IN THE CIRCUIT COURT OF THE CITY OF DANVILLE - c. RAY DAVENPORT, Commissioner of Labor and Industry In re an Inspection Warrant for GOODYEAR TIRE RUBBER cc, 1901 Goodyear Boulevard Danville, VA 24541 MEMORANDUM AND PETITION FOR INSPECTION WARRANT C. Ray Davenport, Commissioner of Labor and Industry (Commissioner Davenport) comes before this Court seeking an inspection warrant of Goodyear Tire Rubber Co. (Goodyear), pursuant to Virginia Code 40.1?49.8 through which authorize Virginia Occupational Safety and Health (V OSH) Of?cers to enter and inspect workplaces to determine conformity with Virginia Occupational Safety and Health laws and regulations.1 1. Goodyear Tire Rubber (30. Commissioner Davenport seeks a warrant to conduct an inspection of all the Alfa Shears in the Tire Room Area of the workplace of Goodyear, located at 1901 Goodyear Boulevard, 1Code 40.1-49.9 authorizes this Court to consider warrant applications in an. ex parte manner. This statute, copied below, requires an af?davit for the Commissioner, but does not require notice or an opportunity for a hearing for the employer. In fact, the employer may not challenge the warrant prior to its return to the issuing judge, except as a defense to a contempt proceeding or upon a showing that false statements were made to the issuing judge. Code 40.1- 49.12. Marshall v. Barlow/s", Inn, 436 US. 307, 320 n. 15 (1978), af?nned that exports proceedings to secure a Warrant do not violate an employer?s Fourth Amendment rights. Danville, VA 24541 and of any records or reports that VOSH laws and regulations require Goodyear to keep. As set forth in the accompanying af?davit of VOSH Compliance Of?cer Russell Bambarger, William Scheier, a maintenance employee of Goodyear died on Friday, August 12, 2016, when Alfa Shear 16 operated While his body was inside the machine adjusting a proximity switch. The back end of the cutter head of Alfa Shear 16 struck Mr. Scheier as it returned to the home position causing his fatal injuries. Commissioner Davenport through his designated representatives, Montgomery Beasley and Stewart Henderson, opened an inspection on August 12, 2016. Mr. Bambarger took over the inSpection on August 1.5, 2016 ?om Mr. Beasley and Mr. Henderson. He was later joined on the inspection on August 22, 2016 by Compliance Of?cer Robert Farmer. During interviews of employees and supervisory personnel of Goodyear, Mr. Bambarger and Mri Farmer learned that when the reset button is pressed on Alfa Shear 1'6 and other Alta Shears in the Tire Room Area the cutter head returns to the home position. Some of the employees and supervisors said they did not become aware that the shear?s cutter heads would return to home when'the reset button was pressed until after the fatality of Mr. Scheier. The potential for injury in a similar circumstance exists in each of the other Alfa Shears in the Tire Room Area. He reported these additional hazards to his supervisor, Mr. Willis. Based on this information Director Willis expanded the scope of the inspection to include all of the Alfa Shears in the Tire Room Area to determine compliance with safety and health standards for each of those pieces of equipment in addition to Alfa Shear 16 where the accident occurred. VOSH Standards require that machines or equipment be locked out or tagged out when repairs or maintenance is being performed on the equipment. This prevents the machine from being operated when a maintenance person is repairing the machine and exposing that person to a hazard. As part of his inspection, MrrBaInbarger sought to have the machine where Mr. Scheier was killed, Alfa Shear 16, turned off and have the proper lockout or tag out procedure be demonstrated. Jim Lane, Goodyear?s Regional Safety Director told Mr. Barnbarger they would not demonstrate lockout procedures for Alfa Shear 1d. Later, Mr. Bambarger requested that Alfa Shear l6 simply be turned off, with the cutter head not in the home position, so the reset button could be pressed both while the power was off in the machine and after the power was restored. Mr. Lane denied his initial request saying they could not disrupt production. During interviews of Goodyear supervisors on August 30, 2016, Mr. Bambarger repeated his request to have Alfa Shear 16 shut down to demonstrate the lookout procedures and to view the effect of the reset button to Patrick Lewis, a Littler Mendelson Attorney who was representing Goodyear in the interviews. Mr. Lewis denied him permission as well. I B. Scope of the Inspection Commissioner Davenport?s warrant petition applies to all of the Alfa Shears in the Tire Room area of Goodyear, located at 1901 Goodyear Boulevard, Danville, VA 24541, and to any records or reports required to be kept by VOSH laws and regulations. Virginia Code 40.1?49.3 provides legislative authority to conduct an inspection to determine conformity with VOSH laws and regulations. Part