Haggi IAbdullah HaggiENGLISH 2O1OShannon Branfield.docx

Haggi I
Abdullah Haggi
ENGLISH 2O1O
Shannon Branfield
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t?umlan5*n.-Q -^(
resource .rffi,ce? The ambiguous "-#*r:"
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dependence on violent conrlicd rournat of Peace no*,"@,7s7-
776,
This article is relevant to my argument because it offers part of
a solution to both the
rentier peace and resource curse theories, particularly for the
oil-producing countries. Hence,
the maior argument in this reference is that both resource
dependence and resource wealth per
capita should be considered. In essence, these two concepts
should be taken into account
because only the availability of the extremely high per capita
revenues mainly from oil

enables governments to attain internal stability. Notably, the
empirical analysis of this
reference supports this hypothesis effectively. The research
findings of this article state that
oil-wealthy nations ostensibly manage to maintain their political
stability through an
amalgamation of protection by outsiders, high expenditure on
the security apparatus, and
large-scale distribution. In comparison to the oil-poor nations
and inconsistency to the rentier
theory, the reference states that oil-wealthy countries'
institutions seem not to be particularly
characterized through clientelism and patronage.
Benes, J., Chauvet, M., Kamenikr 0., Kumhof, M., Laxton, D.,
Mursula, S., &Selody, J.
,ri- , Th. future of oil: Geology versus technolog,v.lnternational
Journal of Forecasting,,{31(l)"
L"',_
j:,
207-22{,2015. Print
Haggr 2

Most importantly, this ret'erence is also relevant to my
argument since it reconciles
and discusses two diametrically opposed perspectives about
rvorld's oil production future and
prices. The article notes that the geological perspective expects
that physical constraints shall
dictate the future evolution of prices and oil output. This
perspective is supported by the
statistics that pofiray that rvorld oil production has deciined
significantly since 2005 despite
the historically high prices. Additionally, spare capacity has
also reduced to near historic
lows. On the other hand, the technological perspective of oil
expects that higher oil prices
should eventually lead to a decisive eff-ect specitically on oil
output through encouraging
technological solutions. Tl"ris perspective is supported by the
fact that high prices since 2003
resulted in escalated revisions in production forecasts lbunded
on a purel-v geological
perspective.
"-,i'
ir-
r l;

Bromley, S. The United States and the control of world oil'.
Government antl Oppositio{,',
,'''"
tt'
: 40Q1.225-255. 2005. Print.
I :'
This informative relerence is appropriate for my argument
because it expounds oa the
drive to correct the world's oil, which is the fundamental
driving torce that is trehind the
American foreign policy. Hence, the reference argues that
instead of perceiving the American
foreign poliey as being driven by the US oil companies'
expansionary forces that seek new-
markets and reserves, it is integral to analysis the American
geopolitics nature. it is also
important to analysis how this American geopolitics nature
shapes various policies tolvards
internationai oil. According to the article, the U.S. indeed
attempts to exercise a certain
degree of influence specifically over the world oil. However,
the kind of this influence is
extremely different and arnbiguous from the types of control
that Arnerica applies to raw

materials that are traditionaily linked w'ith irnperial pow'ers.
T;.
Fasano, U., &Iqbal, Z. GCC countries: from oil dependence to
diversilication.
International Monetary Fund, 2003. Print.
Haggi 3
This reference is relevant
to my argument because
it notes that Gcc nations irave
evidently come fiom far a{ter
combined effor-ts at economic
transtbrmation were started
over
tlvodecadesago.TheseGCCcountries'livingstandardshavecontinu
edtoescalate
regardlessofheaq,-
relianceonvolatileoilrevenues,aswellasfastpopulationgrouth.
Additionarly. these Gcc nations
ha'e also played an integral
function in helping .ther
deveroping nations in the
region especially through

maintaining liberal trade
and exchange
systems,empioymentopportunities.andfinancialsupport'Nonethel
ess'newchallengeshave
evidentlybeguntoemerge.Hence,theswiftiyescalatingdomesticlab
orforcehas
necessitated the ,eed tbr
a sustained increment
in institutionar reforms.
human capital
investment,andnon-
oilgrornth.Nevertheless,theauthoritiesaresearchingfora

