Introduction
Acme Widget Factory was recently inspected by the Occupational Safety and Health Administration (OSHA), which revealed several safety violations and emailed a Notice of Citations and Penalties to the company. According to this document, Acme is obliged to pay $206,000 in penalties for serious and willful breaches of occupational safety. The firm’s safety director organized an informal conference with the regional OSHA director to discuss specific fines and citations that were issued against Acme. At this meeting, the safety department director will be accompanied by five team members who conduct safety training for workers. The firm agrees that severe violations were made regarding employees’ health security, and the safety department guarantees that those issues will be resolved within the indicated period. For instance, OSHA found that the concentration of lead fumes in the frame assembly area was double the permissible exposure levels, which is hazardous for human health if appropriate respirators are not worn (OSHA, 2015). However, the company’s representatives want to discuss all willful and serious violations during the informal meeting and try to reduce some of the penalties.
Discussion
The second citation states that no initial air sampling was done to assess lead levels in the working areas, but OSHA representatives did not ask for Acme documentation related to this particular problem. The company’s safety department performs continuous measurements of lead levels in major operational areas. However, Acme admits that the lead levels were not recorded in the frame assembly area even though efforts were made to reduce those levels. Furthermore, the safety department realizes that not all employees wore respirators while working there, even though formal training was conducted for everyone. Acme will ensure that this issue will be eliminated within the period indicated in the Notice of Citations and Penalties. However, the safety department cannot agree with the statement that air sampling was not done. Since this particular notice was not completely accurate, the safety department wants to ask OSHA to reduce the proposed penalty by half.
Another aspect that the safety department wants to discuss during an informal conference with OSHA is the second item of the same citation discussed above. Official one-week training was conducted at Acme for all employees working in the areas of potential lead exposure. Additionally, new workers who were hired later than these instructions were provided underwent the same tutelage. Therefore, the safety department believes that this specific notice should be reverted, and the penalty of $49,000 needs to be removed. Unfortunately, the safety department did not strictly assess their knowledge and understanding; hence, some employees wore respirators incorrectly or willingly refused to wear them. Since cameras are not placed in all operational rooms at Acme, this situation cannot always be controlled. The safety department issued a disciplinary warning to those workers who were not wearing masks and scheduled new training for all employees for the next week. However, this time, an official oral and written assessment will be done to ensure that all employees understand the provided information correctly and can apply it at the workplace. Moreover, cameras will be placed in all working areas within the next three months.
The next citation that the safety department representatives wish to discuss during this meeting is that OSHA’s notice claims that no instructions were provided for those who were exposed to toxic materials. Acme wants to clarify this item to reduce the penalty of $49,000 by half. The document states that “no training was provided for employees who work on the site and are exposed to hazardous chemicals including … lead, methyl ethyl ketone, acetone, and sulfuric acid” (OSHA, 2015, p. 27). The safety department can provide official documentation that all workers attended lectures related to working with alloys and various toxic substances. Still, Acme decided to conduct training again, including all new chemicals introduced on the factory lane; the abatement document will be provided during the meeting.
The company admits that the severe violations took place and is ready to pay the proposed penalties of $59,000. Furthermore, the appropriate actions will be taken to correct the indicated issues and prevent similar situations in the future. However, the safety department believes that the notices about willful violations were inaccurate; thus, Acme representatives asked to reduce payment for this type of error from $147,000 to $49,000. The total penalty the firm will pay if OSHA agrees that the provided arguments are valid is $108,000. The safety department will ensure that training about toxic substances at the factory and protection measures is conducted regularly. Additionally, one employee in each team will be assigned to control if all workers wear gloves and respirators in areas with potentially high levels of lead or other hazardous materials. If Acme fails to correct these violations, the firm will be required to pay the total amount of penalties proposed in the initial document.
Conclusion
In summary, the Acme safety department decided to organize an informal conference with OSHA representatives to discuss the serious and willful violations mentioned in a Notice of Citations and Penalties. The goal of this meeting is to show that statements about the lack of employee training are incorrect. Hence, the company representatives asked to reduce the penalties proposed by OSHA. At the same time, Acme reassures that some of the violations were fixed or will be resolved without delay.
Reference
Occupational Safety and Health Administration. (2015). Citation and notification of penalty. Web.