Case Study: Local Metal Fabrication and Painting

A client of Compliance Technologies, Inc. (CTI) had received a notice of alleged workplace hazards at their facility from OSHA.  The nature of the alleged hazards was as follows:

“1. Employees are exposed to a strong chemical odor.”

While the complaint provided only a generalized starting point, OSHA requested in their letter that the company “immediately investigate the alleged conditions and make any necessary corrections or modifications” and gave the company seven (7) days to respond to advise OSHA, in writing, of the results of the company’s investigations into the allegations.

The company contacted CTI to investigate.  CTI quickly began an 8-hour time weighted average (TWA) employee exposure monitoring with four selected employees wearing Organic Vapor badges for their entire shift.   Based on the test results from a certified lab, CTI determined that the 8-hour time weighted average employee exposures to the “chemicals of concern” (COCs) at the facility were at levels below OSHA’s regulatory Permissible Exposure Limit (PEL) levels or the National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limit (REL) levels, where applicable. Therefore, CTI’s services helped this client respond to the OSHA complaint of an alleged odor problem in a timely manner and substantiate to the employees, the labor union and OSHA that no mandatory actions were warranted to bring the 8-hour TWA exposures to these chemicals of concern (COCs) to within acceptable levels.


Published by Stephen Kovatch

Senior Client Manager  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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