Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.
____________________________________
ELIZABETH DOLE, SECRETARY OF LABOR, )
                                    )
                    Complainant,    )
                                    )
              v.                    )    OSHRC Docket
                                    )    No. 89-1505
                                    )
LOCKHEED AERONAUTICAL               )
  SYSTEMS COMPANY                   )
                                    )
                    Respondent.     )
____________________________________)

 

SETTLEMENT AGREEMENT

 

Complainant, Elizabeth Dole, Secretary of Labor, United States Department of Labor, and Respondent, Lockheed Aeronautical Systems Company, pursuant to Rule 100 of the Rules of the Occupational Safety and Health Review Commission (the "Commission"), hereby agree to the disposition of this matter on the following terms:

1. Complainant hereby amends citation No. 2 to combine the enumerated citations into single citations as follows:

     -    285 (includes 305, 322)
     -    286 (includes 291, 306)
     -    287 (includes 292, 307)
     -    288 (includes 293, 320, 329)
     -    289 (includes 295, 301, 309, 323, 330)
     -    296 (includes 310, 324)
     -    297 (includes 311, 325)
     -    298 (includes 312, 326, 331)
     -    299 (includes 315, 327)
     -    300 (includes 308, 321)
     -    304 (includes 319, 328)
     -    313 (includes 332)

2. Complainant hereby amends Citation Number 2 as follows:

Items 1 through 341 are hereby reclassified from Type of Violation(s) "Willful" to Type of Violation(s) "Section 17 of the Occupational Safety and Health Act."

3. Respondent does not object to the Complainant amending the Citations and Notifications of Proposed Penalty as set forth in Paragraphs 1 and 2 above.

4. Respondent hereby withdraws its Notice of Contest to the Citations and Notifications of Proposed Penalty at issue in this action, as amended herein.

5.a. Respondent represents that it has abated the cited conditions or will abate those conditions within 30 days of the signing of this agreement. Respondent will implement and perform those tasks set forth in Attachment 1 hereto (Health and Safety Task Force Program Plan) in accordance with the schedule set forth therein at the Burbank, Palmdale, and Rye Canyon facilities of the Lockheed Aeronautical Systems Company.

b. Respondent agrees that it will review its recordkeeping practices at the above facilities to ascertain and assure that its records, going back to July 1, 1987, are currently in compliance with the Act, the recordkeeping regulations at 29 CFR Part 1904, the OSHA No. 200 Log, and the Revised BLS Recordkeeping Guidelines for Occupational Injuries and Illnesses, effective April 1986.

c. Respondent agrees to maintain hereafter its injury and illness records in accord with the Act, the recordkeeping regulations at 29 CFR Part 1904, the OSHA No. 200 Log, and the Revised BLS Recordkeeping Guidelines for Occupational Injuries and Illnesses, effective April 1986, and as they may from time to time be revised.

6. Complainant does not object to the withdrawal of Respondent's Notice of Contest as set forth in Paragraph 4 above.

7. Nothing contained in this Settlement Agreement, the Citations and Notifications of Penalty, Respondent's Notice of Contest, Respondent's withdrawal of its Notice of Contest, Respondent's failure to continue to contest, Respondent's abatement of the alleged violations, Respondent's performance of the tasks set forth in Attachment 1 hereto, Respondent's payment of any penalties or the Commission's Final Order entered pursuant to this Settlement Agreement: (1) shall constitute or be considered, offered or admitted as evidence or an admission on the part of Respondent, in whole or in part, in any proceeding or litigation in any court, agency or forum whatsoever, except in proceedings brought directly under the Occupational Safety and Health Act by the Occupational Safety and Health Administration; or (2) shall, without limiting in any way the foregoing, constitute or be considered, offered or admitted as evidence or an admission on the part of Respondent, in whole or in part, in any proceeding or litigation in any court, agency or forum whatsoever, that any of the conditions alleged in the Citations(s) exist or existed or are or were the cause, or a cause, proximate or otherwise, of any accident, injury or illness or damages, if any, allegedly resulting therefrom. Moreover, the Citation(s) shall not be used as a basis or support for any other Citation(s) with respect to inspection(s) of the Burbank, Palmdale, and Rye Canyon facilities initiated prior to the date of this Settlement Agreement. The agreements, statements, pleadings and actions taken herein are made for the purpose of compromising and settling this matter amicably in the spirit of conciliation to avoid protracted and expensive litigation.