Thiseducativeret-
erenceisrelevantformyargumentsinceitnotesthatAmerica,s
heavy oil dependence threatens
the cou,try,s environment,
econonry' and national
securiry' It
;;;.r;".{merica consumes
nearlv 25% of the total
oil production in the u'or1d
aitherugh it only has 3yo
of its reserves. The nation

also spends huge billions
of dollars
annuarly for o* importation,
particularly from the world's
unstable regions' Thus'
this costly
behaviorendangerstlrelrealthcrfitscitizensthroughpollutiorrfromt
hecourrtry,sbuses'
trucks. and cars, which account
for 2'o/oof America's
grobal rvarming po*ution'
This also
includessmogandsootthatdamagetheirlungs'Inessence.Anrericash
ouldhastenits
..aggressive plan to developing cellulosic
biofuels between now and
2015.', This will greatly
comprehensive reform
strategy to address these
challenges'
assist the courrtry to reduce
its heavy dependence
on oil and pollution'

Haggi4
-^ ., t" w
Holdren, J. P.'The enerry innovation imperative: addressing oil
dependence,
climate change, and other 2lst centurT energy challengtii{-
innovafio$tr97,3-23,2006.
*' !- *'
Print.
This reference is also relevant to my argument because it
expounds that the society
faces numerous energy challenges particularly in this century
although the reduction of
energy resources in an absolute or global sense is none of them.
Thus, the world is running
out of reliably deliverable and extractable natural gas and
conventional oil, and there is the
need to address this issue further. Ideally. other energy sources
such as solar energy should be
harnessed not mitigate this issue amicably. Additionally, the
reference provides various
solutions on w'hat should be done to deal with this situation.
Among these solutions includes

financing and promoting early deployment of promising options
from the RD&D process.
The other solution involves providing the coordination,
continuity, and scale of effort in
demonstration, development, and energy research' ---, {*
Hughes, L., & Rudolph, J. g0l1).'Future world oil production:
growth, plateau, or
:t - - --^ .ito*'
peak?"Currenr Opinion in Environmental Sustainabiliffi),225-
23412011. Print.
Importantly, this reference is relevant to my argument in the
sense that it provides
vital infolnation on the future of world production. Hence. it
notes, "w-ith the exception of
the two oil shocks in the 1970s, world oil production
experienced steady growth throughout
the 20th century, from about 400,000 barrels a day in 1900 to
over 74 million by 1999." It
also states that conservative projections that are derived from
IEA (International Energy
Agency) for 2035 portray that oil production will escalate to
nearly 96 million barels daily.
Nonetheless, majority of the oil products that human beings
consume are derived rnainly
from various sources. which are non-renewable. The article

considers the period that world
Haggi 5
oil production will continue to grow' peak or plateau, and
eventually clecline' It denotes that
societies must be ready fbr a world that has less oil' ",,"* ' .
..,;$;'''' ".-i{-" }, - "/""
'-
-.^- .'t
LaherrBre, JiFuture of oil supplies.Energy exploration
& exploitofon' 2l{3)'P27267'
-- *-""-
2003. Print.
This article is important and relevant to m.v argument
since it expounds on the oil
supplies future. It states that oil is paramount to the
world' which has made publishing
production, and reserve data has gradually turned into
a political act' Hence' majority of the
disputes between the economists (optimists) and
retired geologists (pessimists) is because the
use varied information sources and different definitions
when 'liscussing

the oil supplies
future. ldeally, the optimists utilize the published
political data wiereas the pessimists utilize
cont-idential technical data. This phenomenon has
also afl'ected the OPEC quotas w-hereby its
reserves quantities were increased from 1986 to 1990 although
the real atnournt r'vas less'
Accor<ling to this reference, the major reason for this
is that politics and confidentiality make
it harcl to obtain valid data, which creates uncertainly
about the future of oil supplies'
1 -..
Lefton, R, & weis s,D. oil dependent is a dangerous habit'center
for American
;1$.ogr"rr, Jxn*f3, 20 10, Print'
tx'L
'1
This article is also relevant to my argument because it
provides insightful information
about the dangers of depending heavily on oil since it is a
dangerous habit' Moreover' the u's
is spending close to $1 billion daily overseas on oil imporls
rather than investing the funds in

