EXEMPTIONS FREEDOM OF INFORMATION ACT 5 U.S.C. SECTION 552 Exemption 2 Documents related solely to the internal personnel rules and practices of an agency. Exemption 4 Trade secrets and commercial or financial information obtained from a privileged and confidential source. Exemption 5 Interagency or intraagency memoranda or letters that would not be available by law to a party other than an agency in litigation with the agency. Exemption 6 Personnel, medical, and similar files, of which the disclosure of would constitute a clearly unwarranted invasion of personal privacy. Exemption 7(A) Could reasonably be expected to interfere with enforcement proceedings. Exemption 7(8) Would deprive adjudication. Exemption 7(C) Could reasonably constitute an unwarranted invasion of personal privacy. Exemption 7(0) Could reasonably be expected to disclose the identity of a confidential source, including a State, local, or foreign agency or authority, or any private institution that furnished information on a confidential basis. Exemption 7(F) Could reasonably be expected to endanger the life or physical safety of any individual. a person of a right to a fair trial or an impartial ATTACHMENT 2 LISTING OF EXEMPTIONS RAANI CORPORATION -INSPECTION #110113 1. Inspection Form (specific items), 9 pages - Exemptions 4, 5 and 7c 2. Investigation Form (specific items), 3 pages - Exemption 7c 3. Narrative (specific items), 4 pages - Exemptions 5 and 7c 4. Unprogrammed Activity Form (specific items), 3 pages - Exemption 7c 5. Violation Worksheet (specific items), 40 pages - Exemption 4, 5, and 7c 6. Willful Worksheet (entire document), 41 pages - Exemption 5 Inspection. Page ~ ,. " .FWAL- '-~IJ ~r Establishment Raanl Corporation Name: Inspection 110113 Number: .: RID: 0521700 . Inspection Information . ; o CSH()" Info?: .-. . .- -. I . ."",'" : ;CSHO 1['" t--~. I Accompanied By: c.....- I ~. ! . _ _.. . - - - .. CSHO Job Title: 62 Optional Report Number: : Supervlsor*: S6202 ~- ; Related Activities - . i j"A;ti0tY N~mber Activity Type ; : 83889 Satisfied .. EstabName Raani Corporation FA TICA TIAccident ,: : Related Inspections ... Concurrent Inspections I ; . :In?;;;;cti~~ Nu~b~~-?? : ! . 242952 191970 Joint-Employer Inspections .. : insPection 'N~mb~;-'- Estab Name "."--'9 ; f ' .- .. " - .. <:..L...... .- . ' ''7 '? '-" Estab Name -- ..- Previous/Subsequent Inspections- ' . : Inspection Number Previous/Subsequent s . Site Address Information Estabirsilll';e~t Intormation . -- - --_._-_ . .-.. , , I i , . Establishment Raani Corporation Name: Establishment DBA: Establishment ID: 7928902 Ownership: Private Sector Primary NAICS: 325620 - Toilet i : Typ.e of Business: Corporation prepar.'l~on M~n.l:lf~~~n~ Business Address - ...... ..... _Street Address 1: 5202 West 70th Place Street Address 2: . County: COOK Zip Code: 60638 Country: UNffiO STATES OF AMERICA : ! E-mail Address: Phone Number: 7084968025 State: IWNOIS City: BEDFORD PARK Fax: 708-496?8906 Mailing Address ' . -, Street Address 1: 5202 West 70th Place Street Address 2: Country: UNffiD STATES OF AMERICA State: ILliNOIS -. - . - City: BEDFORD PARK County: COOK Zip Code: 60638 Site Information Type Of 8usiness: Mfg Toiletries Street Address 1: 5202 West 70th Place Temporary/Fixed: Fixed Street Address 2: Primary NAlCS: 325620 - Toilet Preparation Manufacturing SIC Inspected: , .. /I o City: BEDFORD PARK ILliNOIS ." i ... . ... ~ 71! -.~ : ' .- Multi-Employer Inspections , Inspection Number .1 of9:. \ ... Page 2 of9 Inspection . State! . . Phone fJUriilier: 708'-496-8025 County: COOK Mobile Number: Zip Code: 60638 Fax Number: 708-496-8906 Employment Information # Controlled by 175 Employer: # Employed in 175 Estab: # Covered by 175 Inspectfon: : ~s~~~o.!! .l?a~!!s Citations Issued: No No denial of entry. Advance Notice: No Number of Days on 6 Site: Case Closed Date: Dates - - - - - -- - ? -?------ -- - .. _ .Entry Date: 12/12/2011 TIme: 09:30 AM Walk Around : 12/12/2011_ TIme: 11:00 AM Exit: 12/12/2011 TIme: 12:30 PM TIme: 09:30 AM Opening 12/12/2011 Conference: 1ime: Closing Conference 1: 1ime: Closing Conference 2: Candidate for Follow-Up Inspection ' . -- - Flag as candidate For Yes Follow-up: Reason for follow up: Willful violations Issued I Inspection Type Information Initiating Fatality/Catastrophe Type: Secondary Types: Other: Enhanced Enforcement Yes Program: Partnership Program: Migrant Farm Worker: No Inspection Category: Health Scope of Partial Inspectfon: Reason No Inspection : .Explanation: .Sampllng No Performed: National Inspection Programs SVEP (SEVERE VIOLATORS ENFORCEMENT NEP PROGRAM) State/Local Inspection Programs . FORKUFT (POWERED INDUSTRIAL TRUCKS - SAFETY HAZARDS) PIV (POWERED INDUSTRIAL VEHICLES - SAFETY HAZARDS) Strategic Plan Activity :-- Federal Strategic Initiative:' - ._ o o o '4. o o . 0 o o _ o oo o o _ oo ooo o o_ o _ ,..... o ooo o :. . ELECTRICAL FALL FROM HEIGHT , POWERED IND VEHICLE HISPANIC Additional Codes - . . "/1 1 n() 1 'J Page 3 of9 Inspection , Type !N , N VlI1~- Id 08 .. - DeWfp1t071' -- ' - - .. - ...... ... - .. ..... - --.- . S/GCASE Significant Inspection (Private Sector & Federal Agency) - The Primary Inspection _._ IMMLANG- Y All t:A inve?t1g~tions & related OSHA-(,_ - enter ifwo,! Injury Illnes# Business Address I .' I County: COOK Street Address 1: 5202 West 70th Place ?I I! Street Address 2: ?' r . j E-mail Address: Country: UNITED STATES OF AMERICA ?, .. Zip Code: 60638 ., Phone Number: 7084968025 State: IlliNOIS ..~~: .BED~-'-____ _ __ V_eritv Employee Exposure Name and Address Telephone Numbers Exposure Instance 2 I Two Duration Frequency 4.00 hour Daily 4.00 hour daily 4.00 hour -e r Daily Proximity at ---- I At I -7 ~ 2 ~ -- ------ -- --- At -I eI 20. Instance Description: A. Hazard B. Equipment C. Location D. Injury/Illness E. Measurements ] a) Hazards-Operation/Condition-Accident: When the CSHO arrived on site December 13, 2011, unnanounced, she was brought to the compounding area where Carlos Centeno was injured. The CSHO was hardly able to access the M02 tank because the floors were absolutely covered in a slick and thin layer of evidently product. While accessing the area, the CSHO slid her feet along the floor to reduce the liklihood of falling. Employee interviews found that the unexpected visit found the usual state of the floors. After the initial visit, the employer made effort to ensure that the floors were not in that condition. The employer also had a practice of cleaning process tanks with the bottom valve open which resulted in all liquid entering the tank to be ran onto the floor and eventually a floor trench. The water generated did not just roll directly to the trench, it remained in large spots where employees had to maneuver on a daily basis. Employee interviews found that this was a normal status for the floors. b) Equipment: Apply proper non slip coating for floors. Or, clean floors more regularily. Also, discontinue the use of draining contents to the floor. Use piping or a hose to drain directly to the trench so the floors stay dry. c) Location: Compounding d) Injury/Illness (and Justifications for Severity and Probability): Broken bones, bruises e) Measurements: 23. Employer Knowledge: The employer accessed the same work areas on a daily basis. In addition, the employer required employees to drain the contents of tanks which were being cleaned to the floor. 24. Comments: 25. Other Employer Information: In 2008 and employee working in the compounding department slipped and fractured his left shoulder. See OSHA 300 log. U.S. Department of Labor Occupational Safety and Health Administration Violation Worksheet Print Date: 05/01/2012 110113 Inspection Number Opt. Insp. Number Raani Corporation Establishment Name Serious Type Of Violation , ,J Number Expose, Special Enforcement? ---------~--? 1 Item/Group 3 / Citation Number No. Instances REC Employer's Relationship to Hazard -- Standard All 1910.106(e)(6)(ii) --- -- Substance Codes Alleged Violation Description ----- --- ---- ----.------.------.- - - - -- - -.- -.