspector as result of employee complaint
Three citations.
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DUP 1000089
COMPLAINT
June 5, 1S73 - Houston Plant
Employee of electrical contractor alleged discrimination when terminated for refusal to work in shutdown plant area. Union upheld term. OSHA Inspector visited plant and discussed with Steward - No problems expected.
June 19, 1973 - Edge Moor Plant
Plant vis Employees Sept. 6, 1973 - Antioch Works
Edge Moor
OSHA Inspector visited plant as result of alledged lead intoxi cation of contractor's employee. No violations or citations pending results of analysis.
Sept. 13, 1973 - Tucker P 4 P Plant
OSHA Compliance Officer visited plant as result of a complaint.
Oct. 4, 1973 - Newport Pigments Plant
OSHA Compliance Officer visited plant as result of complaint of former employee. No violaticns. No citations.
Sept. 20, 1973 - Seaford Nylon Plant
Visited by OSHA Inspector as result of employee complaint regarding noise exposure. No citations, No penalties.
DUP 1000090
SAFETY AND HEALTH INSPECTIONS CONTRACTORS, HEALTH SURVEYS, STATE INSPECTIONS
February, 1972 - Trail Ridge Plant
Inspected by Department of Interior - Metallic A NonMetallic Safety Act. Violation "Welding operations were not shielded". Protective screen to be put around shop welding spot agreed upon and citation eliminated.
May, 1972 - Edge Moor Plant
Inspected by State of Delaware, Department of Labor, as result of employee complaint on Pigments Department's packing and PKT operations. No citation.
July, 1972 - Healing Springs Plant
Routine annual safety inspection by State Department of Labor. No citations.
October 5, 1972 - Belle Plant
Inspection was made by Safety Inspectors from West Virginia Labor Department as result of an employee complaint about scaffolds. Scaffolds that were inspected were found to be safe.
October 6, 1972 - Wurtland Plant
Routine inspection by State Inspector. Violation - hook on chain fall used for raising bagged chemicals pallet had a malfunctioning safety latch. Will be cited in Officer's written report. No penalty.
May 2, 1973 - Florida Plant (Trail Ridge and Highland)
Inspected by Department of Interior. No problems seemed to be present. Report will be forwarded later.
March 27, 1973 - Kinston Construction
OSHA inspection made by North Carolina Department of Labor o" Daniels Construction, Kinston.
Aug. 22, 1973 - Carney's Point Works
Visited by State determine source
Inspector as result of "rumor". No violations. No citations.
Unable to DUP 1000091
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-2 SAFETY AND HEALTH INSPECTIONS CONTRACTORS, HEALTH SURVEYS. STATE INSPECTIONS November 2, 1973 - Monrovia Plant
Routine inspection by California Divisior. of Industrial Safety Compliance Unit. Seven violations. No penalties. December 26 & 27, 1973 - Carney's Point Works Routine annual Inspection by New Jersey Department of Labor Safety Inspectors. No violations. No citations.
DUP 1000092
SAFETY AND HEALTH INSPECTIONS ROUTINE INSPECTION
June, 1971 - Chambers Works "Freon" Area m-
Inspection was evidently a training activity on the part of the Compliance Officer who had just finished a training program. No citations.
August, 1972 - Clr.nton Film Plant
Visited by OSH/ inspector who asked to see barge unloading facilities in connection with his responsibility for inspection of Maritime Operations. No unloading was being accomplished at time of visit, so no inspection was made.
November 1, 1972 - Clinton Film Plant
Routine OSHA irspection by Federal Compliance Officer. Citation of a minor character resulted in a penalty of $50. Paid by plant without comment.
January 25, 1973 - Fayetteville Works
OSHA inspector from North Carolina Department of Labor made a routine inspection. No violations. No citation.
March 28, 1973 - Hndo
OSHA inspection. Some citations primarily related to improper guarding of dr'.ves. $100 fine - paid by Endo.
May 9, 1973 - Mobnrly Plant
OSHA routine inspection - no citations.
May 21, 1973 - Fa:.rfield Plant
Plant visited by Senior Factory Inspector, Dept, of Labor, State of Connecticut, unannounced for an annual inspection. Ilis prim:; interest was to inspect the Plant under State Statutes." Three items found to be in violation and a few minor infractions. To be reinspected in 60 days.
June 13, 1973 - Pompton Lakes Works
Plant visited by Safety Officer from Defense Supply Agency to conduct a safety audit. No recommendations made.
June 12, 1973 - CLearfield Plant (Berg Electronics) Compliance Officer visited plant on a scheduled inspection. No citations issued. DUP 1000093
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SAFETY AND HEALTH INSPECTIONS ROUTINE
July 3, 1973 - Chicago' F & F Plant
Routine OSHA inspection. No violations. No citations.
August l*i, 1973 - Du Pont Works
Compliance Officer indicated it was a "get acquainted" visit to ciieck
our wharf. Five citations but Compliance Officer did not think tiere
would be any penalties.
^
September 13, 1973 - Brevard Photo Products Plant
Routine OSHA Inspection.
September 17, 1973 - Findlay, Ohio (Remington) Plant
Routine inspection by OSHA Inspector. No serious violations. Three other violations, proposed penalty $100.
September 25, 1973 - Johnsonville Plant
OSHA Inspector was directed by his area supervisor to inspect plait.
Primarily sanitation and health facilities. Made some noise level readings. No violations. No penalties.
October 2-3, 1973 - Bridgeport, Conn. (Remington) Plant
Routine inspection by OSHA Inspector. No violations. No penalties.
October 3, 1973 - Cleveland ICD Plant
A NIOSH Representative made a scheduled one-day visit to the plant to obtain data on personnel exposure to chemicals and other hazards
in business and manufacturing facilities. He indicated approval of plant's medical program and noise control program.
October 29-30, 1973 - Cape Fear Plant
Inspected by two North Carolina Department of Labor representatives as result of random selection. Two violations. -No penalties.
November 28, 1973 - Biwablk Works
Routine inspection by State of Minnesota Department of Labor. Two violations. No penalties.
DUP 1000094
SAFETY AND HEALTH INSPECTIONS INCIDENT OR SERIOUS INJURY____
November, 1971 - Grassclli Plant Result of serious injury to an employee. OSHA inspectors appeared at plant but decided to leave inspection to state men who were already present. No citations.
March, 1972 - Newport Plant Inspected because of death of an employee in February, 1972, resulting from a broken leg in December, 1971. (OSHA Compliance Officer) No citations.
May, 1972 - Savannah River Plant Inspected by OSHA Compliance Officer as result of a fatality. No citations.
November 29, 1972 - Spruance Fibers Plaivt Inspection resulted because of fatality of contractor employse. No citation.
January 23, 1973 - Savannah River Plant OSHA Compliance Officer made inspection of plant as result of fatality on 1/11/73. No violations found. No citation.
October 18, 19, & 30, 1973 - Chambers Works OSHA inspection made because of explosion on 10/17/73 which resulted in one fatality. No violations. No citations.
DUP 1000095