IH Exposure Assessment Enforcement Activities and Observations Anthony Pierpoint Office of Worker Safety and Health Enforcement Office of Enforcement

Enforcement Process  Enforcement staff are assigned sites to monitor  Review and evaluate performance and compliance information from numerous sources  Pursue cases of significance

Potential Enforcement Outcomes  Close investigation; no action  Issue an Enforcement Letter  Settlement  Issue a Preliminary Notice of Violation  Others (Compliance Order, Special Report Order)

Worker Safety and Health Enforcement Activities Notices of Violation Babcock & Wilcox Technical Services, Y-12 LLC Worker Injury from Lithium Hydride Exposure – Unintentional Firearm Discharge Los Alamos National SecurityWorker Exposure to Chlorine National Security Technologies, LLCWork Injuries from Chemical Drum Explosion Sandia CorporationWorker Safety and Health Program Implementation UT-Battelle, LLCWorker Injuries – Material Handling and Ergonomic Hazards

Lithium Hydride B&W Y‐12 / Y‐12 National Security Complex  LiH Exposure – Worker sustained first and second-degree burns and respiratory injury  Regulatory Deficiencies  Personal Protective Equipment  Hazardous Energy Control  Fine Violations  $150,000 civil penalty  Mitigation for response and corrective actions

Worker Exposure to Chlorine Los Alamos National Security, LLC/Los Alamos National Laboratory  Multiple Workers Exposed to Chlorine  Job scoping task to plan for legacy apparatus removal  Regulatory Deficiencies  Hazard Identification, assessment and control  Management Responsibilities  Civil Penalty Waived  Fee reduction

Worker Exposure to Material Handling/Ergonomic Hazards UT-Battelle, LLC/Oak Ridge National Laboratory  Programmatic Investigation – Two Events with Injury  Regulatory Deficiencies  Management Responsibilities  Hazard Identification and assessment  Hazard Prevention and Abatement – Hierarchy of Controls  Material Handling Limits (ACGIH TLVs and NIOSH RWLs)  Fine Violations  $131,250 Civil Penalty  50% Mitigation for response and corrective actions

Worker Injuries – Drum Explosion National Security Technologies, LLC / Nevada National Security Site  Detonation of isopropyl alcohol peroxide  NNSA/NSTec joint accident investigation  Regulatory deficiencies  Hazard identification/assessment in work planning and control process  Chemical management  Hazard communication  Fire protection  Five violations – contract fee reduction of $2.05 million  Corrective actions address regulatory issues

Unintentional Detonator Initiation and Lithium Ion Battery Fire Sandia Corporation / Sandia National Laboratories  Events revealed deficiencies in Part 851 Worker Safety and Health Program implementation  Regulatory deficiencies  Management responsibilities  Hazard identification/assessment  Hazard control  Emergency response  Training and information  Recordkeeping and reporting  Six violations – contract fee reduction of $686,000  Four recurring violations of Part 851  Corrective actions address regulatory issues

Worker Safety and Health Enforcement Activities Enforcement Letters and Consent Orders ELURS Energy and Construction, Inc.Silica Exposure ELNational Security Technologies, LLCN-propyl Bromide Exposure EL CO Armor Towers, Construction Consultants, L.I., Inc. Brookhaven Science Associates RF Exposure

Worker Safety and Health Enforcement Activities Current Investigations Potassium Hydroxide Injury Worker Retaliation and Occupational Medicine Program Heat Stress Ozone Exposure

Part 851 Implementation Challenges  ACGIH TLV’s and NFPA  Supervisory/Management Oversight  Subcontractor Oversight  Hierarchy of Controls  Training and Information  Medical Emergency Planning and Response  Recurrence of Violations

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