the country since its economy needs such an amount
of money for other developments'
Furthermore, burning oil that increases global warming also
poses severe threats to the
country's national securitv, as well as the global security'
It notes' "For these reasons' we
need to kick the oil addiction by investing in clean-energy
refonn to reduce oil demand' while
taking steps to curb global warming'' ,.-'-,""'-' ''.
*.- ,, {
tl
Ross. M. L. Does oil hinder democrac_v ?.hltorkt
potilicb{53(03), 325-36I,
2001- Print'
Haggi 6
Notably. this reference is indeed relevant to my argument since
it notes that some scholars
have suggested that the oil rvealth in the Middle East assists in
explaining its failure to
democratize. This article is also informative trecause it
examines three fundamental concepts
of this "oil impedes democracy" claim. The author has utilized

combined time-series cross-
national data mainly from l 13 nations between 1971 and 1997
to portray that oil exports are
associated strongly with the authoritarian rule. This is not
evident only in the Middles East
countries but in other countries that have other kinds of mineral
exports. They also "have a
similar antidemocratic effect, while other types of commodity
exports do not."
D,^U"cl^!.I- rnm{*"^J, ftHY
Olt€A^" -1"t1&r, Corrnrnas, L dcd{s
q4*
U.S. Department of Labor
Occupational Safety and Health Administration
Denver Commons Office Plaza
111 Main St., Suite 111
Denver, CO 11111
Phone: (111) 111-1111 FAX: (222) 222-2222

Citation and Notification of Penalty
To: Inspection Number: 111111111
Acme Widget Factory Inspection Date(s): 04/15/2015-
04/16/2015
and its successors Issuance Date: 08/21/2015
1 Factory Lane
Inglewood, CO 11111-1111
Inspection Site: The violation(s) described in this citation
and
1 Factory Lane Notification of Penalty is (are) alleged to
have
Inglewood, CO 11111-1111 occurred on or about the day(s)
the inspection
was made unless otherwise indicated within the
description given below.
This Citation and Notification of Penalty (this citation)
describes violations of the Occupational
Safety and Health Act of 1970. The penalty(ies) listed herein is
(are) based on these violations.
You must abate the violations referred to in this citation by the
dates listed, and pay the
penalties proposed unless, within 15 working days (excluding
weekends and federal holidays)
from your receipt of this Citations and Notification of Penalty,

you mail a notice of contest to the
U.S. Department of Labor Area Office at the address shown
above. Please refer to the enclosed
booklet (OSHA 300) which outlines your rights and
responsibilities and should be read in
conjunction with this form. Issuance of this citation does not
constitute a finding that a violation
of the Act has occurred unless there is a failure to contest as
provided for in the Act or, if
contested, unless this citation is affirmed by the Review
Commission or a court.
Posting – The law requires that a copy of this Citation and
Notification of Penalty be posted
immediately in a prominent place at or near the location of the
violation(s) cited herein, or, if it is
not practicable because of the nature of the employer’s
operations, where it will be readily
observable by all affected employees. This citation must remain
posted until the violation(s)
cited herein has (have) been abated, or for 3 working days
(excluding weekends and federal
holidays)—whichever is longer. The penalty dollar amounts
need not be posted and may be

marked out or covered up prior to posting.
Informal Conference – An informal conference is not required.
However, if you wish to have
such a conference you may request one with the area director
during the 15 working day
contest period. During such an informal conference, you may
present any evidence or views
which you believe would support an adjustment to the
citation(s) and/or penalty(ies).
If you are considering a request for an informal conference to
discuss any issues related to this
Citation and Notification of Penalty, you must take care to
schedule it early enough to allow time
to contest after the informal conference, should you decide to
do so. Please keep in mind that a
written letter of intent to contest must be submitted to the area
director within 15 working days of
your receipt of this citation. The running of this contest period
is not interrupted by an informal
conference.