8. In accordance with Rules 7 and 100 of the Rules of Procedure of the Commission, Respondent shall give this Settlement Agreement to affected employees represented by an authorized employee representative by serving a copy of it on said representative. In accordance with Rules 7 and 100 of the Rules of Procedure of the Commission, Respondent shall give this Settlement Agreement to affected employees, if any, not represented by an authorized employee representative by posting it in a place where citations are required to be posted.

9. Complainant and Respondent agree and request that an order be entered by the Commission which approves this Settlement Agreement, with no costs, fees or other expenses to be assessed or awarded to any of the parties.

10. Respondent will remit the penalty of $1,495,560 to the Complainant within 15 days of the effective date of a final order approving this settlement agreement.

                              By:  Edward J. Faeder
                                   EDWARD J. FAEDER
                                   Environmental Protection
                                     and Safety Branch
                                   Lockheed Aeronautical
                                     Systems Co.

                        Reviewed:  Thomas J. Smith
                                   THOMAS J. SMITH, ESQ.
                                   Lockheed Aeronautical
                                     Systems Co.

                           Dated:  6/30/89

                                   ROBERT P. DAVIS
                                   Solictor of Labor

                              By:  Jerry G. Thorn
                                   JERRY G. THORN
                                   Deputy Solicitor

                                   DANIEL TEEHAN
                                   Regional Solicitor

                           Dated:  6/30/89


 STATUS DATE: 06/20/89    TIME: 07.46.51
SYSTEM NAME:  HEALTH AND SAFETY FIRST      RESP: T. KALLMAN/P. ST. CLAIR
                                           CHART NO: 1
__________________________________________________________________________
|                           |S|            |H|    All Dates shown are    |
|                           |T|            |O|     week ending dates     |
|       TASKS               |A|  ASSIGNED  |U|       for 1989/1990       |
|                           |T|     TO     |R|___________________________|
|                           |U|            |S|                           |
|                           |S|            | |                           |
|___________________________|_|____________|_|___________________________|
|                           | |            | |                           |
|I. Develop standards and   | |            | |                           |
|   checklists to be used   | |            | |                           |
|   during the wall to wall | |            | |                           |
|   reviews. Specifically:  | |            | |                           |
|                           | |            | |                           |
| A. Establish guidelines to|C| Allyn/Tsuda| | * May 5                   |
|   be followed during the  | |            | |                           |
|   general housekeeping    | |            | |                           |
|   sweep for segregating   | |            | |                           |
|   and storing hazardous   | |            | |                           |
|   material in a staging   | |            | |                           |
|   area until the material | |            | |                           |
|   can be properly         | |            | |                           |
|   dispositioned (i.e.     | |            | |                           |
|   labeled and stored or   | |            | |                           |
|   removed as hazardous    | |            | |                           |
|   waste).                 | |            | |                           |
|                           | |            | |                           |
| B. Develop a checklist to |C| Kallum     | | * May 5                   |
|   be used for performing  | |            | |                           |
|   the wall to wall        | |            | |                           |
|   building safety         | |            | |                           |
|   inspection:             | |            | |                           |
|                           | |            | |                           |
|   1. Office and Admin.    |C| Kallum     | | * May 5                   |
|   areas                   | |            | |                           |
|                           | |            | |                           |
|   2. All other areas      |C| Kallum     | | * May 5                   |
|                           | |            | |                           |
|II. Conduct complete       | |            | |                           |
|   building sweeps to      | |            | |                           |
|   identify and correct    | |            | |                           |
|   housekeeping and safety | |            | |                           |
|   issues, specifically:   | |            | |                           |
|                           | |            | |                           |
| A. Perform general        | |            | |                           |
|   housekeeping survey     | |            | |                           |
|   and cleanup             | |            | |                           |
|                           | |            | |                           |
|   1. ADP                  |R| McManigell | | ____X thru June 30        |
|                           | |            | |                           |
|   2. ATF                  |C| Cantrell   | | _* thru May 5             |
|                           | |            | |                           |
|   3. H.Q. OPS             |C| Wilken     | | ____X thru May 26         |
|                           | |            | |                           |
|   4. RT&E                 |R| Gunther    | | ____X thru June 30        |
|                           | |            | |                           |
|   5. ALL OTHER            |R| Melvin     | | X____X May 5 thru June 30 |
|                           | |            | |                           |
| B. Perform wall to wall   | |            | |                           |
|   physical safety and     | |            | |                           |
|   fire department         | |            | |                           |
|   inspection to identify  | |            | |                           |
|   all deficient conditions| |            | |                           |
|                           | |            | |                           |
|   1. ADP                  |T| McManigell | | _(Completion 05/31/1992)  |
|                           | |            | |                           |
|   2. ATF                  |C| Cantrell   | | _* thru May 5             |
|                           | |            | |                           |
|   3. H.Q. OPS             |T| Wilken     | | ______X thru Sep 29       |
|                           | |            | |                           |
|   4. RT&E                 |T| Gunther    | | ______X thru Sep 22       |
|                           | |            | |                           |
|   5. ALL OTHER            |T| Melvin     | | X_____X May 5 thru Oct 27 |
|                           | |            | |                           |
| C. Correct deficiencies   | |            | |                           |
|   noted in II. B.         | |            | |                           |
|                           | |            | |                           |
