OSHA Inspection: THE MONROE CLINIC, INC.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $12,471 · Current $12,160 Reduced

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(e)(1): All Class I, II, and III asbestos work was not conducted within regulated areas:    On or about September 27, 2016, and at times prior to and thereafter, the employer did not ensure that Class III asbestos work was conducted within regulated areas, including but not limited to the following occurrences:    a) Beginning July 1, 2016 through July 27, 2016, induction coil unit maintenance which disturbed asbestos containing material located on the backside of false drop ceiling tiles.    b) Beginning July 1, 2016 through August 29, 2016, fan coil unit maintenance which required crawling within the 1950 Building crawl space which contains asbestos containing material in the dirt and debris.    e) On July 12, 2016, opening boiler #2 for inspection and disturbing asbestos containing material that insulates the boiler.    f) On July 13, 2016, boiler #2 inspection and clean up which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    h) On July 21, 2016, boiler #1 inspection which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    j) On July 26, 2016, the removal of relief valves for recertification on boiler #2 which required disturbing friable asbestos containing insulation on the piping and asbestos containing debris around the valves.    k) Beginning August 1, 2016 through August 25, 2016, boiler 2 annual maintenance which required crawling on top of and disturbing the friable and damaged asbestos containing material that insulates the boiler.    l) Beginning August 1 2016 through August 5, 2016, the insertion of a flue gas probe through damaged and friable asbestos containing material to conduct an analysis of the flue gas for boilers #1 and #2.    m) Beginning August 8, 2016 through August 12, 2016, the insertion of a flue gas probe through damaged and friable asbestos containing material to conduct an analysis of the flue gas for boilers #1 and #2.    n) On August 14, 2016, work on the reassembly of boiler #2 which disturbed asbestos containing material that insulates the boiler.    o) On August 15, 2016, removal of lockout /tagout from boiler #2 and application of lockout/tagout to boiler #1 which disturbed asbestos containing material that insulates the boilers.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $12,471 · Current $12,159 Reduced

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(f)(2)(i): The employer with a work operation covered by the asbestos standard did not ensure that a "competent person" conducted an exposure assessment immediately before or at the initiation of the operation to ascertain expected exposures during that operation or workplace:    On or about September 27, 2016, and at times prior to, a competent person did not conduct an exposure assessment immediately before or at the initiation of maintenance staff performing class III asbestos work, including but not limited to, the following occurrences:    a) Beginning July 1, 2016 through July 27, 2016, induction coil unit maintenance which disturbed asbestos containing material located on the backside of false drop ceiling tiles.    b) Beginning July 1, 2016 through August 29, 2016, fan coil unit maintenance which required crawling within the 1950 Building crawl space which contains asbestos containing material in the dirt and debris.    e) On July 12, 2016, opening boiler #2 for inspection and disturbing asbestos containing material that insulates the boiler.    f) On July 13, 2016, boiler #2 inspection and clean up which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    h) On July 21, 2016, boiler #1 inspection which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    j) On July 26, 2016, the removal of relief valves for recertification on boiler #2 which required disturbing friable asbestos containing insulation on the piping and asbestos containing debris around the valves.    k) Beginning August 1, 2016 through August 25, 2016, boiler 2 annual maintenance which required crawling on top of and disturbing the friable and damaged asbestos containing material that insulates the boiler.    n) On August 14, 2016, work on the reassembly of boiler #2 which disturbed asbestos containing material that insulates the boiler.    o) On August 15, 2016, removal of lockout /tagout from boiler #2 and application of lockout/tagout to boiler #1 which disturbed asbestos containing material that insulates the boilers.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $12,471 · Current $0 Reduced

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(f)(6)(i): The employer failed to provide the affected employees or their designated representatives an opportunity to observe the exposure monitoring:    On or about August 24, 2016, the employer did not provide the maintenance employees the opportunity to observe exposure monitoring.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $12,471 · Current $12,160 Reduced

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(h)(1)(iii): Respirators were not used during Class II and III asbestos jobs where wet methods were not used:     On or about September 27, 2016, and at times prior to and there after, the employer did not ensure that respirators were used during Class III asbestos jobs where wet methods were not used, including but not limited to, the following occurrences:    a) Beginning July 1, 2016 through July 27, 2016, induction coil unit maintenance which disturbed asbestos containing material located on the backside of false drop ceiling tiles.    b) Beginning July 1, 2016 through August 29, 2016, fan coil unit maintenance which required crawling within the 1950 Building crawl space which contains asbestos containing material in the dirt and debris.    e) On July 12, 2016, opening boiler #2 for inspection and disturbing asbestos containing material that insulates the boiler.    f) On July 13, 2016, boiler #2 inspection and clean up which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    h) On July 21, 2016, boiler #1 inspection which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    j) On July 26, 2016, the removal of relief valves for recertification on boiler #2 which required disturbing friable asbestos containing insulation on the piping and asbestos containing debris around the valves.    k) Beginning August 1, 2016 through August 25, 2016, boiler 2 annual maintenance which required crawling on top of and disturbing the friable and damaged asbestos containing material that insulates the boiler.    n) On August 14, 2016, work on the reassembly of boiler #2 which disturbed asbestos containing material that insulates the boiler.    o) On August 15, 2016, removal of lockout /tagout from boiler #2 and application of lockout/tagout to boiler #1 which disturbed asbestos containing material that insulates the boilers.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $12,471 · Current $0 Reduced