of that Code section allows the Commissioner to inspect and investigate all pertinent machines and equipment within reasonable times and within reasonable limits. To properly investigate the accident that occurred in Alfa Shear 16, the Commissioner needs to observe the machine being shut down and lockout and or tag out procedures being followed. While the machine is completely powered off the Cummissioner needs to see the effect of the reset button being pressed while the cutter head is not in the home position. When the machine has the power restored, the Commissioner needs to see the effect of the reset button being pressed While the cutter head is not in the home position. The same two tests need to be performed on three of the following Alfa' Shears in' Tire Room Area to investigate those machines during a shutdown: Ali?s. Shear 1, 4, S, 6, 8, 9, 11,12, 13, 14 and 15. As part of any inspection, Commissioner Davenport?s inspectors may assess the employer?s written record of injuries and illnesses, several programs relating to speci?c standards, and the employer?s overall safety and health management program, as authorized under Code 4016(7). Further specifying the powers and duties of the Commissioner under Code 40.1? 49.8, the VOSH Administrative Regulations Manual (VOSHARM), at 16 VAC 25?60-2402, provides that: As part of an inspection, the Commissioner may take or obtain photographs, video recordings, audio recordings, and samples of materials, and employ other reasonable inVestigative techniques as deemed appropriate. As used herein, the term ?employ other reasonable investigative techniques" includes, but is not limited to, the use of devices to measure employee exposures and the attachment of personal sampling equipmentisuch as dosimeters, pumps, badges and other devices to employees in order to monitor their exposures. VOSHARM 16 VAC 25?85?1904 further allows the Commissioner to review all accident, injury, and occupational ?illness records, and. other such records as are required by Code 40.1450). II. APPLICABLE LAW A. Background United States Supreme Court precedent establishes that a warrant is required under the Fourth Amendment for administrative entry onto private property. Camara v. Municipal Court, 387 U.S. 523 (1967) (housing code inspection of a dwelling); Sec V. Seattle, 387 U.S. 541 (1967) (housing code inspection of a commercial structure). However, Camara and See also establish that the standard of probable cause necessary to justify issuance of an administrative search warrant is lower than that required for a criminal search warrant. Where considerations of health and safety are involved, an inference of probable cause can be drawn even without a showing of cause to believe that substantial dangerous conditions exist. Camera, supra p. 538. The United States Supreme Court examined the standard of probable cause necessary for OSHA inspections in Marshall v. Barlow 15?, Inc, 436 U.S. 307, 320 (1978), and reaf?rmed the holdings of Camam and See: . [The] entitlement to inspect will not depend on . . . demonstrating probable cause to believe that conditions in violation of OSHA exist on the premises. Probable cause in the criminal law sense is not required. For the purposes of an administrative search such as this, probable cause justifying ?the issuance of a warrant may be based not only on speci?c evidence of an existing violation but also on a showing that 'reasonable legislative or administrative standards for conducting an inspection are satis?ed with reapect to a particular [establishment]! [emphasis added]. In the Fourth Circuit, Barlow?s has been interpreted as authorizing two methods of establishing probable cause. Upon application for an administrative search warrant, a judge can base probable cause on a ?nding of either "particularized" evidence of violations on the premises, or on'an administrative plan. In re Establishment Inspection of Seaward Int?l, Inc, 510 F. Supp. 314 (WD. Va. 1980), 644 F.2d 880 (4th Cir. 1981). B. Virginia Statutory Framework In Virginia, issuance of Virginia Occupational Safety and Health (V OSH) inspection warrants for work sites is governed by the standards set forth in Code 40.1-49.9, which provides as follows: Administrative search warrants for inspections of workplaces, based upon a petition demonstrating probable cause and supported by an af?davit, may be issued by any judge having authority to issue criminal warrants whose territorial jurisdiction encompasses the workplace to be inspected or entered, if he is satis?ed from the petition and a?idavit that there is reasonable and probable cause for the issuance of an administrative search warrant. No administrative search warrant shall be issued pursuant to this chapter except upon probable cause, supported by af?davit, particularly describing the place, things or persons to be inspected or tested and the purpose for which