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INSPECTIONS: A few years ago, OSHA cited a major university clinic for wilful violation by exposing its employees to formaldehyde without providing proper protections. OSHA cited the university for eight alleged serious violations of the formaldehyde standard, including:
- Developing a sampling strategy for determining employee exposure to formaldehyde.
- not repeating initial and periodic personal monitoring.
- not providing and ensuring the use of appropriate personal protective equipment.
- not providing medical surveillance and a medical questionnaire for employees exposed to formaldehyde.
- not developing a written hazard communication program for formaldehyde.
- not providing information and training to employees in the hazards of handling formaldehyde.
The alleged serious violations carry a total proposed penalty of $17,500.
In addition, the university was cited for seven alleged other-than-serious violations, including:
- not providing written notice of methods to be used to control exposure to formaldehyde.
- not properly labeling waste and laundry containers.
- not properly labeling containers of hazardous chemicals.
- not providing appropriate waste and spill containment areas for hazardous chemicals.
- not providing eye wash for employees exposed to formaldehyde.
The alleged other-than-serious violations carry a total proposed penalty of $5,000.
A willful violation is defined by OSHA as one committed with an intentional disregard for, or plain indifference to, the requirements of the OSHA act and regulations. A serious violation is defined as a condition which exists where there is a substantial possibility that death or serious physical harm can result. An other-than-serious violation is a hazardous condition that would probably not cause death or serious physical harm, but would have a direct and immediate relationship to the safety and health of employees.
Offices and Clinics of Doctors of Medicine with less than 100 employees
Listed below are the standards which were cited by Federal OSHA during the period October 2006 through September 2007. Penalties shown reflect current rather than initial amounts.
| Standard |
#Cited |
#Insp |
$Penalty |
Description |
| Total |
353 |
94 |
128931 |
|
| 1910.1030 |
259 |
81 |
110871 |
Bloodborne pathogens. |
| 1910.1200 |
51 |
20 |
7423 |
Hazard Communication. |
| 1910.0132 |
9 |
2 |
1825 |
General requirements. |
| 1910.0157 |
7 |
5 |
225 |
Portable fire extinguishers. |
| 1910.0037 |
6 |
5 |
750 |
Maintenance, safeguards, and operational features for exit routes. |
| 1910.0303 |
5 |
4 |
1438 |
General requirements. |
| 1910.0023 |
3 |
3 |
2575 |
Guarding floor and wall openings and holes. |
| 1910.0151 |
2 |
2 |
950 |
Medical services and first aid. |
| 1904.0004 |
1 |
1 |
0 |
Recording criteria. |
| 1904.0029 |
1 |
1 |
0 |
Forms. |
| 1904.0039 |
1 |
1 |
0 |
|
| 1910.0022 |
1 |
1 |
400 |
General requirements. |
| 1910.0024 |
1 |
1 |
0 |
Fixed industrial stairs. |
| 1910.0036 |
1 |
1 |
0 |
Design and construction requirements for exit routes. |
| 1910.0101 |
1 |
1 |
0 |
Compressed gases (general requirements). |
| 1910.0141 |
1 |
1 |
1100 |
Sanitation. |
| 1910.0242 |
1 |
1 |
1375 |
Hand and portable powered tools and equipment, general. |
| 1910.0305 |
1 |
1 |
0 |
Wiring methods, components, and equipment for general use. |
| 1910.1096 |
1 |
1 |
0 |
|
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