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(h)(1)(iv): Respirators were not used during all Class II and III asbestos jobs where the employer had not produced a negative-exposure assessment:    On or about September 27, 2016,  and at times prior to and thereafter, the employer did not ensure that respirators were used during Class III asbestos jobs where the employer had not produced a negative-exposure assessment, including but not limited to, the following occurrences:    a) Beginning July 1, 2016 through July 27, 2016, induction coil unit maintenance which disturbed asbestos containing material located on the backside of false drop ceiling tiles.    b) Beginning July 1, 2016 through August 29, 2016, fan coil unit maintenance which required crawling within the 1950 Building crawl space which contains asbestos containing material in the dirt and debris.    e) On July 12, 2016, opening boiler #2 for inspection and disturbing asbestos containing material that insulates the boiler.    f) On July 13, 2016, boiler #2 inspection and clean up which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    h) On July 21, 2016, boiler #1 inspection which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    j) On July 26, 2016, the removal of relief valves for recertification on boiler #2 which required disturbing friable asbestos containing insulation on the piping and asbestos containing debris around the valves.    k) Beginning August 1, 2016 through August 25, 2016, boiler 2 annual maintenance which required crawling on top of and disturbing the friable and damaged asbestos containing material that insulates the boiler.    ln) On August 14, 2016, work on the reassembly of boiler #2 which disturbed asbestos containing material that insulates the boiler.    o) On August 15, 2016, removal of lockout /tagout from boiler #2 and application of lockout/tagout to boiler #1 which disturbed asbestos containing material that insulates the boilers.    r) Beginning August 29, 2016 through August 30, 2016, the insertion of a flue gas probe through damaged and friable asbestos containing material to conduct an analysis of the flue gas for boilers #1 and #2.    s) Beginning September 5, 2016 through September 7, 2016, the insertion of a flue gas probe through damaged and friable asbestos containing material to conduct an analysis of the flue gas for boilers #1 and #2.    t) Beginning September 19, 2016 through September 22, 2016, the insertion of a flue gas probe through damaged and friable asbestos containing material to conduct an analysis of the flue gas. for boilers #1 and #2.    u) Beginning September 12, 2016 through September 14, 2016, the insertion of a flue gas probe through damaged and friable asbestos containing material to conduct an analysis of the flue gas for boilers #1 and #2.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $12,471 · Current $12,159 Reduced

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(g)(9): The employer did not follow the work practices and engineering controls for Class III asbestos work specified in 29 CFR 1926.1101(g)(9)(i) through (g)(9)(v), to minimize the exposure to employees:    On or about September 27, 2016, and at times prior to and thereafter, the employer did not use engineering controls when maintenance employees were performing Class III activities, including but not limited to, the following occurrences:    a) Beginning July 1, 2016 through July 27, 2016, induction coil unit maintenance which disturbed asbestos containing material located on the backside of false drop ceiling tiles.    b) Beginning July 1, 2016 through August 29, 2016, fan coil unit maintenance which required crawling within the 1950 Building crawl space which contains asbestos containing material in the dirt and debris.    e) On July 12, 2016, opening boiler #2 for inspection and disturbing asbestos containing material that insulates the boiler.    f) On July 13, 2016, boiler #2 inspection and clean up which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    h) On July 21, 2016, boiler #1 inspection which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    j) On July 26, 2016, the removal of relief valves for recertification on boiler #2 which required disturbing friable asbestos containing insulation on the piping and asbestos containing debris around the valves.    k) Beginning August 1, 2016 through August 25, 2016, boiler 2 annual maintenance which required crawling on top of and disturbing the friable and damaged asbestos containing material that insulates the boiler.    n) On August 14, 2016, work on the reassembly of boiler #2 which disturbed asbestos containing material that insulates the boiler.    o) On August 15, 2016, removal of lockout /tagout from boiler #2 and application of lockout/tagout to boiler #1 which disturbed asbestos containing material that insulates the boilers.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $12,471 · Current $0 Reduced

