Читать книгу Patty's Industrial Hygiene, Hazard Recognition - Группа авторов - Страница 65

Robert is a CIH and the EHS Manager at a large Midwest refinery for XYZ Energy. The unit operators at the facility are represented by a union and the contract is about to expire. The situation is tense – employees have demanded expensive contract modifications including an eight percent raise and an employer matching funds program regarding pension and management shows no signs of agreeing.

As part of the negotiations, the chair of the refinery health and safety committee, a unit operator, reviews all the OSHA regulations identifying those violations that are applicable in his opinion. He compiles a dossier containing more than 100 suspect violations and submits the document as a complaint to OSHA anonymously.

A team of OSHA inspectors and local police show up at the refinery with a warrant based on information in the dossier. Robert is called immediately and meets with the OSHA team. They inform him that they intend to inspect all the locations in the refinery based on the complaint, but may include other areas as granted by the warrant using OSHA's General Duty Clause. Robert spends the next week accompanying the OSHA inspectors around the site. There is one area of the refinery where a petroleum‐based product is loaded into large transport trucks using a top‐fill technique. Robert has monitored the operator for benzene exposure in this area. This procedure happens several times each week and each time the five parts per million short‐term exposure limit (STEL) for benzene is exceeded. Robert has brought this exposure issue to management and they are reluctant to spend the money to install engineering controls to reduce the exposure. This area was not specifically included in the OSHA complaint and the inspectors have not raised any questions regarding this matter.