---- --- DBA Name ~ -lI ---- 29 CFR 1910.106(e)(6)(ii): "Grounding." Class I liquids shall not be dispensed into containers unless the nozzle and container are electrically interconnected. Where the metallic floor plate on which the container stands while filling is electrically connected to the fill stem or where the fill stem is bonded to the container during filling operations by mea ns of a bond wire, the provisions of this section shall be deemed to have been complied with a. On or about January 26, 2012, employees were exposed to fire and explosion hazards while splash loading Steol CS-460, a Class r flammable liquid containing ethanol, into a production tank without the proper use of bonding and grounding. -- - -Recommended Abatement Action - -- --- -- ------ - - ---_._--- ----- - --- ----------- Penalty Severity High Probability Lesser Gravity Moderate Size Gravity based Penalty 5000.00 Good Faith -- History Num Times Repeated Multiplier 1 5000.00 Proposed Penalty f.K~ Quick Fix Calculated Penalty - _._---- -- Proposed Penalty Justification: Abatement Details 15000.00 - - - -- - - - - - - '- ,..---' r------ - --------_.. _.--_._--_._._- _.--.- .- - - - - -_.- Date Abated User-entered Abatement Due Date Date Verified Yes Abatement Documentation Required? _ .._---- - _._ Abatement Status 10 Wkg Days Days to Abate Abatement Completed Description: -- -------- MultiStep Abatement Days to abate Type/Other Type User entered Abatement Due Date Employee Exposure Exposure Instance Name and Address Telephone Numbers 1 I .. I I /At I I 10.00 minute , I daily I (v Proximity -.-- - - - - - - - _ . _ - 10.00 minute I. Verify Date Frequency Duration ----- - - -- - -.-- - - Twice Twice Completed (status) Daily At 70 20. Instance Description: A. Hazard B. Equipment C. Location D. Injury/Illness E. -Measurements =oJ a) Hazards-Operation/Condition-Accident: While employees were standing on an unguarded working platform elevated by a PIV, they tilted a drum containing Steol CS-460 a Class I flammable (FP 78F) and splash loaded it into a large production tank through an open hatch. The employees did not use proper bonding and grounding while transferring the flammable liquid. The employer did not have any means available for bonding and grounding, i.e. bond wires. b) Equipment: Bond/ground wires c) Location: Entire facility d) Injury/Illness (and Justifications for Severity and Probability): Burns, fires e) Measurements: 23. Employer Knowledge: The employer assigned the employees to add the flammable liquid to the production tank. The employer had MSDS's on site which explained the material was flammable. 24. Comments: 25. Other Employer Information: U.S. Department of Labor Occupational Safety and Health Administration Violation Worksheet Print Date' 05/01/2012 110113 Inspection Number Opt. Insp. Number Raani Corporation Establishment Name DBA Name Type Of Violation Citation Number if- Number Exposed Special Enforcement? Standard 1 Item/Group 4/ No. Instances Serious 1 REC FAT/CAT/Accident Employer's Relationship I to Hazard All -- - -- 1910_ 132(d)(1) ------- Substance Codes Alleged Violation Description -------- 29 CFR 1910.132(d)(1): The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE): a. On or about November 17,2011, in the facility, employees were required to work with heated water/cleaning solutions and hazardous chemicals, including but not limited to, sodium hydroxide. The employer failed to perform a hazard assessment to determine which hazards were present which necessitated the use of PPE. Recommended Abatement Action Penalty Severity High Probability Greater Gravity High Size Gravity based Penalty 7000.00 Good Faith C/'f, . b Num Times Repeated History Multiplier 1 Quick Fix Calculated Penalty 7000.00 Proposed Penalty Proposed Penalty Justification: Abatement Details - -- - 17000.00 -.- I ----1 - 30 Wkg Days Abateme~tSt~tus ----------------, ------------------- ---------------------1---- - - - - - - - - ----Date Abated User-entered Abatement Due Date Days to Abate f---- ---_._---- --_._---_.- ~------- ' - -------------_._._-- Date Verified Yes Abatement Documentation Required? Abatement Completed Description: MultiStep Abatement Days to abate Type/Other Type - - Employee Exposure - Name and Address Telephone Numbers Exposure Instance r.-Daily User entered Abatement Due Date r ' 8.00 hour I Verify Date ..--------- ---------- ---, Duration - -- - - ----- --------------- - - - - - - -- Completed( status) Frequency 1------- --- - - - - - Daily I Proximity I , --------------l At I ~L I 8.00 hour Daily 8.00 hour Daily At 8.00 hour Daily At Daily 8.00 hour Daily Daily 8.00 hour Dally At At I At Daily Daily I 7c -f I Daily C- I fC .- .- 120. Instance Desc-ri-p-t?-Io-n-:-_---A-:.-_~-_a-z=a=r~-~B-.-Eq-U-iP~ent _ C. ----- Locat~?_~ __ _Inj:!ry~!_"n_es_s_~_._M_ea_:urements D. a) Hazards-Operation/Condition-Accident: The employer required that employees work with hazardous chemicals and extremely high temperature water/cleaning solutions. The employer failed to assess the hazards associated with the use of these materials which necessitated the use of PPE. b) Equipment: PPE assessment c) Location: Entire facility _ d) Injury/Illness (and Justifications for Severity and Probability): Death, scald burns, blindness, chemical exposure e) Measurements: J 23. Employer Knowledge: The employer requires and assigns employees to transfer hazardous chemicals and clean tanks and floors with high temperature water on daily basis heated water. Numerous management members are in the facility and compounding area on a daily basis. It had been The ER had QAP1851 procedure entitled Training Module for Chemical Safety and Right to Know. developed on May 15, 2007 and had been updated on 7/14/2011. The written purpose of the procedure is to train affected employees in the safe handling and storage of chemicals and potentially hazardous products. The document includes the following: 4.1- Also, we manufacture and package some formulations that require hazard analysis and training because these formulations use some of those hazardous chemicals. 4.3-It also trains the employee in baSic safety procedures and use of chemicals safety equipment. 4.S-The document includes detailed information typically contained on an MSDS. 4.8-General Safety Guidelines: 4.8.1-Employees will be trained in the correct use of safety goggles, respirators, dust masks, and neoprene gloves. Have these items at the training session and demonstrate their correct use. 24. Comments: 25. Other Employer Information: U.S. Department of Labor occupational Safety and Health Administration Violation Worksheet Print Date' 05/01/2012 Inspection Number 110113 Opt. Insp. Number Raani Corporation Establishment Name DBA Name Type Of Violation Serious Number Exposed if Special Enforcement? 1 No. Instances ._---_._-- _._---_. Standard 1910.151(c) -----------Item/Group 1 5/ REC Citation Number FAT/CAT/Accident L Employer's j;elationshi P ._--_._----- to Hazard -'-- _ _ All ---_._----_._-------------- -------_.__.-.---------- - - - - _. -----_._--._._----_.. __._- ---- Substance Codes .----~-----------.---- - ------- Alleged Violation Description 29 CFR 1910.151(c): Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use: a. On or about November 17, 2011, in the compounding area, employees worked with corrosive chemicals including but not limited to, hydrogen peroxide, ammonium hydroxide, and sodium hydroxide. A safety shower was not immediately available and located within 100 feet of all areas where corrosive chemicals were used, thereby exposing employees to eye damage and skin burns. I --1 ---- - - - Recommended Abatement Action Penalty --------_.. - I - Severity High Probability Greater Gravity High Gravity based Penalty 7000.00 .--------------- Good Faith Num Times Repeated History Multiplier 1 Calculated Penalty 7000.00 Proposed Penalty Justification: Abatement Details Size ---_.--------. --.--- - Quick Fix Proposed Penalty __ . ----- -- - ------ .. - S - ------.------- 17000,00 15 Wkg Days Days to Abate Abatement Status Date Abated User-entered Abatement Due Date Yes Abatement Documentation Required? Date Verified Abatement Completed Description: ._ ----- - ---------------" ..- - --.- - --_ ._-- Multistep Abatement Type/Other Type Days to abate User entered Abatement Due Date Completed(status) Verify Date Employee Exposure a_m~e i _E_X_P_o_s_u_r_e-l--_______ N __ a_n_d_A_d__ __s.