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(i)(1): The employer did not provide and require the use of protective clothing, such as coveralls or similar whole-body clothing, head coverings, gloves, and foot coverings for each employee exposed to airborne concentrations of asbestos that exceed the time weighted average and/or excursion limit in 29 CFR 1926.1101(c) or for which a required negative exposure assessment was not produced:    On or about September 27, 2016, and at times prior to and thereafter, the employer did not provide maintenance staff appropriate protective clothing when Class III work was performed for which a required negative exposure assessment was not provided, including but not limited to, the following occurrences:     a) Beginning July 1, 2016 through July 27, 2016, induction coil unit maintenance which disturbed asbestos containing material located on the backside of false drop ceiling tiles.    b) Beginning July 1, 2016 through August 29, 2016, fan coil unit maintenance which required crawling within the 1950 Building crawl space which contains asbestos containing material in the dirt and debris.    e) On July 12, 2016, opening boiler #2 for inspection and disturbing asbestos containing material that insulates the boiler.    f) On July 13, 2016, boiler #2 inspection and clean up which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    g) Beginning July 18, 2016 through July 22, 2016, the insertion of a flue gas probe through damaged and friable asbestos containing material to conduct an analysis of the flue gas for boilers #1 and #2.    h) On July 21, 2016, boiler #1 inspection which required opening the boiler and disturbing asbestos containing material that insulates the boiler.    j) On July 26, 2016, the removal of relief valves for recertification on boiler #2 which required disturbing friable asbestos containing insulation on the piping and asbestos containing debris around the valves.    k) Beginning August 1, 2016 through August 25, 2016, boiler 2 annual maintenance which required crawling on top of and disturbing the friable and damaged asbestos containing material that insulates the boiler.    n) On August 14, 2016, work on the reassembly of boiler #2 which disturbed asbestos containing material that insulates the boiler.    o) On August 15, 2016, removal of lockout/tagout from boiler #2 and application of lockout/tagout to boiler #1 which disturbed asbestos containing material that insulates the boilers.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $12,471 · Current $9,976 Reduced

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(k)(6): At the entrance of the mechanical rooms/areas in which employees could reasonably be expected to enter and which contained ACM and/or PACM, the building owner did not post signs identifying the material present, its location, and appropriate work practice which, if followed will ensure that asbestos containing material and/or presumed asbestos containing material will not be disturbed:    On or about July 1, 2016, and at times thereafter, the employer did not post any signage on the boiler room/Power Plant identifying the asbestos containing material present, its location and appropriate work practices which, if followed, will ensure that power plant operators and maintenance staff will not disturb asbestos containing material and/or presumed asbestos containing material.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(k)(8)(i): Where feasible, installed asbestos products did not contain a visible label:    On or about July 1, 2016, and at times thereafter, the employer did not ensure that where feasible, installed asbestos products contained a visible label, such as but not limited to, the pipe insulation in the boiler room, the insulation around the boilers and the access door to the crawlspace opening.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $12,471 · Current $9,976 Reduced

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(k)(9)(i): The employer did not institute, at no cost to employees, a training program for each employee who was likely to be exposed in excess of the permissible exposure limit (PEL) and for each employee who performed Class I through IV asbestos operations:    On or about July 1, 2016, and at times prior to and thereafter, the employer did not provide required training to the maintenance employees that perform Class III and Class IV asbestos operations.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(o)(1): The employer did not designate a competent person on construction worksites, having the qualifications and authorities for ensuring worker safety and health required by 29 CFR 1926.1101(C), General Safety and Health Provisions for Construction 29 CFR 1926.20 through 29 CFR 1926.32:    On or about September 27, 2016, and at times prior to and thereafter, the employer did not designate a competent person with the qualifications for ensuring worker safety and health for maintenance employees performing Class III and Class IV work, in that the competent person was not trained in a manner consistent with EPA requirements for training as set forth at 40 CFR 763.92(a)(2).

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $124,709 · Current $62,355 Reduced

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(k)(1)(ii): The employer did not include asbestos in the program established to comply with the Hazard Communication Standard (HCS) and ensure each employee was trained in accordance with the provisions of the HCS and paragraphs (k)(9) and (10) of this section. The employer did not provide information on at least the following hazards: Cancer and lung effects.    On or about September 27, 2016, and at times prior to and thereafter, the employer did not include asbestos in the Hazard Communication Standard to ensure that each employee, including but not limited to, maintenance employees, was trained in the hazard of the asbestos in the facility and at least the cancer and lung effects of the hazard.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 9020

General-duty citation text

29 CFR 1926.1101(k)(2)(ii)(B): The building owner and/or facility owner did not notify employees of the owner who will work in or adjacent to areas containing asbestos containing material or presumed asbestos containing material of the presence, location and quantity:    On or about July 1, 2016, and at times thereafter, the employer did not inform maintenance staff who work in and adjacent to the 1938,  1958, 1972 and 1993 buildings containing asbestos containing material or presumed asbestos containing material of the presence, location and quantity, as identified in the 2008 asbestos survey and the 2016 asbestos survey.

Issued

Dec 21, 2016

Abate by

Jan 13, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 9020

General-duty citation text

29 CFR 1910.1200(h)(2)(ii): The employer did not provide information to the employees on operations in their work area where hazardous chemicals were present:    On or about September 27, 2016, and at times prior to and thereafter, the employer did not provide employees information on the asbestos throughout the facility.