the inspection, testing or collection of samples for testing is being made. Probable cause shall be deemed to exist if either reasonable legislative or administrative standards for conducting such inspection, testing or collection of samples for testing are satis?ed with respect to the particular place, thing or person or (ii) there is cause to believe that there is a condition, object, activity or circumstance which legally justi?es such inspection, testing or collection of samples for testing. The supporting af?davit shall contain either a statement that consent to inspect, test or collect samples for testing has been sought. and refused or facts or circumstances reasonably justifying the failure to seek such consent in order to enforce effectively the occupational safety and health laws, regulations or standards of the Commonwealth which - authorize such inspection, testing or collection of samples for testing. In the case of an administrative search warrant based on legislative or administrative standards for selecting workplaces for inspection, the af?davit shall contain factual allegations suf?cient to justify an independent determination by the judge that the inspection program is based on reasonable standards and that the standards are being applied to a particular workplace in a neutral and fair manner. For example, if a selection is based on a particular industry's high hazard ranking,- the af?davit shall disclose the method used to establish that? ranking, the numerical basis for that ranking, and the relevant inapection history of the workplace to be inspected and the status of all other workplaces within the same territorial region which are subj act to inspection pursuant to the legislative or . administrative standards used by the Commissioner. The af?davit shall not be required to disclose the actual schedule for inspections or the underlying data on which the statistics were based, provided that such statistics are derived from reliable, neutral third parties. The issuing judge may examine the af?ant under oath or af?rmation to verify the accuracy of any matter in the af?davit. [emphasis added] Code 40.1-49.8 provides legislative authority for such an inspection to determine conformity with Virginia Occupational Safety and Health laws and regulations. This section authorizes the compliance of?cer, with consent or by appropriate warrant: (1) To enter without delay and at reasonable times any factory, plant, establishment, construction site, or other area, workplace or environment where work is performed by an employee of an employer, and (2) To inspect, investigate, and take samples during regular working hours and at other reasonable times, and within reasonable limits and in a reasonable manner, any such place of employment and all pertinent conditions, structures, machines, apparatus, devices, equipment, and materials therein, and to question privately any such employer, owner, operator, agent or employee. Code empowers the Commissioner of Labor and. Industry to: that accident, injury and occupational illness records and reports he kept at any place of employment and that such records and reports he made available to the Commissioner or his duly authorized representatives upon request. Further, he may require employers to develop, maintain and make available such other records and information as are deemed necessary for the proper enforcement of [Title 40.1]. As set forth below in the accompanying af?davit, probable cause, based upon Commissioner Davenport?s application of reasonable legislative and administratiVe standards, exists in this case and justi?es the issuance of an inspection warrant. 111. PETITION FOR WARRANT A. Statement of Probable Cause for Warrant I Commissioner Davenport seeks an inepection warrant pursuant to Code (reasonable legislative or administrative conducting such impaction). As set forth with particularity inthe attached af?davit, based on routine Virginia Occupational Safety and I Health scheduling practices, Regional Safety Director Lee A. Willis assigned Compliance Safety and Health Of?cers Russell Bambargcr and Robert Farmer to conduct an inspection into the fatal accident that occurred at Alfa Shear 16 on August 18, 2016 at the worksite of Goodyear Tire Rubber Co. at 1901 Goodyear Boulevard, Danville, VA 24541. As indicated in the attached af?davit, the compliance of?cers learned in interviews with Goodyear employees and supervisors that the other Alfa Shears in Tire Room Area would return to home when the reset button was pressed. This presented the same employee safety concerns that resulted in the death of William Scheier. The compliance of?cers reported the potential hazards to Region Safety Director Lee Willis who based on the procedures set forth in the VOSH FieldOperations Manual (POM) at Chapter 5.1 .B. expanded the inspection to include all the Alfa Shears in Tire Room Area. Compliance