___ d_re. s D ___t _u __ . c p_ro_x _i_ty Instance Telephone Numbers __ --+-____ _ r a ._i_o_n_--t-_F_r_e_q u_e_n__y_'-.__ _i_m _ . l I-- Daily I Carlos Centeno 20. Instance Description: 1.00 hour A. Hazard B. Equipment C. Location 5 D. Injury/Illness .. At I _ _ ._ _ J _______ =.J E. Measurements a) Hazards-Operation/Condition-Accident: Employees worked with corrosive chemicals on a daily basis in the compounding area . The employer had a safety shower/eyewash located in the preweigh area but it was not located within 100 feet of all the compounding tanks. Carlos Centeno was injured by an extremely hot cleaning solution but it was likely not to be considered corrosive. However, employees made their own "solution" and may have adjusted the solution to unknown and possibly unexpected pH's. Either way, a quick drenching access was not immediately available for all employees. b) Equipment: Quick drenching, eyewash, safety shower c) Location: Compounding - two more additional are necessary. d) Injury/Illness (and Justifications for Severity and Probability): Death, chemical burns, blindness e) Measurements : Tank M02 and the eyewash/safety shower were 175 feet apart unless you wiggled through tanks and hoses. This would be impossible for most employees without the use of eyes. The nearest safety shower to tank M02 using the normal walkway was approximately 175 feet away. 23. Employer Knowledge: The employer has a document (QAP 931)which includes the following statement under the section 4.8.2 under General Safety Guidelines: Employees will be trained in the emergency response procedures. Explain the eye rinse and body shower operation. Given an example of when an employee should use this equipment. The employer assigned employees to work with the corrosive chemicals and told employees to "be careful" when handling the corrosive materials. 24. Comments: 25. Other Employer Information: U.S. Department of Labor Occupational Safety and Health Administration Violation Worksheet Print Date' 05/01/2012 Inspection Number 110113 Opt. Insp. Number Raanl Corporation Establishment Name DBA Name lei'.'i.. Serious Type Of Violation f------------j--------- :;::~r Exposed__ Item/Group 6/ 1 - - - - -- - 1--- ----- - - - 1 - - - - - - + - ------ - -- - - Number ,-'f----_ ~o. _InstancC:~_l ~;.;~Io~~r'~-----:I~C - -- - ---- - - - - - - - - - I Enforcement? Relationship _to Hazard ---------'--------------------------------Standard 1910_178(1)(1)(i) 1 - - - - - - - - - + - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -..- - - --1 Substance Codes I----------r---------------------------------------Alleged Violation 29 CFR 1910.178(1)(1)(i): The employer shall ensure that each powered industrial truck Description operator is competent to operate a powered industrial truck-safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (I). a. On or about December 13, 2011, employees required to operate powered industrial vehicles, were not trained on the safe operation of the powered industrial vehicles, thereby exposing employees to struck by hazards. 1 - - - - - - - - - - 1 - - - - - - - - - - - - - - - - - - - - - - - - - ---------------Recommended Abatement Action L -_ _ _ _ _ _ _L -_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____ Penalty Severity '---- High - ..._ -_ ----_.- - - - - - - - ------------------"-_._"-_._------ Probability Greater Gravity High Size Gravity based Penalty 7000.00 Good Faith Num Times Repeated -- History Multiplier 1 7000.00 Proposed Penalty ~ Quick Fix Calculated Penalty -------- 70UO.00 Proposed Penalty Justification: Abatement Details LID_a_v:-s_to_A_b_a_t_e_ _ _ _--'-1_5_W k_g_D-.:.ay_ __ S __~~- L ______u______ _ J ~ba!e-;;;;nt ~!~tus ____ User-entered Abatement Due Date I Date Abated --- - -- r - - - - -- Date Verified Yes Abatement Documentation Required? -- Abatement Completed Description: MultiStep Abatement Days to abate Type/Other Type User entered Abatement Due Date Verify Date Completed(status) Employee Exposure Name and Address Telephone Numbers Exposure Instance Daily 1----- daily I I ---- - - - - -.--10.00 minute - -- Daily 10.00 minute "-rG- I Duration Frequency Proximity 12 At ----------- - - - - - -- ---12 At Ie.-- I - -------- ----- ------ -- -- -- - ----- -- ~ -- ------ 10.00 minute 12 At 10.00 minute 12 At ~(C--- Daily 1L.2_0_._I_n_s_ta_n_c_e_D_e_s_c_ri.::...p_ti_o_n_:____A_._H_a_z_a_rd_ B. Equipment C. Location D. Injury/Illness E-. Measuremen~ a) Hazards-Operation/Condition-Accident: The employer requires employees to operate PIV's. The employees have not been provided any training to ensure they understand or are competant to operate the PIV. The floors In the facility were very slippery and often wet which contributed to the hazard(s) of operating a PIV without training. Employees were also lifting personnel on pallets and on improperly guarded platforms without PIV training. b) Equipment: PIV training c) Location: Entire facility d) Injury/Illness (and Justifications for Severity and Probability): Broken bones, death e) Measurements: 23. Employer Knowledge: The employer stated they ask people if they are trained. 24. Comments: 25. Other Employer Information: U.S. Department of Labor Occupational Safety and Health Administration Violation Worksheet Print Date' 05/01/2012 110113 Inspection Number Opt. Insp. Number Raani Corporation Establishment Name DBA Name Special Enforcement? ------------.. - 1 Item/Group No. Instances tJ , Number Exposed Standard Citation Number Serious Type Of Violation 1 REC Employer's Relationship to Hazard All _ ._._.--_._._----------_.__._-1910.303(b)(1) 7/ -- - - -------_._-----------. .-- -----.----------------- Substance Codes A"eged Violation Description 29 CFR 1910.303(b)(1): Examination. Electric equipment shall be free from recognized hazards that are likely to cause death or serious physical harm to employees: I a. On or about February 14, 2012, near tank M09, on battery charger number 6, the battery charging cables had rips in the protective coating leaving exposed bare wires unguarded, thereby exposing employees to live electrical parts. -----. "-. . _ - -- _ - _ -_ _ 0-- ___ - - -- -- - - - - - - - - - - - - - - - - - Recommended Abatement Action ---.J Penalty Severity High Probability Greater Gravity High 7000.00 Gravity based Penalty ~- Size -iGOod -l Faith - - -- - , -- 1-----.--- - - --. - - - - - - - -- - - . - . History -- -_. - - - _ ._ - -- - - - - - - ---_." Num Times Repeated Multiplier Calculated Penalty , Quick Fix 7000.00 ~----------------.-----.--- f - - - - -..- - - - - - - - - Proposed Penalty Justification: 5 ?---------?---?. -----.. --- -==G 1 _?_----?----1 - --.-.-- Proposed Penalty . - _ . - - - - - - - _._._----_._- . -- - - --- - - ---. - - - - .. - 7()"J.00 .- - - - - - - - - - - - - - - - - - Abatement Details Days to Abate User-entered Abatement 1 Wkg Days Abatement Status Date Abated I - Due Date - rate Vified ... Yes Abatement Documentation Required? I- Abatement Completed Description: MultiStep Abatement Days to abate Type/Other Type User entered Abatement Due Date Completed (status) Verify Date Employee Exposure Name and Address Telephone Numbers Exposure Instance Twice twice ,- . -- -- -- '--------] - Duration Proximity Frequency - -- -- - - . -- ~ - - - - ~ , 5.00 minute Day day daily - - - -- - - At 5.00 minute - At 5.00 minute -re\ Twice , At 70 I I I I /20. Instance Description: 7eA. Hazard 1 B. Equipment C. Location - - D. Injury/Illness -E. Measu~ements:=J a) Hazards-Operation/Condition-Accident: Employees were required to operate and charge PIV's. Battery charger #6 was located in compounding near tank M09. The battery charger cable had missing insulation on the charging unit exposing employees to live electrical parts. When not In use the battery charger cable lies on the floor potentially near water which is used often in this departement and where the floors remain wet. Also, the battery charger is located in a common aisle used to store raw materials. Employees frequent this area often while searching for raw materials. b) Equipment: Battery charger #6. Model # GTC12-60DTl, Serial # 91D1569, 240 Volts, 126 amps c) Location: Compounding area, near tank M09 d) Injury/Illness (and Justifications for Severity and Probability): Electrocution, shock e) Measurements: 23. Employer Knowledge: Balwinder Singh, Compound Department Manager, is in this work area all day. 24. Comments: 25. Other Employer Information: U.S. Department of Labor occupational Safety and Health Administration Violation Worksheet Print Date' 05/11/2012 110113 Inspection Number Opt. Insp. Number Raani Corporation Establishment Name ~-------~-------------------------------- ----------------- DBA Name ~--------~-------,--------,--------.