If you decide to request an informal conference, please
complete, remove, and post the page 4
Notice to Employees next to this Citation and Notification of
Penalty as soon as the time, date,
and place of the informal conference have been determined. Be
sure to bring to the conference
any and all supporting documentation of existing conditions, as
well as any abatement steps
taken thus far. If conditions warrant, we can enter into an
informal settlement agreement which
amicably resolves this matter without litigation or contest.
Right to Contest – You have the right to contest this Citation
and Notification of Penalty. You
may contest all citation items or only individual items. You may
also contest proposed penalties
and/or abatement dates without contesting the underlying
violations. Unless you inform the
area director in writing that you intend to contest the citation(s)
and/or proposed
penalty(ies) within 15 working days after receipt, the citation(s)
and the proposed
penalty(ies) will become a final order of the Occupational
Safety and Health Review

Commission and may not be reviewed by any court or agency.
Penalty Payment – Penalties are due within 15 working days of
receipt of this notification
unless contested. (See the enclosed booklet and the additional
information provided related to
the Debt Collection Act of 1982.) Make your check payable to
“DOL-OSHA”. Please indicate the
inspection number on the remittance.
OSHA does not agree to any restrictions or conditions or
endorsements put on any check or
money order for less than the full amount due and will cash the
check or money order as if
these restrictions, conditions, or endorsements do not exist.
Notification of Corrective Action – For each violation which
you do not contest, you are
required by 29 CFR 1903.19 to submit an Abatement
Certification to the area director of the
OSHA office issuing the citation, identified above. The
certification must be sent by you within
10 calendar days of the abatement date indicated on the citation.
For willful and repeat

violations, documents (e.g., photos, copies of receipts, training
records) demonstrating that
abatement is complete must accompany the certification. Where
the citation is classified as
serious and the citation states that abatement documentation is
required, documents such as
those described above are required to be submitted along with
the abatement certificate. If the
citation indicates that the violation was corrected during the
inspection, no abatement
certification is required for that item.
All abatement verification documents must contain the
following information: 1) Your
name and address; 2) the inspection number (found on the front
page); 3) the citation and
citation item number(s) to which the submission relates; 4) a
statement that the information is
accurate; 5) the signature of the employer or employer’s
authorized representative; 6) the date
the hazard was corrected; 7) a brief statement of how the hazard
was corrected; and 8) a

statement that affected employees and their representatives have
been informed of the
abatement.
The law also requires a copy of all abatement verification
documents, required by 29 CFR
1903.19, to be sent to OSHA and also be posted at the location
where the violation appeared
and the corrective action took place.
Employer Discrimination Unlawful – The law prohibits
discrimination by an employer against
an employee for filing a complaint or for exercising any rights
under this Act. An employee who
believes that he/she has been discriminated against may file a
complaint no later than 30 days
after the discrimination occurred with the U.S. Department of
Labor Area Office at the address
shown above.
Employer Rights and Responsibilities – The enclosed booklet
(OSHA 300) outlines
additional employer rights and responsibilities and should be
read in conjunction with this

notification.
Notice to Employees – The law gives an employee or his/her
representative the opportunity to
object to any abatement date set for a violation if he/she
believes the date to be unreasonable.
The contest must be mailed to the U.S. Department of Labor
Area Office at the address shown
above and postmarked within 15 working days (excluding
weekends and federal holidays) of the
receipt by the employer of this Citation and Notification of
Penalty.
Inspection Activity Data – You should be aware that OSHA
publishes information on its
inspection and citations activity on the Internet under the
provisions of the Electronic Freedom
of Information Act. The information related to your inspection
will be available 30 calendar days
after the citation issuance date. You are encouraged to review
the information concerning your
establishment at www.osha.gov. If you have any dispute with
the accuracy of the information
displayed, please contact the office.

http://www.osha.gov/
NOTICE TO EMPLOYEES OF INFORMAL CONFERENCE
An informal conference has been scheduled with OSHA to
discuss the
citation(s) issued on 08/21/21015. The conference will be held
at the OSHA
office located at Denver Commons Office Plaza, 111 Main St.,
Suite 111,
Denver, CO 11111 on ________ at __________. Employees
and/or
representatives of employees have a right to attend an informal
conference.

