Citations And Penalties For Discussion

Running Head: CITATIONS AND PENALTIES

Citations And Penalties For Discussion

Name

Institution

Citations and Penalties to discuss with the area director

In my meeting with the area director of OSHA, I intend to discuss a number of citations and penalties in regard to the letter I received. I will be accompanied by my deputy manager and the Head of engineers in the workplace. First, I will discuss Citation 1 Item 1a that highlights the high-level exposures of lead fumes that were emitted beyond the established permissible exposure level. Upon noting this citation, I immediately carried out my investigations to find out whether an MIG welder in the frame assembly area was exposed to lead at an airborne time-weighted average of 100 µg/m3. In doing this I have sampled some recordings on the level of lead fumes that was emitted in a 400 minute period with an inclusion of a zero increment for the 70 minutes that were not sampled. To my surprise, the reported level in the letter does not tally with my findings. In addition, the existing ventilation systems are in good condition implying that the removal of lead fumes from the frame assembly area is effective. Consequently, the high penalty ought to be revoked or reduced since it does not reflect a true indication of the situation in the ground. However, I plan to install new and modern ventilation systems so as to improve efficiency and workability of the ventilation process.

Second, I will thrash out Citation 1 Item 2 which observes that there was no written program for employees who were exposed to lead and consequently required the wearing of respirators while working in the frame assembly area. In my company, we employ qualified and certified personnel who have gone through the profession and have experience in regard to the requirements. In addition, they are provided with the required gear so that they are protected against any exposure to the lead fumes. Further, upon hiring new employees into our company, they are taken through an orientation program so as to acclimatize with the working environment and its requirements. To support my argument I provide a power point presentation that highlights how my employees dress in their various work points. I, therefore, believe that there is no need for a written program to be in place. The associated penalty to this citation is baseless and therefore, should be canceled. Nevertheless, I will incorporate the written program to act as a reminder of the general requirements.

Third, in reference to Citation 1 Item 10 that remarks the violation for substituting fixed cables with flexible cables which were not secured, I present an argument that situation on the ground is not the same as the reported situation in the Citation and Penalty letter. I have qualified engineers and electricians who are in the workplace all the time to ensure that in the case of any power surge is rectified immediately. In addition, they ensure proper wiring and installation of the electric cables and the sockets. Every cable is insulated and, therefore, the matter of shocks to the employees while working is nonexistence. Moreover, the employees have never complained or suggested of any electrical shocks or change in the wiring systems which is a clear indication the matter raised in this citation and penalty column is out of context and should be waived. To evidence my point of view I present pictures showing the wiring system at the workplace together with happy employees in their work points.

Fourth, and last I will discuss Citation 2 Item 3b that accuses the company of not providing training to the employees in connection with the hazardous substances in the workplace. This accusation is not in order because upon hiring an employee he or she is taken through tutorials and orientations to acquaint him or her to the climate of the workplace and the requirements. Further, he or she is put under a supervisor who trains him or her for a probation period of 3 months before fully placed in his or her work point. In respect to this, I expect all my employees to have the necessary skills and experience to undertake their respective duties. Therefore, the warning ought to be abolished. Conversely, I intend to arrange for a training workshop that will occur twice in a year so that the employees can better and sharpen their skills together with the incorporation of new technologies.

Reference

Järvelä, M., Kauppi, P., Tuomi, T., Luukkonen, R., Lindholm, H., & Nieminen, R. et al. (2013). The inflammatory response to acute exposure to welding fumes during the working day. International Journal Of Occupational Medicine And Environmental Health26(2). http://dx.doi.org/10.2478/s13382-013-0097-z

Levchenko, O. (1998). Methods of reducing the generation of welding fumes (review). Welding International12(9), 747-752. http://dx.doi.org/10.1080/09507119809452048

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