-------.------------ Type Of Violation Number Exposed Special Enforcement? I Citation Number 2 Item/Group 1/ No. Instances 1 REC FAT/CAT/Accident Employer's Relationship to Hazard Willful - Serious All I ~S-ta-n-d-a-rd--------+-O-S-H-AC-T-of19-70-s-e-cti~-n-(-5)-(a-)-(l-)----~-------~L-------------------------- ~ J------------t--------------- - - - - - - - -. .. ---------------------------~ Substance Codes Ali-e-g-e-d-V-i-o-la-t--io-n-'--+-O-S-H-A CT--~f1970 Section (5)(a)(1): The employer did n~t- furniShemployment and a place ?Description I of employment which were free from recognized. hazards that were causing or likely to cal,lse death or serious physical harm to employees: I I a. On November 17, 2011, an employee suffered scald and chemical burns on approximately eighty (80) percent (%) of his body, including thirty-one (31) percent (%) third degree, after a work related incident which resulted in the employee's death. The employer failed to_seek or administer emergency medical care when obviously necessary to prevent further injury and/or death to a severely burned employee. I I I Recom";;;nd~-'-~~e feasible and acceptable method- to correct this hamd, 1:::::N: CaE::~;:::ON I (a) Call n IAbatement Action _--1 _____ ___ Penaltv ~_-_. -- ----- 911 imm~dia~ "1 AND DOCUMENTATION REQUIRED_ .. - - - . - __ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 0 _ _ _ _ o_ _ _ _ _ _ jl o ___ o _. _ _ _ _. _ Proposed Penalty Justification: Abatement DetaUs Abatement Status 5 Wkg Days Days to Abate Date Abated User-entered Abatement Due Date Date Verified Yes Abatement Documentation Required? l Abatement Completed Description: I MultiStep Abatement Type/Other Type Days to abate User entered Abatement Due Date . Completed(status) Verify Date . - ~ Employee Exposure ,.---- -- - Exposure Instance Once ---- Name and Address Telephone Numbers Carlos Centeno 20. Instance Description: Duration 1.00 hour A. Hazard B. Equipment C. Location -I Frequ~ncy. IProximity ~J Once D. Injury/Illness At E. Measurements a) Hazards-Operation/Condition-Accident: The employer did not furnish medical aid to an employee who in the course of employment became injured and where such action was demanded to save life or to prevent further serious bodily injury. The injured employee suffered burns on 80?% of his body including 31% which were third degree. . Upon discovery of the injured employee, two members of the management team including the VP of Operations, Muhammad Javaid, and Compounding Department Manager, Balwinder Singh, neglected to wash the employee in the available safety shower, or call 911 to utilize available emergency care. It took a minimum of 38 minutes before the employee arrived at a local CUNIC (approximately 4.5 miles away) after having been transported by and in? the vehicle of another employee while he shivered in shock and yelled, Hurry, hurry! The clinic personnel assessed the severely burned employee, started to manually rinse the employee of the obvious chemical ?contamination and contacted the employer numerous times to obtain an MSDS. Within minutes the clinic called 911, an ambulance arrived and the employee was transported to a specialized burn unit where he remained until his death three weeks later. The employer assigned the employee to work with the high temperature cleaning solution and understood the extreme temperature of the material which burned the employee. The employer did not use the quick drenching unit located in the department to remove residual material or cool the skin after the incident. Muhammad Javaid . and Balwlnder Singh admitted to witnessing the employee with his shirt off and speaking with him. Both managers agre~d the injured employee s skin was burned, damaged, wrinkly and parts were peeling. Muhammad J<;Ivaid went as far to describe the burn area as . quite a big area, elbow to shoulder to back and on both arms the skin was peeling. NONE of the co-workers varied in their assessment of the injured employee which included that his skin was peeling from his body. The employer further delayed treatment whUe completing customary paperwork authorizing treatment for this employ~e at the local clinic. The employer waited for greater than 30 minutes until r I ? .- c.. another coworker was assigned (I ~., to drive the employee, wearing plastic over his peeling skin and shivering from shock, in an automobile to a local clinic where he arrived no less than 38 minutes after the incident. The driver of the deceased stated that ~. '7 r.--'(Even after the incident, company officials have not concluded that 911 should have been called immediatelY. Rashid Chaudary, the CEO, stated he could not say if the employee needed an ambulance or not because he was not there. Rashid Chaudary said he dldn I- t think Carlos Centeno died from burns and he had no opinion on the matter to call 911 because he wasn I- t there. Rashid Chaudary stated that if Carlos Centeno had lived the decision to not call an ambulance would nave been the right call. af' When Balwinder Singh heard the employee screaming and saw him after he had removed his shirt, he allegedly asked if the employee wanted an ambulance, which Balwinder Singh stated the injured employee declined. Muhammad Javald responded to the area within 5- 6 minutes and proceeded to complete customary paperwork authorizing treatment at a local clinic while reviewing the employee I- s driverl- s license. Muhammad Javaid stated he never asked the employee if he needed an ambulance. Clara Childs, Production Supervisor, asked both Muhammad Javaid and Balwinder Singh if an ambulance had been called. Balwinder Singh responded no, he needed to go to the clinic first. One employee stated that the injured employee was very angry?because he said that they (management) would not call him an ambulance. All witnesses stated that the employee was in viSibly in need of an ambulance due to the condition of. his peeling skin. Employee interviews and reports obtained stated that the employee complained of the extreme pain. None of the witnesses differed in their opinion. Employees provided signed statements of the severity of the injury and the extreme delayed response in seeking medical care. The emergency medical technicians (EMT I- s), who responded to the 911 call from the cliniC, stated that an ambulance should have been called to the scene immediately do to the visible severity of the injuries and th.e extreme pain the employee suffered. . General Duty Clause justification: (A) The employer failed to keep the workplace free of hazards !I The employer elected not to call an ambulance or administer emergency medical care when obviously necessary to prevent further injury or death to a severely burned employee. The employer 'simply should have utilized available emergency care. (B) The hazard was recognized II The hazard of burns is known and obvious and was viSibly apparent to everyone involved. The Common Law Emergency Rule states' an employer must provide emergency care for life threatening, work related injuries if the employer has notice of the injury. Any reasonable person would know that the burn victim needed an ambulance. (C) The hazard was causing or likely to cause death or serious physical harm !I The delayed treatment could have caused or increased the risk of shock, dehydration, and infection among other life threatening issues. The injured employee was a diabetic further complicating his need for immediate care. (D) Feasible and useful method to correct the hazard !I Call rationale human would deem necessary. 