|   1. ADP                  |T| McManigell | | _(Completion by May 1992) |
|                           | |            | |                           |
|   2. ATF                  | | Cantrell   | | (TBD)                     |
|                           | |            | |                           |
|   3. H.Q. OPS             | | Wilken     | | (TBD)                     |
|                           | |            | |                           |
|   4. RT&E                 | | Gunther    | | (TBD)                     |
|                           | |            | |                           |
|   5. ALL OTHER            | | Melvin     | | (TBD)                     |
|                           | |            | |                           |
| D. Perform wall to wall   | |            | |                           |
|   search of each building | |            | |                           |
|   to identify unlabeled   | |            | |                           |
|   products and ensure that| |            | |                           |
|   approved labels are     | |            | |                           |
|   affixed or materials are| |            | |                           |
|   properly dispositioned. | |            | |                           |
|   In addition identify any| |            | |                           |
|   central dispensing      | |            | |                           |
|   points and establish a  | |            | |                           |
|   procedure to ensure that| |            | |                           |
|   any containers of       | |            | |                           |
|   dispensed products are  | |            | |                           |
|   appropriately labeled on| |            | |                           |
|   an on-going basis       | |            | |                           |
|                           | |            | |                           |
|   1. ADP                  |R| McManigell | | X___X June 2 thru July 28 |
|                           | |            | |                           |
|   2. ATF                  |R| Cantrell   | | X___X June 2 thru July 28 |
|                           | |            | |                           |
|   3. H.Q. OPS             |R| Wilken     | | X___X June 2 thru July 28 |
|                           | |            | |                           |
|   4. RT&E                 |R| Gunther    | | X___X June 2 thru July 28 |
|                           | |            | |                           |
|   5. ALL OTHERS           |R| Melvin     | | X___X June 2 thru July 28 |
|                           | |            | |                           |
| E. In conjunction with    | |            | |                           |
|   step II.D. develop/     | |            | |                           |
|   update required         | |            | |                           |
|   inventory records of    | |            | |                           |
|   chemicals used in the   | |            | |                           |
|   workplace by department | |            | |                           |
|   and insure that required| |            | |                           |
|   MSDSs are on file.      | |            | |                           |
|                           | |            | |                           |
|   1. ADP                  |R| McManigell | | X___X June 2 thru July 28 |
|                           | |            | |                           |
|   2. ATF                  |R| Cantrell   | | X___X June 2 thru July 28 |
|                           | |            | |                           |
|   3. H.Q. OPS             |R| Wilken     | | X___X June 2 thru July 28 |
|                           | |            | |                           |
|   4. RT&E                 |R| Gunther    | | X___X June 2 thru July 28 |
|                           | |            | |                           |
|   5. ALL OTHERS           |R| Melvin     | | X___X June 2 thru July 28 |
|                           | |            | |                           |
| F. Implement program to   | | Allyn      | | X (TBD) Oct               |
|   review and evaluate     | |            | |                           |
|   adequacy of vendor      | |            | |                           |
|   labels and MSDSs.       | |            | |                           |
|                           | |            | |                           |
| G. Establish guidelines   | | Allyn/     | |                           |
|   for continuing regular  | | StClair    | |                           |
|   housekeeping and safety | |            | |                           |
|   inspections after       | |            | |                           |
|   initial sweeps are      | |            | |                           |
|   completed. These        | |            | |                           |
|   guidelines are to be    | |            | |                           |
|   followed until company- | |            | |                           |
|   wide compliance program | |            | |                           |
|   (Step XIII) is completed| |            | |                           |
|                           | |            | |                           |
|   1. HOUSEKEEPING         |R|            | | _____X thru July 21       |
|                           | |            | |                           |
|   2. SAFETY               |R|            | | X___X June 30 thru July 28|
|___________________________|_|____________|_|___________________________|
| X = Milestone      * = Completed Milestone    R = Rescheduled Milestone|
| X___X = Time Span  R____R = Rescheduled Span  B = Block Release        |
| # = Schedule Position      (TBO) = To be determined                    |
|________________________________________________________________________|
|                                                                        |
| Status Codes:  C = Completed   T = Tracking (on schedule)              |
|                X = Behind schedule & threatens user need date          |
|                R = Rescheduled but does not threaten user need dates   |
|________________________________________________________________________|
|                           | |            | |                           |
|III. Enhance program for   | |            | |                           |
|    providing personnel    | |            | |                           |
|    protection equipment   | |            | |                           |
|    where required         | |            | |                           |
|                           | |            | |                           |
| A. Define requirements    |R| Allyn      | |                           |
|   for documenting results | |            | |                           |
|   of work place           | |            | |                           |
|   surveillance program.   | |            | |                           |
|                           | |            | |                           |
| B. Review and revise as   |R| Allyn      | | X___X June 5 thru Aug 25  |
|   necessary workplace     | |            | |                           |
|   surveillance program    | |            | |                           |
|   data reporting system   | |            | |                           |
|   and records management  | |            | |                           |
|   system.                 | |            | |                           |
|                           | |            | |                           |
| C. Develop questionaire   |C| Allyn      | | * May 5                   |
|   to be used to identify  | |            | |                           |

