OSHA Inspection: ENGINEERING PROFESSIONAL SERVICES

Issued

Sep 20, 2010

Abate by

Nov 4, 2010

Penalty

Initial $1,800 · Current $1,080 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized hazards that
were causing or likely to cause death or serious physical harm to
employees in that employees
were exposed to the hazards of excessive levels of heat stress while
installing communications
equipment on military vehicles on August 12, 2010, and at times prior
thereto. Such exposures
may lead to the development of serious heat-induced illnesses such as heat
stroke, heat
exhaustion, heat syncope (heat-induced loss of consciousness), heat
cramps, heat rash, and
transient heat fatigue.
a) At the worksite located at 53rd North Street, Bldg 2032 (M3), Fort
Hood, Texas,
employees were exposed to hazardous levels of heat while performing work
inside
installing communications equipment on military vehicles on August 12,
2010, and at
times prior thereto. Such exposures may lead to the development of serious
heat-induced
illnesses such as heat stroke, heat exhaustion, heat syncope (heat-induced
loss of
consciousness), heat cramps, heat rash, and transient heat fatigue. The
Wet Bulb Globe
Temperature (WBGT) index in the vehicle bay ranged from 81.3 degrees F to
86.6
degrees F during the 427 minute sampling period on August 12, 2010. The
estimated
metabolic workload for employees performing tasks along the install line
put them in the
"moderate" workload category as correlated with the guidelines established
by the
American Conference of Governmental Industrial Hygienists (ACGIH) and the
National
Institute for Occupational Safety and Health (NIOSH). The exposed
employees were
performing various work tasks that included installing equipment mounts,
communication
units, antennas, wiring, and other various related activities. The
environment the exposed
employees worked in was inside a vehicle bay that had overhead cover and
four rolling
garage type doors, with as many as ten vehicles at a time within.  The
heat sources for
the work environment included the vehicles themselves since they are
parked on the
apron in the direct sunlight and are comprised of metal; four
wall-mounted, window style
air conditioning units that were rearward facing to the bay and blowing
hot exhaust; and
the weather as a National Weather Service Heat Advisory had been issued
for the day
of the inspection with daytime highs in the lower 100's and heat indices
of 106 or above.
The employer implemented various heat stress controls, such as beginning
work at 7 AM
and finishing at 4 PM; allowing an hour and a half for lunch (11:30 AM to
1:00 PM,
and working 3 hours in the afternoon); large standing, stationary fans; a
Sparkletts 5-
gallon water cooler; one full size refrigerator/freezer; two mini-frigs;
electrolyte mix;
and an air conditioned breakroom. At the time of the inspection, the CSHO
observed that
there were a total of 9 fans in the bay, but only 6 were running, as they
all
have an auto
shut-off mechanism to prevent motor burn-out, and the 3 were off due to
this reason.
Also noted was that the water cooler did not appropriately chill the water
in the afternoon
due to the excessive demand and heat. The breakroom that had air
conditioning required
the exposed employees to walk over 400 feet away on the apron and in
direct sunlight.
The electrolyte mix was within the breakroom instead of at the water
cooler within the
bay area. And through questioning and interviews, CSHO ascertained that
there was no
heat stress training for the exposed employees.
Means of feasible abatement to correct these hazard(s) include, but may
not be limited
to:
1. Development of a formal heat stress management program which
incorporates: (a) use
of heat stress instruments to monitor the work environment; (b) a heat
acclimation
program to increase heat tolerance of new employees and employees
returning
from
periods of absence of 3 or more days; (c) provision of a nearby cooler
area where heat-
affected employees may recover when symptoms of heat-related illness are
recognized
in, or reported by, employees; (d) availability of adequately trained
personnel at the work
site to treat workers that develop signs or symptoms of a serious heat
related illness, such
as heat stroke; (e) maintenance of ice or iced water in adequate amounts
for immediate
first aid to heat stroke victim(s); and (f) a continuing training program
informing
employees about: (1) The hazards of heat-related injuries and illness(es)
and preventative
measures; (2) Predisposing factors and relevant signs and symptoms of
heat-related
illness; (3) Potential health effects of excessive heat stress; (4)
Importance of immediate
reporting to onsite management personnel of the development of signs or
symptoms of
heat-related illness observed in or reported by employees; (5) First aid
procedures for
heat-related illnesses; (6) Importance of immediate administration of
appropriate first aid
to workers reporting or displaying symptoms of heat-related illness; and
(7) Effects of
therapeutic drugs and social drugs (including alcohol) that may increase
the risk of heat
injury or illness by reducing heat tolerance. The Fort Hood Industrial
Hygiene Office
was also on site the day of the inspection and had similar readings and
conclusions.
2. Installing additional fans per vehicle with a goal of two per vehicle.
Obtaining swamp
coolers would be ideal.
3. Installing exhaust fans within the ceiling or walls to pull hot air out
of the bay area,
and to redirect the hot exhaust from the four wall-mounted, window style
air conditioning
units, or to reposition them such as they will blow the exhaust outside
and not within the
bay area.
Note: Examples of Permissible Heat Exposure Threshold Limit Values [Values
are given
in 0 degrees C and (0 degrees F) WBGT] established by the American
Conference of
Governmental Industrial Hygienists (ACGIH) are based on the assumption
that nearly all
acclimatized, fully clothed (e.g., lightweight pants and shirt) workers
with adequate water
and salt intake should be able to function effectively under the given
working conditions
without exceeding a deep body temperature of 38 degrees C (100.4 degrees
F). The
Permissible Heat Exposure TLVs are also based on a 5-day work week with an
8-hour
workday. As workload increases, the heat stress impact on an
unacclimatized worker is
exacerbated. For unacclimatized workers performing a moderate level of
work, the
permissible heat exposure TLV should be reduced by approximately 2.5
degrees C (36.5
degrees F).rees

Issued

Sep 20, 2010

Abate by

Nov 4, 2010

Issued

Sep 20, 2010

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Nov 4, 2010

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Issued

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Issued

Sep 20, 2010

Abate by

Nov 4, 2010