911 ,summons an ambulance, as every b) Equipment: CALL 911 c) Location: 5202 W. 70th Place, Bedford Park, IL d) Injury/Illness (and Justifications for Severity and Probability): Death e) Measurements: 23. Employer Knowledge: Known and obvious. This hazard was obvious to everyone involved. Employees can testify that the burn victim needed an ambulance immediately. Common Law Emergency Rule: an employer must provide emergency care for life-threatening, work-related injuries if the employer has notice of the injury. Any reasonable person would know that the burn victim needed ambulance. The ER had QAP1851 procedure entitled Training Module for Chemical Safety and Right to Know. It had been developed on May 15, 2007 and had been updated on 7/14/2011. The written purpose of the procedure is to train affected employee in the safe handling and storage of chemicals and potentially hazardous products. The document includes the following.: 4.1- Also, we manufacture and package some formulations that require hazard analysis and training because these formulations use some of those hazardous chemicals. 4.3-It also trains the employee in ba~ic safety procedures and use of chemicals safety equipment. 4.5-The document includes detailed information typically contained on an MSDS. 4.8-General Safety Guidelines: 4.8.1-Employees will be trained in the correct use of safety goggles, respirators, dust masks, and neoprene gloves. Have these items at the training session ~nd demonstrate their correct use?. 4.8.2-Employees will be trained in the emergency response procedures. Explain the eye rinse and body shower . operation. Given an example of when an employee should use this equipment. 24. Comments: 25. Other Employer Information: U.S: Department of Labor Occupational Safety and Health Administration Violation Worksheet Print Date' 05/11/2012 110113 Inspection Number Opt. Insp. Number Raanl Corporation Establishment Name DBA Name Type Of Violation Number Exposed Special Enforcement? - - Standard t ----Willful - Serious Citation Number ----- No. Instances . - ---- -.- - - -?? -- - - - - - --- - -- Substance Codes r--. Alleged Violation Description Item/Group 2 - 1 REC Employer's Relationship to Hazard 2/ - - -- .- ._-------FAT/CAT/Accident - -- All I I ~ 1910.132(a) ----- - -. ---29 CFR 1910.132(a): Application . Protective equipment, including personal protective . equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it Is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorp tion inhalation or p hy sical contact: I I a. On or about November 17, 2011, in the facility, employees were required to work with heated water/cleaning solutions pnd hazardous chemicals, including but not limited to, sodium hydroxide. The employer failed to provide and require the use of appropriate body protection including personal protective equipment which was water proof and/or protective against chemical contact. . ABATEMENT CERTIFICATION AND DOCUMENTATION IS REQUIRED. Recommended Abatement Action ------- ---- - ---------------- ---- ---------..-----.. - L _ _ _ _ _ _ _ _ _ _ _-'-_ _ __ .__ _ _ _ _ _ _ _ _ _ __ _. High Severity Justification Probability ------_ ._--- Greater - -- .. - ---- - -- - - - -. Probability Justification Gravity High ISize - I? ---I i - - --- - - j Penalty Severity ---- --- -~ . -- - - .._----- 10% 70000.00 Gravity based Penalty Good Faith 6 History Num Times Repeated Multiplier 1 Quick Fix Calculated Penalty 70000 .00 Proposed Pena'lty Proposed Penalty Justification: J70000.00 \ Abatement Details ------ Date Abated User-entered Abatement Due Date .. _ - -- . -- - .---- - - .---- ---- - _ ._ ._-- Date Verified Yes Abatement Documentation Required? .- ~--- Abatement Status 10 Wkg Days Days to Abate Abatement Completed Description: MultiStep Abatement J Type/Other Type Days to abate Abatement Due ' J',___._us_ _ e_r_e_n_t_e_re_d_--.l_c_o_m_p_le t_ d_ _ e_ (_st_a_t_u_s_ -'-__ V_e_ri_fy_D_a_te. > __ __ Date Employee Exposure Name ~nd Address Telephone Numbers Exposure Instance Duration pr_~-,dmity __1 Frequency - , ~-----~--~. Daily . :---; . : .... . 8.00 hour Daily I At (~ r------?-I---? --?-----..------..---?--- .---- ----------.-..-- ._ .---.--.--Daily I: o I .- At Daily At . .... .- Daily . . - 7~ , Daily 8.00 hour 8.00 hour J' I IC-- - - -- - - -i---- - - - ------ - - --.- -- ---- '------.------~ Carlos Centeno Daily 8.00 hour -- 1 - -- -- -.- - - -- - -.- - -- -..._ ___ ____._.__ l...-_ _ _ _ /20. Instance Description : A. Hazard iE~-Uip-~;nt Daily ~ __.l......_ '? c Location . _ At _ _ _ _ _ ._ __ _ __ _ ____ ___ D. Injury/Illness --E-.-Me-a-s~~e-m-e-n-ts J - a) Hazards-Operation/Condition-Accident: On November 17, 2011, an employee was burned on over 31 % of his. body with a heated cleaning solution. This employee died from the injuries he sustained. The employee transferred the heated cleaning solution while wearing only a regular tee shirt to protect his skin. The employer failed to. provide PPE for heated cleaning solutions and chemical exposure. Nor, did the employer . . require the use of PPE. b) Equipment: PPE -Body protection - Water proof clothing, chemical resistant clothing. c) Location: Entire facility, compounding department d) Injury/Illness (and Justifications for Severity and Probability): Burns on skin, chemical exposure, death e) Measurements: 23. Employer Knowledge: The employer requires and assigns employees to transfer hazardous chemicals and clean tanks and floors with high temperature water on daily basis heated water. Numerous management members are in the facility and compounding area on a daily basis. Employees interacted with the high temperature Iiquid(s) wearing only latex gloves and tee-shirts. Many employees also discussed having chemical burns on extremities. One employee said when he showed the Compounding Manager his peeling skin from a chemical burn, he was told to leave it alone, it wasn t dangerous. Another employee received skin grafts after being burned and vowed never to work in the Compounding area again. However, when asked about corrective actions for burns, Muhammad Javaid stated there was no need for corrective action because it was always someone s fault because they don t operate equipment properly. r r r In QAP 931 the employer included the following information: 4.1- Also, we manufacture and package some formulations that require hazard analysis and training because these formulations use some of those hazardous chemicals. 4.3-It also trains the employee in basic safety procedures and use of chemicals safety equipment. 4.5-The document includes detailed information typically contained on an MSDS. 4.8-General Safety Guidelines: 4.8.1-Employees will be trained in the correct use of safety goggles, respirai:ors, du~t masks, and neoprene gloves. Have these items at the training session and demonstrate their correct use. 24. Comments: 25. Other Employer Information: U.S. Department of Labor Occupational Safety and Health Administration Violation Worksheet Print Date' 05/11/2012 - 110113 Inspection Number -- 1-------- Opt. Insp. Number Raanl Corporation Establishment Name DBA Name Willful - Serious Type Of Violation 4' Number Expose, Special Enforcement? Standard Substance Codes Alleged Violation Description Citation Number 2 Item/Group 3/ No. Instances 1 REC FAT/CAT/Accident --'--I 1910.132(f)(l) -- Employer's Relationship Ito Hazard All ------- ---1 , -- -- -29 CFR 1910.132(f)(1): The employer shall provide training to each employee who is required by this section to use PPE: -- a. On or about November 17, 2011, in the facility, employees were required to work with heated water/Cleaning solutions and hazardous chemicals, including but not limited to, sodium hydroxide. The employer failed to provide training to employees which included the appropriate PPE required to be worn when exposed to the hazards. I ABATEMENT CERTIFICATION AND DOCUMENTATION IS REQUIRED. -- Recommended Abatement Action Penalty ---Severity High Severity Justification Probability Greater Probability Justification Gravity High Size Gravity based Penalty 70000.00 Good Faith Num Times Repeated Multiplier 1 - - - - - - -.Calculated PenaltY 70000.00 History -----------------i Quick Fix - _ ._ - - - _ .__ ._------j. __ ._- _._--- -- - - - - - - - - - - - - - - -- - - - - -. 0J --------- _ __ ' _ - _ _ _ oo __ _ o _ _ _ 0 ? ____ /uOOO.OO i Proposed Penalty -- .