You receive a follow-up call from the area director saying the employee filing the original non-formal complaint has provided additional information about the alleged health situation and submitted a formal complaint using the OSHA-7 form, making the complaint a formal complaint. A few days later, an OSHA compliance officer shows up at your facility to perform a comprehensive inspection. The compliance officer presents the proper credentials, and you verify that the compliance officer is employed by OSHA and assigned to the local office.
During the opening conference, the compliance officer provides you with the formal complaint, alleging that employees are exposed to hazardous concentrations of metal fumes in welding areas of the plant, that you have not performed any air sampling to determine exposure levels, that adequate ventilation is not present in welding areas, and that adequate respiratory protection has not been provided to welders. As a part of the inspection, the compliance officer requests the following documents:
chemical inventory list;
OSHA 300 logs;
Hazard Communication Program, including training records;
any sampling data that you have;
Respiratory Protection Program, including medical clearance letters and training records;
written hazard assessment for personal protective equipment (PPE) used at the facility;
Safety Data Sheets (SDSs) for the metals you use in the production process and any welding rods/wire used in
the welding area; and
any other written programs you have that are required by an OSHA regulation.
The compliance officer takes a walk-through tour of the facility, spending extra time in the welding areas. During the walk- through, the compliance officer points out several issues believed to be apparent violations. The issues are as follows:
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