Of?cer Bambarger, following Virginia Code 40.1-49.8, sought to investigate and inspect the cause of the accident. To properly investigate the cause of the accident at Alfa Shear 16, the machine must have all sources of power shut down and proper lock out or tag out procedures applied during the de?energization. Discovering how the cutter head operates when the reset button is pushed is required for a proper investigation of the machine and its operation. B. Refusal of Entry Lead Safety Compliance Of?cer Bambarger asked to have the machine where Mr. Scheier was killed, Alfa Shear 16, turned off and have the proper lockout or tag out procedure be demonstrated. Jim Lane, 'Goodyear?s Regional Safety Director told Mr. Bambarger they would not demonstrate lockout procedures for Alfa Shear 16. Later, Mr. Bambarger requested that Alfa Shear 16 simply be turned off, with the cutter head not in the home position, so the reset button could be pressed both While the power was off in the machine and after the power was restored. Mr. Lane denied his initial request saying they could not disrupt production. During interviews of Goodyear supervisors on August 30, 2016, Mr. Bambarger repeated his request to have Alta Shear 16 shut down to demonstrate the lockout procedures and to View the effect of the reset button to Patrick Lewis, a Littler Mendelson Attorney who was representing Goodyear in the interviews. Mr. Lewis denied him permission as well. C. Reasonableness of the Requested Testing The Commissioner?s request to test Alpha Shear 16 and three other Alfa Shears in the Tire Room Area will not place an undue burden on Goodyear as their operators and maintenance personnel are regularly required to de?energize Alfa Shears and properly follow lockout procedures during Operations and maintenance on the machines. Such a shutdown would'not be and could be performed during a regularly scheduled period of maintenance or shutdown of the machine. The need for the tests on the additional machines is further justified to prevent a recurrence of the fatal accident by assuring that the effect of the reset button is consistent on all machines tested and not an anomaly on Alfa Shear 16. Some of the Goodyear employees and supervisors were not aware of the possibility that the shear?s cutter head could return home when the reset button is pushed. One employee indicated that the reset button on Alfa Shear 16 would return the cutter head to the home position, even when all power to the machine was locked out. IV. CONCLUSION Commissioner Davenport seeks an inspection warrant authorizing eXpansion of the scope of the inspection into all the Alfa Shears in Tire Room Area of the ivorkplace of Goodyear Tire Rubber Co. at 1901 Goodyear Boulevard, Danville, VA 24541, for the purpose of conducting an occupational safety and health inspection. As part of the inspection the warrant will require that Alfa Shear 16 and three other Alta Shears be turned off and locked out or tagged out with the cutter head not in the home position, so that the reset button can be pressed while the power is off and once the power is restored. . Respectfully submitted, C. RAY DAVENPORT, Commissioner of Labor and Industry Street, Suite 200 Danville, Virginia 24541 Phone: 434! 797?1635 Fax: 434! 797-4809 Commonwealth of Virginia At Large, To Wit: AFFIDAVIT . I, Russell Bambarger, hereby state as follows: I am employed by the Commonwealth of Virginia, Department of Labor and Industry as a Virginia Occupational Safety and Health (V OSH) Lead Compliance Safety Of?cer in the Department?s Southwest Region. The Southwest Region is headquartered in Roanoke and Compliance Officers from this of?ce inspect establishments in the City of Danville My duties presently require me to assign VOSH inspections for the Southwest Region, under Virginia Code 40 1- 49. 8. Commissioner Davenport seeks an inspection warrant authorizing entry into the workplace of Goodyear Tire Rubber Co. located at 1901 Goodyear Boulevard, Danville, VA, for the purpose of conducting an occupational safety and health inspection of the Alfa Shears 1n the Alfa Shear area of the facility. The Commissioner 5 repiesentative intends to inspect and investigate the workplace, and to review records required to be maintained by VOSH regulations 1910.20, 1910.146, 1910.147, 1910.1200 and 60.A of the VOSH Administrative Regulations Manual, and to question privately any employer, owner, operator, .agent or employee on the premises to determine whether the workplace is in conformity with the Virginia Occupational Safety and Health laws and regulations. Particular hazards that could be encountered include lockout/tag out hazards. - Commissioner Davenport seeks to conduct a full inspection and investigation of the machine in which William Scheier died. To properly investigate the accident that occurred in Alfa Shear 16, the Commissioner needs to observe