-.-.. _._------- _ ._---------------------- ._.- ----_.- -------_. . - -j I __J Proposed Penalty Justification: Abatement Details 30 Wkg Days Days to Abate Abatement Status Date Abated User-entered Abatement Due Date Date Verified Yes Abatement Documentation Required? Abatement Completed Description: MultiStep Abatement to_~:a~_L~~:_:e_r:;,_:_~_:_e_/_~_~_e_...L_c_o_m p_e_t___ota~~oJ __ l e d ( ,---T_y_p_e_/_O_t_h_e_r_T_y_p_ __D_a_ __ _e--'L _ y_s I .V~'ify- l Date Employee Exposure - - ---- Name and Address Telephone Numbers Exposur~ Instance Duration Frequency --c-- P~~Xi~itYl -- Daily 8.00 hour Daily At 8.00 hour Daily At 8.00 hour Daily Daily .~ - Daily _i I C- Daily 7C--_ .._--. Daily Carlos Centeno -- ------ - - - - ------- 18.00 hour - - - -- Daily - ---- -- - -- ---- --------- At - - ----- - 20. Instance Description: A. Hazard B. Equipment C. Location D. Injury/IIInes;- E. Measurements ~ a) Hazards-Operation/Condition-Accident: Employees were required to work with hazardous chemicals and heated water/cleaning solutions and were exposed to hazards. The employer failed to provide training to employees of the required PPE to be worn to protect from the hazards. b) Equipment: PPE training c) Location: Entire facility d) Injury!IIIness (and Justifications for Severity and Probability): Death, burns, blindness e) Measurements: 23. Employer Knowledge: The employer requires and assigns employees to transfer hazardous chemicals and clean tanks and floors with high temperature water on daily basis heated water. Numerous management members are in the facility and compounding area on a daily basis. Rashid Chaudary said that Pervaiz Jafrl had been so busy with compliance responsibilities (other than OSHA), things had got missed. Rashid Chaudary stated the Pervaiz Jafrl told him that employees needed more training. Rashid Chaudary said that years a'go he had concluded he needed a separate compliance department but couldn ~ t afford it due to the economy. Rashid Chaudary said during the time Pervaiz Jafri was overworked, not only OSHA issues got neglected. The employer had three or more recordable injuries each year since 2008 related to inadequate PPE. ' The ER had QAP1851 procedure entitled Training Module for Chemical Safety and Right to Know. It had been developed on May 15, 2007 and had been updated on 7/14/2011. The written purpose of the procedure is to train affected employees in the safe handling and storage of chemicals and potentially hazardous products. The document includes the following: 4.1- Also, we manufacture and package some formulations that require hazard analysis and training because these formulations use some of those hazardous chemicals. 4.3-It also trains the employee In basic safety procedures and use of chemicals safety equipment. 4.5-The document includes detailed information typically contained on an MSDS. 4.8-General Safety Guidelines: 4.8.1 - Employees will be trained in the correct use of safety goggles, respirators, dust masks, and neoprene gloves. Have these items at the training session and demonstrate their correct use. 4.8.2-Employees will be trained in the emergency response procedures. Explain the eye rinse and body shower operation. Given an example of when an employee should use this equipment. 24. Comments: 25. Other Employer Information: U:S. Department of Labor Occupational Safety and Health Aqministration Violation Worksheet Print Date: 05/11/2012 110113 Inspection Number Opt. Insp. Number Establishment Name . Raani Corporation - DBA Name Willful - Serious Type Of Violation NumberExpo~ed _ _ SpecialI Enforcement? Citation Number No. Instances Item/Group Employer's Relationship . 4/ REC 2 FAT/CAT/Accident All -- 29 CFR 1910.133(a)(1): The employer shaff ensure that each aff~cted employee uses appropriate eye or face protection when exposed to eYe or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentia fly injurious light radiation. ' Alleged Violation Description a. On or about November 17, 2011, in the faciiity, employees were required to work with heated water/cleaning solutions and hazardous chemicals, including but not limited to, sodium hydroxide. The employer failed to provide and require the use of appropriate eye and face protection including safety glasses, goggles and/or face shields. I I L-- ABATEMENT CERTIFICATION AND DOCUMENTATION IS REQUIRED. - - - - - - - - - - - - -- -----1- Recommended Abatement Action Penalty . -- ----l - ---- -- Severity Justification - - ----- - - - - - - - - - - - ------- -~ -------~-------.----------- Probability IGreater I - - - - - - - -.- Probability Justification Gravity High Size Gravity based Penalty 70000.00 Good Faith Num Times Repeated History -----_ ------_----1! ?_ ?- IS ] I Multiplier 1 Quick Fix Calculated Penalty 70000.00 Pr!>posed Penalty 170000.00 I Proposed Penalty Justification: Abatement Details '------------T--- 10 Wkg Days Days to Abate Abatement Status Date Abated User-entered Abatement Due Date Abatement Documentation Required? ' Date Verified Yes Abatement Completed Description: MultiStep Abatement' r Type/Other Type L "DayS to I _____,~ abatel---user entered comp,eted(statuT Verify Date_J 'Abatement Du~ , I , Date Employee Exposure Daily Daily Duration' Name and Address Telephone Numbers Exposure Instance 8.00 hour I Frequency Daily At I t,e, I ,-_.., -- - - 8.00 hour Daily At 8.00 hoW , I Proximity Daily At re- l Daily 7c: ,-_._------ Daily Carlos Centeno 120. Instance Description: -, 8.00 hour A. Hazard B. Equipment C. Location Daily .------ 1----;--- ----~ D. Injury/Illness I At E. Measurements ------' a) Hazards-Operation/Condition-Accident: Employees were required tq work with hazardous chemicals and heated water/cleaning solutions. The majority of the chemicals transferred were by means of splash loading. The employer had some safety glasses in the facility. However, employees were not required to wear safety glasses. In most cases due to the splash loading of hazardous materials, employees should have been 'required to wear a minimum of safety goggles and use a face shield for even greater protection. The employer did not provide safety goggles and the use of safety glasses was up to the employee if they were worn. b) Equipment: Safety glasses, goggles and face shields, appropriate eye and face protection c) Location: Entire facility, compounding and preweigh d) Injury/Illness (and Justifications for Severity and Probability): Blindness, eye burns, eye damage e) Measurements: 23. Employer Knowledge: The employer requires and assigns employees to transfer hazardous chemicals and clean tanks and floors with high temperature water on daily basis .heated water. Numerous management members are in the facility and compounding area on. a daily basis. Although some safety glasses were around, employees were not required to wear the safety glasses as witnessed by the CSHO. Rashid Chaudary said that he was in the plant numerous times each day and that he witnessed employees not wearing glasses at various times. Upon noticing employees not wearing eye protection, Rashid Chaudary approached the employee(s) and told them to wear the PPE. Rashid Chaudary agreed that he must talk with supervision and have them enforce the use of eyeglasses more often. Rashid Chaudary said all employees take shortcuts until they see the owner is around. The'employer had various written procedures which state, When required, you must wear protective equipment such as goggles, safety glasses, masks, gloves, hair nets, etc. Pervaiz Jafrl stated that they used MSDSs to determine what PPE was necessary. Many of the chemicals used in the facility carried strong warnings of permanent eye damage with contact. When employees werE~ exposed to the more hazardous chemicals, such as thioglycolic acid 80% or caustic soda, Balwinder Singh stated he instructed employees to be more careful when handling the chemicals. Since 2008 there had been seven recordable injuries related to chemical exposure to eyes. Muhammad Javaid stated injuries were discussed in the daily production meeting where the Chairman/CEO, Rashid Chaudary, and Director of Quality Assurance & Regulatory Compliance (including safety and health), Pervaiz Jafri, were also present. Muhammad Javaid said management sought corrective actions at that time. The interviews confirmed employees were not provided PPE or required to wear PPE. Nearly all employees interviewed described using the eye wash after chemicals got into their eye. One OSHA recordable eye injury. resulted In the employee being issued a formal warning which included the statement, While transferring calcium hydroxide into container you did not do your job carefully with the result that the said chemical dusted up and went into your eyes. You are hereby warned to be careful in future. 