CERTIFICATION OF CORRECTIVE ACTION WORKSHEET
Inspection Number:
Company Name:
Inspection Site:
Issuance Date:
List the specific method of correction for each item on this
citation in this package that does not
read "Corrected During Inspection" and return to: U.S.
Department of Labor - Occupational
Safety and Health Administration, Denver Commons Office
Plaza, 111 Main St., Suite 111,
Denver, CO 11111
Citation Number ____ and Item Number ____ was corrected on
_______________ By (Method
of
Abatement):__________________________________________
_____________________
_______________ By (Method
of Abatement):
_____________________________________________________

__________
_______________ By (Method
of Abatement):
_____________________________________________________
__________
_______________ By (Method
of Abatement):
_____________________________________________________
__________
_______________ By (Method
of Abatement):
_____________________________________________________
__________
_______________ By (Method
of Abatement):
_____________________________________________________
__________
I certify that the information contained in this document is
accurate and that the affected
employees and their representatives have been informed of the
abatement.

________________________
____________________________
Signature Date
________________________
____________________________
Typed or Printed Name Title
NOTE-: 29 USC 666(g) whoever knowingly makes any false
statements, representation or
certification in any application, record, plan or other documents
filed or required to be
maintained pursuant to the Act shall, upon conviction, be
punished by a fine of not more than
$10,000 or by imprisonment of not more than 6 months or both.
POSTING: A copy of completed
Corrective Action Worksheet should be posted for employee
review
U.S. DEPARTMENT OF LABOR
OCCUPATIONAL SAFETY AND HEALTH
ADMINISTRATION
CERTIFICATE OF CORRECTION

The undersigned certifies that on ______________, all of the
violations
cited on OSHA Citation # ____________ issued on _________,
were
corrected and that a copy of this certificate was posted on
_________ in a
manner and place for review by affected employees.
______________________
Employer’s Signature
U.S. Department of Labor Inspection Number: 111111111
Occupational Safety and Health Administration Inspection
Date(s): 04/15/2015-04/16/2015
Issuance Date: 08/21/2015

Company Name: Acme Widget Factory
Inspection Site: 1 Factory Lane, Inglewood, CO 11111-1111
The alleged violations below have been grouped because they
involve similar or related
hazards that may increase the potential for injury or illness.
Citation 1 Item 1a Type of Violation: Serious
29 CFR 1910.1025(c)(1) Exposure levels to lead fumes during
welding operations were
not kept below the established permissible exposure level
(PEL).
(a) Location – Frame Assembly Area
On 04/15/15, a MIG welder in the frame assembly area was
exposed to lead
at an airborne time weighted average (TWA) exposure of 100
µg/m3. This
exposure was approximately 2 times the permissible exposure
limit (PEL) of
50 ug/m3. This exposure was calculated from a sample collected
over a 410
minute period; a zero increment was included for the 70 minutes
not sampled.
(b) Location – Frame Assembly Area
On 04/15/15 a MIG welder in the frame assembly area was
exposed to lead
at an airborne time weighted average (TWA) exposure of 80

µg/m3. This
exposure was approximately 2 times the permissible exposure
limit (PEL) of
50 ug/m3. This exposure was calculated from a sample collected
over a 400
minute period; a zero increment was included for the 80 minutes
not sampled.
ABATEMENT DOCUMENTATION REQUIRED FOR THIS
ITEM
Date by which violation must be abated: 09/28/2015
Proposed Penalty: $7000.00
Date(s): 04/15/2015-04/16/2015
Citation 1 Item 1b Type of Violation: Serious

29 CFR 1910.1025(e)(1)(ii): Where an employee was exposed to
lead above the
permissible exposure limit, but for 30 days or less per year,
engineering controls were
not implemented to reduce exposures to 200 ug/m3:
Engineering controls were not implemented to reduce the
exposure to employees
overexposed to Lead.
Engineering controls usually effective in these circumstances
include, but are not limited
to, the following:
1. Modification of the existing ventilation system to improve
capture velocity at the
ventilation hoods.
2. Modification of ventilation hoods to better collect metal
fumes,
Abatement Steps
STEP 1: Effective respirators shall be provided and used by all
employee(s) as an
interim measure. Abatement must be completed by September 1,
2015.