|   areas which might       | |            | |                           |
|   require monitoring by   | |            | |                           |
|   safety and health (e.g.,| |            | |                           |
|   noise, toxic exposure,  | |            | |                           |
|   etc.)                   | |            | |                           |
|                           | |            | |                           |
| D. Conduct surveys using  | |            | |                           |
|   (B) above and identify  | |            | |                           |
|   areas which might       | |            | |                           |
|   require monitoring by   | |            | |                           |
|   safety and health.      | |            | |                           |
|                           | |            | |                           |
|   1. ADP                  |R| McManigell | | X___X May 12 thru June 30 |
|                           | |            | |                           |
|   2. ATF                  |R| Cantrell   | | X___X May 12 thru June 30 |
|                           | |            | |                           |
|   3. H.Q. OPS             |R| Wilken     | | X___X May 12 thru June 30 |
|                           | |            | |                           |
|   4. RT&E                 |R| Gunther    | | X___X May 12 thru June 30 |
|                           | |            | |                           |
|   5. ALL OTHER            |R| Melvin     | | X___X May 12 thru June 30 |
|                           | |            | |                           |
| E. Using the information  |R| Allyn      | | X___X June 9 thru Aug 4   |
|   in II.C. identify those | |            | |                           |
|   locations that don't    | |            | |                           |
|   have current data on-   | |            | |                           |
|   hand and establish a    | |            | |                           |
|   schedule for baseline   | |            | |                           |
|   monitoring.             | |            | |                           |
|                           | |            | |                           |
| F. Conduct baseline       |R| Allyn      | | X___X July 21 thru Nov 10 |
|   monitoring, post        | |            | |                           |
|   required information,   | |            | |                           |
|   inform medical as       | |            | |                           |
|   appropriate, provide the| |            | |                           |
|   employees with the      | |            | |                           |
|   necessary equipment and | |            | |                           |
|   train as appropriate.   | |            | |                           |
|                           | |            | |                           |
| G. Develop and implement  | |            | |                           |
|   a procedure to ensure   | |            | |                           |
|   that EPSO is informed   | |            | |                           |
|   whenever:               | |            | |                           |
|                           | |            | |                           |
|   1. A change in a        | | Goetz/Krupp| |                           |
|   process or machinery    | |Kramer/Allyn| |                           |
|   configuration occurs.   | |            | |                           |
|                           | |            | |                           |
|     Develop Plan          |R|            | | ______X thru July 14      |
|                           | |            | |                           |
|     Implement Plan        | |            | | (TBD)                     |
|                           | |            | |                           |
|   2. New facility         | |Kramer/Allyn| |                           |
|   construction or major   | | Pretto     | |                           |
|   modification is         | |            | |                           |
|     implemented.          | |            | |                           |
|                           | |            | |                           |
|     Develop Plan          |R|            | | ______X thru July 14      |
|                           | |            | |                           |
|     Implement Plan        | |            | | (TBD)                     |
|                           | |            | |                           |
|   3. A new chemical is    | |Goetz/Krupp/| | ______X thru July 14      |
|   being evaluated for     | |Allyn       | |                           |
|   introduction into the   | |            | |                           |
|   workplace.              | |            | |                           |
|                           | |            | |                           |
|   4. In the design and    | |Goetz/Krupp/| |                           |
|   development of new      | |Allyn       | |                           |
|   processes. (Mfg should  | |            | |                           |
|   be in the loop).        | |            | |                           |
|                           | |            | |                           |
|     Develop Plan          |R|            | | _____X thru June 30       |
|                           | |            | |                           |
|     Implement Plan        | |            | | TBD                       |
|                           | |            | |                           |
| H. Establish safety cribs | |            | |                           |
|   to meet the company and | |            | |                           |
|   employees safety needs. | |            | |                           |
|                           | |            | |                           |
|   1. Evaluate the need for|C| StClair/   | | _* thru May 5             |
|   safety cribs and prepare| |Team Leaders| |                           |
|   a recommendation        | |            | |                           |