24. Comments: 25. Other Employer Information: ij U.S. Department of Labor Occupational Safety arid Health Administration Violation Worksheet Print Date' 05/11/2012 110113 Inspection Number Opt. Insp. Number Raani Corporation Establishment Name DBA Name , Special Enforcement? 2 Item/Group 5/ No. Instances [j Number Exposed 40 REC FAT/CAT/Accident Employer's Relationship to Hazard All - - Standard Citation Number Willful - Serious Type Of Violation ._ .- 191O.138(a) Substance Codes 1-. - -- - -- - . 29 CFR 1910.138(a): General requirements. Employers shall select and require employees Alleged Violation to use appropriate hand protection when employees' hands are exposed to hazards such as Description those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; thermal burns; and harmful temperature extremes. 1 , a. On or about November 17,? 2011, in the facility, employees were required to work with heated water/cleaning solutions and hazardous chemicals, including but not limited to, sodium hydroxide. The employer failed to provide and require the use of appropriate hand protection which Included waterproof, insulated, and/or chemical resistant gloves. ABATEMENT CERTIFICATION AND DOCUMENTATION is REQUIRED. -- Recommended Abatement Action - - -- - - - _. ---.l Penalty High Severity Severity Justification --.--_. f.-.- ----===3 =- Greater Probability Probability Justification I Gravity t-.-.. ' High ~----- .- Size - - ... .:.-- -- . - -- 1_~OOd_ Fa!th____ .-.. ---_-___ S . --------. . - - - - -- - - Gravity based Penalty 70000.00 Num Times Repeated - - ---_._ -- H;stooy ------_.--- _ -.-.- _._ -------I .- - -.. _- - - ---- - .-. - -- ... ~ Quick Fix ..-70000.00 _ __ ____ _ _ _.___ ___ _. ..J ------- - 70000.00 Proposed Penalty ____ Multiplier ._ _ ._ _ ._ _. _- 1 .-~ - -- Calculated Penalty .1 i Proposed Penalty Justification: ~_--L _ _- - - - ; - - - - - - - ' - - _ - - - - : - -_ _ _ J Abatement Details Abatement Status 10 Wkg Days Days to Abate Date Abated User-entered Abatement Due Date Date Verified Yes Abatement DocumentationRequired? Abatement Completed Description: -- -- MultiStep Abatement Completed(status) User entered Abatement Due Date ' - - - - - - - - - - - - ' - - - - - - - - - - - - - --- - - - --------'--- - - - - - - - Days to abate Type/Other Type Verify Date] Empioyee Exposure ------- --- DUration Proximity I - - - -- - . , I ' At Daily At (~ I ,. Daily 8.00 hour I 8.00 hour Daily Daily . Frequency - --_._-_._------- rL.- Daily' Daily - - -T - - - - -?--l - Name and Address Telephone Numbers 'Exposure Instance ~- 8.00 hour --1-----_ . _ - -- Daily -- At I I I , rc- Carlos Centeno Daily LI2_0_._I_n_s_ta_n_c_e_D_e_s_c_ri..:..p~tl_?o_n_:___A_._H a_z_a_rd __ _ I 8.00 hour Daily At 8.00 hour Daily At _ B. Equipment C. Location D. In j Ury/I1!ness E. Measurem~nt~ a) Hazards-Operation/Condition-Accident: EE ~ s were required to work with and were exposed to chemicals and heated water when making batches and cleaning tanks, floors and containers. Employees transferred the chemicals and water by splash loading the chemicals into other containers. Also, employees often titled drums on their side and twisted the bung cover off while material splashed out of the drum. When the desired quantity was In the secondary container, employees placed their hand(s) in the stream of chemical(s) and twisted the bung until it was closed. Significant hand exposure was witnessed by the CSHO. The employer purchased only poor quality latex gloves suitable for a medical environment \'{hich was not adequate protection from most of the chemicals used at the facility. Although there was ?one lone pair of long black gloves in the facility, the majority of employees were not aware that the gloves existed. The problem was exasperated because employees wer.e never provided training to understand the hazards of the chemicals/heated water and the subsequent need for or use of PPE and hand protection. b) Equipment: Appropriate hand protection including insulated gloves, waterproof gloves, chemical resistant gloves. c) Location: Entire facility d) Injury/Illness (and Justifications for Severity and Probability): Burns, dermatitis, skin damage, skin grafts . e) Measurements: 23. Employer Knowledge: The employer r~qulres and assigns employees to transfer hazardous chemicals and clean tanks and floors with high temperature water on daily basis heated water. Numerous management members are in the facility and compounding area on a daily basis. The employer has MSDS's on site which specify the exact hazards and appropriate hand protection. Even. more critical the MSDS's document the damage that can be occur from having exposure and not being adequatley protected. . Balwinder Singh stated they had a long thick black pair of gloves more suitable for heat protection available at all times, however, few employees interviewed knew of the presence of the special gloves. Balwinder Singh stated that the ' black gloves were kept in the maintenance department because they were expensive and the employees stole them. According to Balwinder Singh, any employee could obtain the black gloves if so desired. Balwinder Singh said employees wore latex gloves when handling high temperature liquids. The employer purchased the cheapest medical grade latex gloves by the pallet. These same types of gloves are commonly used in home hair coloring kits. The latex gloves were not adequate gloves for the majority of chemicals used at the site. The gloves were not insulated and offered no protection against high temperature liquids. The employer was aware they provided employees with inadequate hand protection for the hazards they were exposed ~dai~ . The employer!- s Chemical Safety and Right to Know procedure included that employees would be trained in the correct I,lse of safety goggles and neoprene gloves and that these items should be at the training session and training should demonstrate their proper use. The employer!- s own written program(s) recognized the need for more substantial hand protection and the employer still failed to ensure that proper gloves were provided and used by employees. Pervaiz Jafri stated latex gloves were not suitable for use with caustics. The owner, Rashid Chaudary, said although he wasn!- t sure, he thought that latex gloves may be eaten up by some of the chemicals used in the facifity. Rashid Chaudary said he could not recall having seen compounders wearing latex gloves. Rashid Chaudary was certain the Pervaiz Jafri was knowledgeable and made the decision to get the right kind of gloves. Interestingly, Pervaiz Jafri had stated that he was not responsible for what g'loves were actually purchased and that decision was up to production. It was impossible that critical management members admittedly visited the production area numerous times each day and did not notice that employees were only provided medical latex ' gloves. 24. Comments: 25. Other Employer Information: U.S. Department of Labor Occupational Safety and Health Administration Violation Worksheet Print Date' 05/11/2012 Inspection Number 1l01i3 Opt. Insp. Number Raani Corporation Establishment Name DBA Name Willful - Serious Type Of Violation Citation Number Item/Group 2 6/ -- 1 - - . ' ----.No. Instances 1 REC FAT/CAT/Accident .. _ - ._----1--- - - - - -r - . - - - - - I Employer's All Special I Relationship Enforcement? ~ Hazard -.------.