the machine being shut down and apprOpriate lockout and or tag out procedures being followed. While the machine is completely powered off the Commissioner needs to see the effect of the reset button being pressed while the cutter head is not in the home position. When the machine has the power restored, the Commissioner needs to see the effect of the reset button being pressed While the cutter head is not in the home position. The same two tests need to be performed on three of the following Alfa Shears in Tire Room Area to investigate those machines .during a shutdown: Alfa Shear 1, 4, 5, 7, 8-, 9, ll, 12,13,14 and 15. I. ADMINISTRATIVE STANDARDS USED FOR ASSIGNING INSPECTION Regional Safety Director Lee Willis assigns inspections of establishments for VOSH compliance inspections under Code 40.1-49.8, according to the following priorities as listed in Chapter 3- of the VQSH Field. Operations Manual: - I. First Priority imminent danger situations 2. Second Priority fatalities\catastrophes 3. Third Priority complaints or referrals 4. Fourth Priority - ?rst report of accident inspections 5. Fifth Priority - follow-upfmonitoring 6. Sixth Priority general schedule inspections Mr. Willis assigned the present inspection under the second priorityas a fatality inspection, there being no higher priority inspections pending for assignment. II. FACTS PERTTNENT TO EXPANDING THE SCOPE OF THIS INSPECTION Fatality investigations are a complete investigation of the circumstances of the accident under FOM Chapter 7, Section 1.0.1. That section also allows the Regional Safety Director to expand the scope of the inspection. During interviews of employees and supervisory personnel of Goodyear, I learned that when the reset button is pressed on Alfa Shear 1.6 and other machines in the Alfa Shear area the cutter head returns to the home position. The Alta Shear area is also called Tire Room Area by Goodyear". Some of the employees and supervisors said they did not become aware that the Shear?s cutter heads would return to home when the reset button was pressed until after the fatality of Mr. Scheier. The potential for injury in a similar circumstance exists in each of the other Alfa Shears in Tire Room Area. JUSTIFICATION FOR DIRECTING SHUTDOWN OF ALFA SHEAR 16 AND SIMILAR ALFA SHEARS Virginia Code 40.1 49.8 directs the Commissioner to investigate and inSpect machines and equipment at reasonable times and within reasonable limits and in a reasonable manner. Under the provisions of Chapter .7, Section 1.8.4 of'the FOM, the investigation of a fatality shall determine the cause of the accident; whether the accident was related to a violation of VOSH safety or health standards; and what effect the violation (if any) of a stande had on the occurrence of the accident. To properly investigate the cause of the accident at Alfa Shear 16, the machine must have all sources of power shut down and proper lock out or tag out procedures applied during the de? energization. Discovering how the cutter head operates when the reset button is pushed is required for a proper investigation of the machine and its operation. As part of myinspection, I sought to have the machine where Mr. Scheier was killed, Alfa Shear 16', turned off and have the proper lockout or tag out procedure be demonstrated. Jim Lane, Goodyear?s Regional Safety Director told me they would not demonstrate lockout procedures for Alfa Shear 16. Later, I requested that Alfa Shear 16 simply be turned off, with the cutter head not in the home position, so the reset button could be pressed both while the power was off in' the machine and after the powerwas restored. Mr. Lane denied my initial request saying they could not disrupt production. Durlng Interviews of Goodyear supervisors on August 30, 201-6, I repeated my request to have Alta Shear 16 shut deem to demonstrate the lookout procedures and to view the effect of the reset button. to Patrick Leads, a Littler Mendelson Attorney who was representing Goodyear in the intewiews. Mr. Lewis denied me permission as well. Some of the Goodyear employees and supervisors I interviewed were not aware of the possibility that the shear? cutter head could return home when the reset button is pushed. One employee indicated that the reset button on Alfa Shear 16 would return the cutter head to the home position, even when all power to the machine was locked out. Tests on the additional machines can prevent a recurrence of the fatal accident by assuring that the effect of the reset button is consistent on all machines tested and not an anomaly on Alfa Shear 16. The tests Alpha Shear 16 and three other Alfa Shears in the Tire Room Area will not place an undue burden on Goodyear as the operators and their maintenance personnel are regularly required to de?energize Alfa Shears and properly follow lookout procedures during operations and maintenance on the machines. Such a shutdown would not take a long time and could even be performed during a regularly scheduled period of maintenance or a shutdown of the machine. Ihave read the above statement, consisting of three (3) pages, and swear it is true to the best of my knowledge and belief. Russell Bambarger, Southwest Region Lead Safety Compliance Of?cer The foregoing instrument was acknowledged before me this 13% day of September, 2016 by Russell B'ambarger, Southwest Region Lead Safety Compliance Of?cer, for the Department of Labor and Industry. taryP bl' - 11 1c My Commission expires: 60? 