|   regarding the number    | |            | |                           |
|   required, their location| |            | |                           |
|   and estimated           | |            | |                           |
|   construction cost.      | |            | |                           |
|                           | |            | |                           |
|   2. Construct safety     |T| Kramer     | | X____X June 2 thru July 28|
|   cribs and stock each    | |            | |                           |
|   crib with the necessary | |            | |                           |
|   equipment.              | |            | |                           |
|                           | |            | |                           |
|   3. Safety crib attendant| |            | |                           |
|                           | |            | |                           |
|     A. Establish the job  |C| Allyn/     | | _* thru May 5             |
|     definition for a      | | Bevans     | |                           |
|     safety crib attendant | |            | |                           |
|                           | |            | |                           |
|     B. Identify & train   |C| Allyn/     | | X----* May 12 thru June 16|
|     individuals to staff  | | Bevans     | |                           |
|     the cribs.            | |            | |                           |
|                           | |            | |                           |
| I. Hand Protection        | |            | |                           |
|                           | |            | |                           |
|   1. Evaluate the hand    | | Allyn      | | X____X June 16 thru Sep 29|
|   protection needs        | |            | |                           |
|   company-wide and        | |            | |                           |
|   establish a glove       | |            | |                           |
|   guidance program which  | |            | |                           |
|   meets all needs and     | |            | |                           |
|   eliminates the current  | |            | |                           |
|   confusion.              | |            | |                           |
|                           | |            | |                           |
|   2. Stock the safety     | | Allyn      | | X____X Aug 4 thru Sep 29  |
|   cribs according to the  | |            | |                           |
|   guidance developed in   | |            | |                           |
|   III.I.1. Also prepare   | |            | |                           |
|   and post glove guidance | |            | |                           |
|   charts at all the safety| |            | |                           |
|   cribs.                  | |            | |                           |
|                           | |            | |                           |
|___________________________|_|____________|_|___________________________|
|                                                                        |
| X = Milestone      * = Completed Milestone    R = Rescheduled Milestone|
| X___X = Time Span  R____R = Rescheduled Span  B = Block Release        |
| # = Schedule Position      (TBO) = To be determined                    |
|________________________________________________________________________|
|                                                                        |
| Status Codes:  C = Completed   T = Tracking (on schedule)              |
|                X = Behind schedule & threatens user need date          |
|                R = Rescheduled but does not threaten user need dates   |
|________________________________________________________________________|
|                           | |            | |                           |
|IV. Review and revise      | |            | |                           |
|   hazard communication    | |            | |                           |
|   and hazardous material  | |            | |                           |
|   handling as required    | |            | |                           |
|   specifically.           | |            | |                           |
|                           | |            | |                           |
| A. Evaluate procedures for| | Tsuda/     | |                           |
|   ordering, receiving and | | Jacobson/  | |                           |
|   and distributing        | | Smith      | |                           |
|   hazardous materials and | |            | |                           |
|   propose recommendations | |            | |                           |
|   for needed changes so as| |            | |                           |
|   to ensure all hazardous | |            | |                           |
|   materials received are  | |            | |                           |
|   accompanied by MSDSs    | |            | |                           |
|   and properly labeled.   | |            | |                           |
|                           | |            | |                           |
|   1. Evaluation of present|C|            | | ___* thru May 19          |
|   system                  | |            | |                           |
|                           | |            | |                           |
|   2. Recommendations and  | |            | |(Referred to separate team)|
|   development of new      | |            | |                           |
|   system                  | |            | |                           |
|                           | |            | |                           |
|   3. Implementation of    |T|            | | X____X June 2 thru July 28|
|   short term fixes (i.e.  | |            | |                           |
|   P.O. clause and material| |            | |                           |
|   authorizing directives) | |            | |                           |
|                           | |            | |                           |
| B. MSDS for Lockheed      | |            | |                           |
|   generated products:     | |            | |                           |
|                           | |            | |                           |