------._--_._--- - . -------- t1910.1200(h)(1) [Standard _ Lf Number Exposed I ----- ~i . i Substance Codes Alleged? Violation Description -- 29 CFR 1910.1200(h)(I): Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their Initial aSSignment, and whenever a new physical or health hazard the employees have not previously been trained abdut is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., f1amm'ability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available ~hrough labels and material safety datasheets. I a. On or about November 17,2011, employees required to work with hazardous chemicals such as but not limited to, sodium hydroxide, were not provided training on the hazards a.ssociated with the chemicals . ABATEMENT CERTIFICATION AND DOCUMENTATION IS REQUIRED . - - - - - - - - - - --- -- . _---- --_._------- ------_._------- Recommended Abatement Action ' ._------ Penalty High Severity Severity Justification 1--- Greater Probability Probability Justification Gravity High " -- ------- -----_._- - - - - - - - - lSize --------_.-- I Gravity based Penalty I Num Times Repeated -- Good Faith --_._-- --------------- - -------- -- 70000.00 - - - - -_ .._---------_ ..._ - -- G----?----------- History Multiplier -1 Quick Fix Calculated Penalty 70000.00 Proposed Penalty 170000.00 Proposed Penalty Justification: Abatement Details . Abatement Status 30 Wkg Days Days to Abate Date Abated User-entered Abatement Due Date Date Verified Yes Abatement Documentation Required? Abatement Completed Description: I _ .___J - r MultiStep Abatement A_~_:__~_:;_a~_:_~_r~_~_e_-,--C_o_mpleted(statu~ _____v_e_ri_tv~:__J e Type/Other Ty__ .LI_ _ _y_s_t_o abate_--,-___ pe __ D_a . __ Employee Exposure . Name and Address Telephone Numbers Exposure Instance Daily Daily . -------- ---- -- Frequency Proximity --Daily Daily - - At 8.00 hour At le,------ 1---- - -- - -- Daily 8.00 hour - -- -~ Daily -At .- .- (V -- -_ ._--- - Daily Duration (~ i I\. . 8.00 hour I I __ Carlos Centeno ------_. 8.00 hour - -------- Daily - - --- --- At [20. Instance Descripti~n: a) Hazards-Qperation/Condition-Accident: The employer had a written hazard communication program . The employer had approximately 130 full time employees. The company used-approximately 60 temporary workers per day. The employer had not completed any haz com training since the year of 2008 and 2009. Since that point, countless employees had worked in a position which entailed the potential for or hazardous chemical exposure and handling. The employer never provided the employees with any training to understand where to get further informaiton like an MSDS. Also, they were provided training to understand the hazards associated with these chemicals. Chemical exposure included but was not limited to the following; thioglycolic aCid, hydrogen peroxide, ammonium hydroxide, sodium hydroxide, dibenzoyl peroxide and nitrogen gas. b) Equipment: Haz Com training c) Location: Entire facility d) Injury/Illness (and Justifications for Severity and Probability): Death, burns, blindness, asphyxiation. e) Measurements: 23. Employer Knowledge: The employer requires and assigns employees to transfer hazardous chemicals and clean tanks and floors with high temperature water on daily basis heated water. Numerous management members are in the facility and compounding area on a daily basis. The employer has been issued a citation for not having provided hazard communication training on 7/21/1993. The employer agreed to the citations during an informal settlement agreement and abated this hazard on 9/7/1993. The employer stated that the same employee, Pervaiz Jafri, who interacted with OSHA in 1993 was still In charge of Safety on the date of the accident which initiated the inspection. The written d.ocument contained the following under the section entitled Introduction: It is the intention of the Raanl Corporation to comply fI.!ll in a prudent manner with all occupation safety and health standard/regulation . Consequently, this program to comply with the Department of Labor, Occupational Safety and Health' Administration's Hazard Communication Standard 29 CFR 1910.1200 will be implemented and enforced. Also in this written program it includes the following under Information and Training: It is the policy of Raani Corporation to provide an information and training program to all employees with the implementation of this program, at the time of new employee's initial assignment, and whenever a new hazard is introduced into the working place. . 24. Comments: When asked why the employer stopped training employees Muhammad Javaid, VP of Operations stated that It~ s just missed no explanation for it The owner of the facility stated that he was aware that the indiYidual in charge of Regulatory Compliance was overworked and that "things" had been missed including OSHA. The owner stated that he was aware that he needed more training for years. The owner stated that due to the economy he was not able to hire someone to take over regulatory compliance. 25. Other Employer Information: The employer had suffered many injuries related to chemical exposure and/or cleaning solutions. Chemical burns of the skin and eyes have been occuring on annual basis for years. Please see OSHA 300 logs. U.S. Department of Labor Occupational Safety and Health Administration Violation Worksheet Print Date' 05/01/2012 Inspection Number Raani Corporation Establishment Name Opt. Insp. Number ----- DBA Name , J Number Exposed Special Enforcement? Citation Number 3 Item/Group 1/ No. Instances 1 REC FAT/CAT/Accident Employer's Relationship to Hazard All -----Standard Substa nce Codes Alleged Violation Description ,.----- - - - - -- --c-- Other-thanSerious Type Of Violation 110113 190439(a) ------29 CFR 1904.39(a): Basic requirement. Within eight (8) hours after the death of any employee from a work-related incident or the in-patient hospitalization of three or more employees as a result of a work-related incident, you must orally report the fatality/multiple hospitalization by telephone or in person to the Area Office of the Occupational Safety and Health Administration (OSHA), U.S. Department of Labor, that is nearest to the site of the Incident. You may also use the OSHA toll-free central telephone number, 1-800-321-0SHA (1-800-321-6742): a_ On or about December 8, 2011, an employee died as a result of a work related Incident The employer failed to report the death.of the employee to the Occupational Safety and Health Administration (OSHA). i which occurred on November 17, 2011. -Recommended Abatement Action Penalty Severity Minimal - Probability Size Gravity Gravity based Penalty 7000.00 Num Times Repeated Good Faith History ! - 1:7 Multiplier 1 Quick Fix Calculated Penalty 6300.00 Proposed Penalty Proposed Penalty Justification: d. Unadjusted penalty of $7000 was used as a deterrent and was Imposed at the Discretion of the Area Director. 17000.00 Abatement Details Days to Abate Abatement Status Corrected During Inspection User-entered Abatement Due Date Date Abated 12/09/2011 Date Verified 12/13/2011 Abatement Documentation Required? No Abatement Completed Description: Medical Examiner notified OSHA of the work related fatality. MultiStep Abatement Days to abate Type/ Other Type User entered Abatement Due Date completed(s._ta_t_u_s_)....LI_ _ve_r_ify_D_a_te_---'1 __ Employee Exposure - Exposure Instance Once Name and Address Telephone Numbers Carlos Centeno 20. Instance Description: 5.00 hour A. Hazard Frequency Duration B. Equipment C. Location Daily D. Injury/Illness Proximi At E. Measurements a) Hazards-Operation/Condition-Accident: An employee was burned on over 31% of his body on November 17,2011. The employee succumed to his injuries on December 8,2011. Raani Corporation was notified of his death by Ron's Staffing Service, the temporary agency the employee worked. The employer failed to report the death of Carlos Centeno to OSHA upon notification of his death. b) Equipment: Report fatality to OSHA within 8 hours. c) Location: d) Injury/Illness (and Justifications for Severity and Probability): Death e) Measurements: 8 hours. 23. Employer Knowledge: Ron's Staffing Service made notations in their Internal file dated Dec 9, 2011, which was provided to OSHA that stated the following: "We did not contact OSHA and when I spoke to the client I did reiterate they needed to complete an OSHA log as well as contact OSHA." 24. Comments: 25. Other Employer Information: :=J