Date(s): 04/15/2015-04/16/2015
STEP 2: Submit to the Area Director a written detailed plan of
abatement outlining a
schedule for the implementation of engineering measures to
control employee
exposures as referenced in this citation. This plan shall include,
at a minimum, target
dates for the following actions which must be consistent with
the dates required by this
citation.
a) Evaluation of the extent and location of the hazard source.
b) Evaluation of control measure options.
c) Selection of optimum control method(s).
d) Determination of control measure design.
e) Ordering and delivery of equipment and material(s).
f) Installation of control measures.

g) Training of employees in proper operation and maintenance
of newly-implemented
control measures.
h) Assurance of effective performance of control measures.
All proposed control measures shall be evaluated for each
particular use by a
technically qualified person. Abatement must be completed by
September 1, 2015.
STEP 3: Correction should have been completed by the
implementation of feasible
engineering controls and air sampling results to verify the
effectiveness in achieving
compliance. Abatement must be completed by September 1,
2015.
ITEM
Date By Which Violation Must be Abated: 09/28/2015
Date(s): 04/15/2015-04/16/2015

Citation 1 Item 2 Type of Violation: Serious
29 CFR 1910.134(c)(1): A written respiratory protection
program that included the
provisions in 1910.134(c)(1)(i) - (ix) with worksite specific
procedures was not
established and implemented for required respirator use: No
written program was
developed for employees who were overexposed to lead and
who are required to wear
respirators while working in the frame assembly area.
ITEM

Date(s): 04/15/2015-04/16/2015
29 CFR 1910.13 4(e)(1): The employer did not provide a
medical evaluation to
determine the employee’s ability to use a respirator, before the
employee is fit-tested or
required to use the respirator in the workplace: At least three
employees who were
required to use respiratory protection while working in the
frame assembly area were
not provided a medical evaluation.
ITEM

Date(s): 04/15/2015-04/16/2015
Citation 1 Item 4a Type of Violation: Serious
29 CFR 1910.134(f)(1): The employer did not ensure that
employees using a tight-fitting
facepiece respirator pass an appropriate qualitative fit test
(QLFT) or quantitative fit test
(QNFT) as stated in 29 CFR 1910(f): No fit testing was done for
employees who were
overexposed to lead and who are required to wear respirators

while working in the
frame assembly area.
ITEM
Date(s): 04/15/2015-04/16/2015
Citation 1 Item 4b Type of Violation: Serious
29 CFR 1910.134(g)(1)(i)(A): Respirators with tight-fitting
facepieces were worn by
employees who had facial hair that came between the sealing

surface of the facepiece
and the face or that interfered with valve function: Two
employees, who wore half mask
3M respirators, had beards which interfered with the face seal.
ITEM
Date(s): 04/15/2015-04/16/2015
29 CFR 1910.134(k)(1): The employer did not ensure that each
employee can

demonstrate knowledge of at least 29 CFR 1910.134(h)(1)(i)
through(vii): At least three
employees who were required to use respiratory protection
while working in the frame
assembly area were not trained in the use of respirators.
ITEM
Date(s): 04/15/2015-04/16/2015

29 CFR 1910.147(c)(1): The employer did not establish a
program consisting of an
energy control procedure and employee training to ensure that
before any employee
performed any servicing or maintenance on a machine or
equipment where the
unexpected energizing, start up or release of stored energy
could occur and cause
injury, the machine or equipment would be isolated, and
rendered inoperative in
accordance with 29 CFR 1910.147(c)(4): No energy control
program was developed for
employees who work on equipment including, but not limited
to, the mechanical
presses.
ITEM

Date(s): 04/15/2015-04/16/2015
29 CFR 191 0.1200(f)(5)(i): The employer did not ensure that
each container of
hazardous chemicals in the workplace was labeled, tagged or
marked with the identity
of the hazardous chemical( s) contained therein: a) At the
jobsite - The employer did not
ensure that each container of hazardous chemicals in the
workplace was labeled with
legible markings. The labels for three 5 gallon jugs containing
clear liquids were not
labeled. Employees in the area could not determine what the
liquids were. Observed on
04/15/2015 Abatement certification required within 10 days
after abatement date. The

certification shall include a statement that abatement is
complete, date and method of
abatement, and state employees and their representatives were
informed of this
abatement.
ITEM
Date(s): 04/15/2015-04/16/2015