|   1. Identify Lockheed    |C|Allyn/Goetz/| | * May 5                   |
|   MSDS which need to be   | |Krupp       | |                           |
|   rewritten.              | |            | |                           |
|                           | |            | |                           |
|   2. Review and rewrite   |T| Allyn      | | _______X thru Sep 29      |
|   all Lockheed MSDSs as   | |            | |                           |
|   determined necessary    | |            | |                           |
|                           | |            | |                           |
| C. Develop procedure for  | |Goetz/Allyn | | X____X Sep 29 thru Dec 1  |
|   updating MSDSs within 90| | Krupp      | |                           |
|   days of the availability| |            | |                           |
|   of new information.     | |            | |                           |
|                           | |            | |                           |
| D. Central Database       | |            | |                           |
|                           | |            | |                           |
|   1. Establish central    |R| Allyn      | | X____X July 7 thru Oct 27 |
|   database of department  | |            | |                           |
|   chemical MSDS inven-    | |            | |                           |
|   tories for all LASC.    | |            | |                           |
|                           | |            | |                           |
|   2. Review and revise as |R| Allyn      | | X____X June 2 thru June 30|
|   appropriate procedures  | |            | |                           |
|   to ensure that central  | |            | |                           |
|   database is updated as  | |            | |                           |
|   changes occur in the    | |            | |                           |
|   departmental inventories| |            | |                           |
|   (Coordinate with IV.A)  | |            | |                           |
|                           | |            | |                           |
| E. Implement program to   | |            | |                           |
|   bring all LASC buildings| |            | |                           |
|   (within California) into| |            | |                           |
|   compliance with the     | |            | |                           |
|   "asbestos warning"      | |            | |                           |
|   requirement of assembly | |            | |                           |
|   bill 1373.              | |            | |                           |
|                           | |            | |                           |
|  1. Identify all buildings|C| Allyn/     | | _* thru May 5             |
|  which contain asbestos.  | | Kramer     | |                           |
|                           | |            | |                           |
|  2. Issue notices to      |R| Allyn/Land/| | _____X thru June 23       |
|  employees.               | | P.R.       | |                           |
|                           | |            | |                           |
| F. Evaluate need for      |C| Kallman/   | | _____X thru May 26        |
|   environmental health    | | Branches   | |                           |
|   and safety coordinators | |            | |                           |
|   within the operating    | |            | |                           |
|   branches.(Implementation| |            | |                           |
|   will be coordinated with| |            | |                           |
|   Task XII)               | |            | |                           |
|                           | |            | |                           |
| G. Evaluate the current   | | Allyn/     | |                           |
|   practices for disposing/| | Branches   | |                           |
|   handling hazardous waste| |            | |                           |
|   material and recommend  | |            | |                           |
|   a program for handling  | |            | |                           |
|   the waste material:     | |            | |                           |
|                           | |            | |                           |
|     1. Short Term         |C|            | | * May 5                   |
|                           | |            | |                           |
|     2. Long Term          |T|            | | (See Task IV A)           |
|                           | |            | |                           |
|___________________________|_|____________|_|___________________________|
|                                                                        |
| X = Milestone      * = Completed Milestone    R = Rescheduled Milestone|
| X___X = Time Span  R____R = Rescheduled Span  B = Block Release        |
| # = Schedule Position      (TBO) = To be determined                    |
|________________________________________________________________________|
|                                                                        |
| Status Codes:  C = Completed   T = Tracking (on schedule)              |
|                X = Behind schedule & threatens user need date          |
|                R = Rescheduled but does not threaten user need dates   |
|________________________________________________________________________|
|                           | |            | |                           |
|V. Review and revise       | |            | |                           |
|  training certification   | |            | |                           |
|  program.                 | |            | |                           |
|                           | |            | |                           |
| A. New employee           | |            | |                           |
|   orientation             | |            | |                           |
|                           | |            | |                           |
|   1. Revise orientation   |R|Allyn/Bevans| | _______X thru Aug 25      |
|   training program to     | |            | |                           |
