OSHA Inspection: RENAISSANCE HOTEL MANAGEMENT COMPANY, LLC

Issued

Apr 6, 2023

Penalty

Initial $15,625 · Current $13,000 Reduced

Hazardous substances C730

General-duty citation text

29 CFR  1910.1000(a)(2): Employee(s) were exposed to an airborne concentration of  Carbon Monoxide listed in Table Z-1 in excess of the 8 hour Time Weighted Average concentration of 50 parts per million (ppm):  a) On November 7, 2022, the employer did not ensure that employee(s) exposed to carbon monoxide did not exceed 50 ppm for an 8-hour Time Weighted Average (TWA). A Building Engineer working in the boiler room was exposed to an 8-hour Time Weighted Average (TWA) concentration of carbon monoxide of 701.4 parts per million (ppm), approximately 14.03  times the  OSHA 8-hour Time Weighted Average (TWA) Permissible Exposure Limit of 50 ppm. The carbon monoxide exposure level was derived from carboxyhemoglobin levels of  35.7%, measured on November 7, 2022.  No abatement certification or documentation is required for this item.

Issued

Apr 6, 2023

Abate by

Jul 7, 2023

Penalty

Initial $0 · Current $0

Hazardous substances C730

General-duty citation text

29 CFR  1910.1000(e): Feasible administrative or engineering controls were not determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):  a) On November 7, 2022, the employer failed to implement an effective combination of engineering and work practice controls to reduce and maintain employee(s) exposures to carbon monoxide to or below 50 parts per million or less. A Building Engineer 3 working in the boiler room was exposed to carbon monoxide at an 8-hour Time Weighted Average (TWA) concentration of 701.4 parts per million (ppm), approximately 14.03  times the  OSHA 8-hour Time Weighted Average (TWA) Permissible Exposure Limit of 50 ppm.   Methods of engineering and work practice controls include but are not limited to:  1. Seek the expertise of a competent individual such as an engineer or certified industrial hygienist to assess existing controls and work practices, obtain recommendations to improve existing controls and work practices, and prepare documentation for the successful installation of recommended equipment or modifications.  2.  Repair, replace or otherwise tune all water boilers, ensuring compliance with current and/or applicable emission controls criteria and standards.  Ensure that water boilers draft and combustion readings are per the manufacturer's recommendations.   3. Implement and adhere to a preventative maintenance schedule for  water boilers as per the manufacturer's instructions.   4. Ensure that water boiler preventive maintenance are conducted by fully trained and qualified employees. Ensure that employees have all the tools to effectively conduct the boiler preventive maintenance.   5. Evaluate the Boiler Room current gas detection system, CO alarm, to ensure that is adequate for commercial operations and that can accurately detect all the different gases that may potentially be generated in the room.       ABATEMENT NOTE:    STEP 1: Effective training on the recognition, signs and symptoms of Carbon Monoxide shall be provided to affected employees.      Abatement Date: 15 days from the citation issuance date  STEP 2: A written, detailed plan of abatement shall be submitted to the Area Director outlining a schedule for the implementation of engineering controls and work practice measures to control employee exposures to carbon monoxide, as referenced in the citation.     Abatement Date: 60 days from the citation issuance date  In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Apr 6, 2023

Abate by

May 2, 2023

Penalty

Initial $11,162 · Current $9,000 Reduced

General-duty citation text

29 CFR  1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met:   a) On November 7, 2022,  the employer did not develop, implement or maintain at the workplace a written chemical hazard communication program which includes 29 CFR 1910.1200(e)(1)(1) through (e)(1)(iii) as outlined by the Standard, and which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met.   Employees worked with hazardous chemicals such as, but not limited to , natural gas and carbon monoxide.  In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).