OSHA Inspection: US FEDERAL AVIATION ADMINISTRATION

Issued

Dec 30, 1992

Abate by

Feb 1, 1993

General-duty citation text

Executive order 12196 section 1-201(a) of the Occupational Safety
and Health Program for Federal Employees'.  The agency head did not
furnish employees places and conditions of employment that were free
from recognized hazards that were causing or were likely to cause
death or serious physical harm:
a)  Employees were exposed to the hazard of suffocation,
burns, or other serious bodily harm or death in the air
traffic control tower at the Allentown, Bethlehem, Easton
(ABE) airport, on or about July 7, 1993.
CHAPTER 12
1.  178c.(4):  The fire cut-off door leading from the
mechanical
room, under the tower floor, to the stair tower was
constructed of 3/4 inch wood.  The door measured 24
inches wide by 43 inches high.  The exit door from the
radar equipment room and the radar room were hollow
wooden doors used in housing construction.
2.  178d.(1):  The stair tower to the Air Traffic Control
Tower (ATCT) terminated in the tower rather than the
ceiling or floor.
3.  178e.(3)(a):  A small office was constructed on the
north side of the radar equipment control room and it
did not have a one-hour fire rating, in that the room
was constructed of 2 x 4 wood studded walls with wood
paneling on the walls.  This room was connected to the
administrative office by a common wall.
4.  178e.(6):  The HVAC ducts that pass through the control
tower floor from the mechanical room were not fire
stopped (grouted) nor was mineral wool or other fire
resistive material used.  The 6 inch by 6 inch hole
in the mechanical room floor which was used to pass
wiring from the radar equipment room to the control
tower did not have fire stopping and two (2) six (6)
inch by six (6) inch holes in the ceiling of the radar
command room.
5.  179a.(1)(c):  The door on the control tower restroom
was 28 inches wide and opened against the way of egress
in a 40 inch wide stair well.
6.  179a.(1)(d):  The main exit door from the control tower
was only 22 1/2 inches wide.
7.  179a.(1)(f):  None of the doors designated as fire doors
were marked as to the fire rating.  These doors were
located in the stair towers and the radar equipment,
radar command and radar room.
8.  179a(3)(b):  The riser leading to the control tower
cab were 7 1/2 inch rise and 10 inches run.
9.  179a.(3)(e):  The first and second stair landings
exiting the control tower cab were only 35  1/2 inches
by 35 1/2 inches rather than the required 44 inches.
10.  179a.(3)(f):  The second set of steps exiting the
control tower cab had the headroom reduced by steel
beams.  The restrictions were 6 feet 3 inches, 5 feet
3 inches, and 6 feet 4 inches, and these area were not
marked to indicate low clearance.
11.  179a.(4)(b):  The ATCT located on top of a building
did not have any smoke proof enclosures.  (This facility
was built in the 1950's).
12.  179a.(4)b.(1):  The means of egress provided for the
control tower cab and it was not a smoke proof enclosure
and no fire detection or alarm system was provided in
the entire facility.
13.  179a.(4)c.(1):  The first designated emergency exit
from the tower cab was not marked.  This door was used
for two evacuation routes that were not immediately
visible and no direction signs were provided.  When
using the escape route that was indicated as straight
through the door, the employees must step over a six
(6) inch sill to enter a 35 inch wide aisle around the
tower cab and there they must step over a 23 1/2 inch
parapet wall then turn right across the roof to a
ladder.  Exit doors in the control tower cab, stair
tower, radar equipment and radar room were not marked.
179a.(4)c.(1):  The second route was down the control
tower stairs through a single fire door and proceed down
the steps or turn right through two (2) aluminum doors
and proceed out.  The direction of travel was not marked
and the employees must make four (4) turns around the
tower to gain access to the stair tower beside the
administration office.  This route of travel is outside
and no emergency lighting with battery back-up was
provided on that outside route or in the stair tower.
14.  179a.(4)c.(5):  No emergency lighting was supplied for
the escape route from the control tower cab.  Employees
must exit across the roof and down several ladders.
A light switch and flood lights were provided for their
route, but no back-up power supply was provided in case
of power failure.  The route around the tower and down
the stair tower by the administration office did not
have any emergency lights.
179a.(4)c.(5):  The  emergency light above the ATCT exit
door and the emergency light on the second floor landing
of the ATCT stair tower did not light when tested.
15.  180a:  This tower did not have any fire detections or
alarm systems.  Battery operated smoke detectors were
located at various locations in the control tower cab
stair tower but they did not meet the requirements of
180b.(1)-(13).
16.  180d.(2)(a):  The tag on the extinguisher did not
indicate monthly inspections.  The last inspection was
2/11/93 in the radar and break rooms.
17.  182a:  The fire evacuation plan contained in appendix
4. Bomb incidents of the ABE handbook was designed more
for bomb threat than fire.  An emergency action plan
should be developed that follows 29 CFR 1910.38(a).
The emergency egress routes that were posted in the
control tower cab, was not clear as to the proper
route/travel.
18.  The agency did not follow the agreed Interim Fire Safety
Improvements at Airport Traffic Control Tower. (ATCT)
in that section 4.a.(1) requires an evacuation plan,
designated exit ways and outside assembly areas.
1.  The evacuation plan did not detail the emergency
escape procedures and the route assignments, the
control tower map did not clearly indicate both routes.
2.  No procedure was developed to account for all
employees after the emergency evacuation has been
completed.
3.  If rescue or medical duties are necessary, the plan
did not assign or detail those duties.
4.  The preferred means of reporting emergencies and
the number to call shall be posted.
5.  Contact person, name, title or department, if
questions arise about the evacuation plan.
6.  The alarm system was local only (home type smoke
detectors) and the alarms in the lower elevations could
not be detected in all work areas.
7.  The employees shall be briefed on the evacuation
plan twice annually or anytime a change to the plan
is made or new duties are assigned or changed.
ABATEMENT NOTE:
1.  The evacuation plan should contain the following elements of a fire
prevention plan.
(i)  A list of the major workplace fire hazards and their proper
handling and storage procedures, potential ignition sources (such
as welding, smoking and others) and their control procedures,
and the type of fire protection equipment or systems which can
control a fire involving them;
(ii) Names or regular job titles of those personnel responsible
for maintenance of equipment and systems installed to prevent
or control ignitions or fires, and
(iii)  Names or regular job titles of those personnel responsible
for control of fuel source hazards.
2.  Housekeeping.  The employer shall control accumulations of
flammable
and combustible waste materials and residues so that they
do not contribute to a fire emergency.  The housekeeping
procedures shall be included in the written fire prevention plan.
3.  Training.
(i)  The employer shall apprise employees of the fire hazards
of the materials and processes to which they are exposed.
(ii)  The employer shall review with each employee upon initial
assignment those parts of the fire prevention plan which the
employee must know to protect the employee in the event of an
emergency.  The written plan shall be kept in the workplace and
made available for employee review.  For those employers with
10 or fewer employees, the plan may be communicated orally to
employees and the employer need not maintain a written plan.
4.  Maintenance.  The employer shall regularly and properly maintain,
according to established procedures, equipment and systems
installed on heat producing equipment to prevent accidental
ignition of combustible materials.  The maintenance procedures
shall be include in the written fire prevention plan.
Section 4.b. Only one (1)air traffic controller is on duty during
the midnight shift and no procedure was devised to verify the presence
of a fire if the alarm sounds or if a fire is otherwise suspected.
Only local home-type alarms are used in the facility.  Section 4.1.
allows for home-type detectors as interim protection not permenant
protection as on this site.