29 CFR 1910.1200(g)(8): The employer did not maintain in the
workplace copies of the
required safety data sheets for each hazardous chemical, and did
not ensure that they
were readily accessible during each work shift to employees
when they were in their
work area( s)
The employer did not maintain safety data sheets to assist
employees working with
hazardous chemicals such as, but not limited to, Methyl Ethyl
Ketone, Acetone, and
Sulfuric Acid. Observed on 04/15/2015. Abatement certification
required within 10 days
after abatement date. The certification shall include a statement
that abatement is
complete, date and method of abatement, and states employees
and their
representatives were informed of this abatement.
ITEM

Date(s): 04/15/2015-04/16/2015
29 CPR 191 0.178(1)(1 )(ii): Prior to permitting an employee to
operate a powered
industrial truck (except for training purposes), the employer
shall ensure that each
operator has successfully completed the training required by
this paragraph (1), except
as permitted by paragraph (1)(5):
a. The employer did not ensure that employees received a
combination of formal
instruction (e.g., lecture, discussion, interactive computer
learning, video tape,

written material), practical training (demonstrations performed
by the trainer and
practical exercises performed by the trainee), and an evaluation
of the operator's
performance in the workplace prior to permitting each employee
to operate a
powered industrial truck.
ITEM
Date(s): 04/15/2015-04/16/2015

29 CFR 1910.305(g)(l)(iv)(A): Flexible cords and/or cables
were used as a substitute
for the fixed wiring of a structure:
Employees were exposed to electrical shock hazards while
operating equipment
such as, but not limited to computers controlling production
equipment which were
plugged into temporary electrical wiring:
a) Management had rerouted some of the computers from the
press area to a
neighboring office by using an electrical cord attached to a
surge protector and
routing it though the AC vent to the office.
b) At least 5 relocatable power taps were being used with one
electrical wall 120V
receptacle to provide power to at least 10 electrical devices
such as, but not limited
to, computers in the manufacturing area, office phones, cell
phone chargers, and
printers.

c) Several extension cords ran across the floor to computers in
the production area
and were not secured.
Date(s): 04/15/2015-04/16/2015
ITEM.

Date(s): 04/15/2015-04/16/2015
OSH Act of 1970 Section 5(a)(1): The employer did not furnish
employment and a place
of employment which were free from recognized hazards that
were causing or likely to
cause death or serious physical harm to employers, in that
employees were exposed to
chemicals that could be injurious to the eyes with no emergency
eyewash within 300
feet.
a. Employees in the parts washing area were using large
quantities of methyl ethyl
ketone and acetone to clean parts. The process required
employees to place
large parts into a solvent cleaning station and spray the parts
with Solven100®, a
mixture containing 75% MEK and 25% acetone. The spraying

process created a
high risk of the chemical splashing into the employee’s eyes.
ITEM
Date(s): 04/15/2015-04/16/2015
29 CFR 1910.138(a): The employer did not select and require
employee(s) to use
appropriate hand protection when the employees hands were

exposed to hazards such
as those from skin absorption of harmful substances and
chemical burns:
a. Employees in the parts washing area were using large
quantities of methyl ethyl
ketone and acetone to clean parts. The process required
employees to place
large parts into a solvent cleaning station and spray the parts
with Solven100®, a
mixture containing 75% MEK and 25% acetone. The employee
was then
required to use a rag dipped in the solution to wipe down the
parts. The
employee was not furnished with any impervious gloves.
ITEM
Date(s): 04/15/2015-04/16/2015

Citation 2 Item 1 Type of Violation: Willful
29 CFR 1910.1025(d)(2): An initial determination was not made
to determine if any
employee may be exposed to lead at or above the action level:
No air sampling was
done to determine if employees were over exposed to lead
during welding operations.
ITEM
Date(s): 04/15/2015-04/16/2015

Citation 2 Item 2a Type of Violation: Willful
29 CFR 1910.1025(1)(1)(i): Employee(s) working in an area
where there is potential
exposure to airborne lead at any level were not informed of the
content of Appendices A
and B of this regulation: No training was done for employees
who work on the site
casting lead containing alloys.
ITEM