3?0ch jiblitilill-Ef?5555?; Naked] fa??ot/tmw Nat/micro 344? VIRGINIA: THE CIRCUIT COURT OF THE CITY OF DANVILLE C. RAY DAVENPORT, Commissioner of Labor and Industry an Inspection Warrant for GOODYEAR TIRE RUBBER CO. 1901 Goodyear Boulevard Danyille, VA 24541 INSPECTION WARRANT On thisdate comes the Commissioner of Labor and Industry, by counsel, before this - Court seeking an inspection warrant pursuant to. Virginia Code 40.1-49.8 and 40.1-49.9. This Court, upon the application of the Commissioner and supporting af?davit, ?nds as follows: 1. The Commissioner of Labor and Industry has a statutory duty to carry out, through his authorized representatives, occupational safety and health inspections at places of employment in Virginia. 2. Virginia Occupational Safety and Health Regional Safety Director Lee Willis, observing reasonable administrative procedures applied in a fair and neutral marmer, assigned Compliance Of?cers to conduct an occupatiOnal safety and health impaction of Goodyear?s workplace in Danville, Virginia focusing on the accident that led to the death of William Scheier in Alfa Shear 16. 3. Based on the similar hazards that existed in all the Alfa Shears in the Tire Room area of the Goodyear plant, Regional Safety Director Lee Willis, following administrative procedures appropriately expanded the scope of the inspection to all the Alfa Shears in the Tire Room area. 4. Probable cause, based on Goodyeat"s repeated refusal to allow the Commissioner?s representatives to conduct reasonable inspection and investigation of Alfa Shear 16, where the fatality occurred, exists to justify the issuance of an inspection warrant requiring - Goodyear to shut down Alfa Shear 16 while the cutter head is not in the home position, follow lockout and or tag. out procedures during the shutdown, press the reset button with the machine completely powered off, and press the reset button once the machine is powered up again and the backend of the of the cutter head is not in the home position. WHEREFORE, the Court orders the Commissioner within ?fteen (15) days of the signing of this order to enter, without delay, the workplace of Goodyear, Inc?s workplace at 1901 Goodyear Boulevard, Danville, VA 24541, and to conduct an inspection of the Alfa Shears the Tire Room Area. The Court further orders Goodyear to allow the Commissioner to observe Alfa Shear 16 being shut down and lockout and or tag out procedures being followed. Further, while the machine is completely powered off Goodyear shall press the reset button while the cutter head is not in the home position allowing the Commissioner to view its effect. When the machine has the power restored, Goodyear shall press the reset button while the cutter head is not in the home position allowing the Commissioner to view its effect. The same tests need to be performed on three of the following Alfa Shears in the Tire Room to investigate these machines during a shutdown: Alfa Shear 1, 4, 5, 6, 7,8, 9, 11, 12, 13, 14 and 15. This occupational safety and health inspection of the workplace is to be conducted during regular working hours and other reasonable times, and within reasonable limits and in a reasonable manner, to inspect, investigate, take samples, photographs, videotape footage, measurements and notes of all pertinent conditions, structures, machines, apparatus, devices, equipment, and material therein, to . review records required to be maintained by Code 40.160), and to question privately any employer, owner, operator, agent or employee on the premises. This order shall expire ?fteen (15) days from the date of its issuance. a The Commissioner shall note the date(s) of execution of this warrant upon its faee and return it to the Clerk for ?ling. So ORDERED this get as orgjgug ,2016. Judge I ask for this: I Mic aetleewman Co onwealth?s Attorney City of Danville 341 Main Street, Suite 200' Danville, Virginia 24541 Phone: 434/ 797?1635 Fax: 434/ 797-4809 IN THE CIRCUIT COURT OF THE CITY OF DANVILLE C. RAY DAVENPORT, Commissioner of Labor and Industry . In re an Inspection Warrant for . af?r?: '1 Ni "n we GOODYEAR TIRE RUBBER 1901 Goodyear Boulevard, {:1ng Danville, VA 24541 ?smile; :33 we- '7 r; Wt RETURN I, ?ns/6W began an occupational safety and health inspection of the workplace in question on this 2 day of mgpl?. VOSH Compliance Of?cer was