Date(s): 04/15/2015-04/16/2015
Citation 2 Item 2b Type of Violation: Willful
29 CFR 1910.1025 (1)( 1 )(ii): A training program was not
instituted and required for all
employees who were subject to lead exposure at or above the
action level, or for whom
the possibility of skin or eye irritation existed: No training was
done for employees who
were overexposed to lead while welding in the frame assembly
area.
ITEM

Date(s): 04/15/2015-04/16/2015
Citation 2 Item 3a Type of Violation: Willful
29 CFR 1910.1 200(e)( 1): The employer did not develop,
implement, and/or maintain at
the workplace a written hazard communication program which
describes how the
criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be
met: No written hazard
communication program was developed for employees who
work on the site and are
exposed to hazardous chemicals including, but not limited to,

lead, methyl ethyl ketone,
acetone, and sulfuric acid.
ITEM
Date(s): 04/15/2015-04/16/2015
Citation 2 Item 3b Type of Violation: Willful
29 CFR 1910.1200(h)(1): Employees were not provided with
effective information and
training as specified in 29 CFR 1910.1200 (h)(2) and (3) on

hazardous substances in
their work area at the time of their initial assignment and
whenever a new hazard was
introduced into their work area: No training was provided for
employees who work on
the site and are exposed to hazardous chemicals including, but
not limited to, lead,
methyl ethyl ketone, acetone, and sulfuric acid.
ITEM
Denver Commons Office Plaza
111 Main St., Suite 111
Denver, CO 11111
Phone: (111) 111-1111 FAX: (222) 222-2222
INVOICE / DEBT COLLECTION NOTICE

Summary of Penalties for Inspection Number 111111111
Citation 1, Serious $59000.00
Citation 2, Willful $147000.00
TOTAL PROPOSED PENALTIES S206000.00
To avoid additional charges, please remit payment promptly to
this Area Office for the total amount of
the uncontested penalties summarized above. Make your check
or money order payable to: “DOL-
OSHA”. Please indicate OSHA’s Inspection Number (indicated
above) on the remittance.
OSHA does not agree to any restrictions or conditions or
endorsements put on any check or money
order for less than the full amount due, and will cash the check
or money order as if these restrictions or
conditions do not exist.
If a personal check is issued, it will be converted into an
electronic fund transfer (EFT). This means that
our bank will copy your check and use the account information
on it to electronically debit your account
for the amount of the check. The debit from your account will
then usually occur within 24 hours and
will be shown on your regular account statement. You will not
receive your original check back. The
bank will destroy your original check, but will keep a copy of
it. If the EFT cannot be completed because

of insufficient funds or closed account, the bank will attempt to
make the transfer up to 2 times.
Pursuant to the Debt Collection Act of 1982 (Public Law 97-
365) and regulations of the U.S. Department
of Labor (29 CFR Part 20), the Occupational Safety and Health
Administration is required to assess
interest, delinquent charges, and administrative costs for the
collection of delinquent penalty debts for
violations of the Occupational Safety and Health Act.
Interest: Interest charges will be assessed at an annual rate
determined by the
Secretary of the Treasury on all penalty debt amounts not paid
within one month (30
calendar days) of the date on which the debt amount becomes
due and payable
(penalty due date). The current interest rate is one percent (1%).
Interest will accrue
from the date on which the penalty amounts (as proposed or
adjusted) become a final
order of the Occupational Safety and Health Review
Commission (that is, 15 working
days from your receipt of the Citation and Notification of
Penalty), unless you file a
notice of contest. Interest charges will be waived if the full
amount owed is paid within
30 calendar days of the final order.
Delinquent Charges: A debt is considered delinquent if it has
not been paid within one
month (30 calendar days) of the penalty due date or if a

satisfactory payment
arrangement has not been made. If the debt remains delinquent
for more than 90
calendar days, a delinquent charge of six percent (6%) per
annum will be assessed
accruing from the date that the debt became delinquent.
Administrative Costs: Agencies of the Department of Labor are
required to assess
additional charges for the recovery of delinquent debts. These
additional charges are
administrative costs incurred by the Agency in its attempt to
collect an unpaid debt.
Administrative costs will be assessed for demand letters sent in
an attempt to collect the
unpaid debt.
____________________ _____________
John Smith Date
Area Director

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