|   include noise training  | |            | |                           |
|   hazardous material      | |            | |                           |
|   handling and general    | |            | |                           |
|   safety.                 | |            | |                           |
|                           | |            | |                           |
|   2. Define who is to     |C| Allyn/     | | _* thru May 5             |
|   receive orientation     | | Branches   | |                           |
|   training (should include| |            | |                           |
|   salary employees)       | |            | |                           |
|                           | |            | |                           |
| B. Review & revise        | | Allyn/     | |                           |
|   environmental health    | | Branches   | |                           |
|   and safety training as  | |            | |                           |
|   necessary.              | |            | |                           |
|                           | |            | |                           |
|      1. Short Term        |C|            | | _____* thru June 2        |
|                           | |            | |                           |
|      2. Long Term         |R|            | | X____X May 26 thru Oct 27 |
|                           | |            | |                           |
| C. Develop annual safety  |R| Allyn/     | | X____X June 30 thru Oct 27|
|   training course for the | | Branches   | |                           |
|   different occupational  | |            | |                           |
|   groups (eg., factory vs.| |            | |                           |
|   office workers)         | |            | |                           |
|                           | |            | |                           |
| D. 1. Review certs program|C|Allyn/Bevans| | _* thru May 5             |
|    and revise as needed so| |            | |                           |
|    shop supervisors can   | |            | |                           |
|    easily determine an    | |            | |                           |
|    employees current      | |            | |                           |
|    certifications and     | |            | |                           |
|    their renewal dates.   | |            | |                           |
|                           | |            | |                           |
| D. 2. Review & Revise as  |R| Allyn/     | | X____X June 2 thru June 30|
|    needed certification   | | Bevans/    | |                           |
|    and medical limitations| | Branches   | |                           |
|    identification         | |            | |                           |
|    procedures.            | |            | |                           |
|                           | |            | |                           |
| E. Evaluate how annual    | | Faeder     | | X____X Sep 1 thru Dec 22  |
|   safety & health training| |            | |                           |
|   programs will be staffed| |            | |                           |
|                           | |            | |                           |
|___________________________|_|____________|_|___________________________|
|                                                                        |
| X = Milestone      * = Completed Milestone    R = Rescheduled Milestone|
| X___X = Time Span  R____R = Rescheduled Span  B = Block Release        |
| # = Schedule Position      (TBO) = To be determined                    |
|________________________________________________________________________|
|                                                                        |
| Status Codes:  C = Completed   T = Tracking (on schedule)              |
|                X = Behind schedule & threatens user need date          |
|                R = Rescheduled but does not threaten user need dates   |
|________________________________________________________________________|
|                           | |            | |                           |
|VI. Review and revise as   | |            | |                           |
|   appropriate LASC's      | |            | |                           |
|   medical monitoring      | |            | |                           |
|   program.                | |            | |                           |
|                           | |            | |                           |
| A. For the various shop   | |Allyn/Bevans| | (TBD)                     |
|   areas define the various| |Pleasant/   | |                           |
|   qualifications/certifi- | |            | |                           |
|   cations require to work | |            | |                           |
|   in that area. (Utilize  | |            | |                           |
|   info from III. B. & C.  | |            | |                           |
|   to determine these      | |            | |                           |
|   requirements)           | |            | |                           |
|                           | |            | |                           |
| B. Using the information  | |Allyn/Bevans| | (TBD)                     |
|   from VI.A. revise the   | | Pleasant   | |                           |

|   preplacement exams and  | |            | |                           |
|   annual medical monitor- | |            | |                           |
|   ing requirements for    | |            | |                           |
|   people working in the   | |            | |                           |
|   various areas.          | |            | |                           |
|                           | |            | |                           |
|___________________________|_|____________|_|___________________________|
|                                                                        |
| X = Milestone      * = Completed Milestone    R = Rescheduled Milestone|
| X___X = Time Span  R____R = Rescheduled Span  B = Block Release        |
| # = Schedule Position      (TBO) = To be determined                    |
|________________________________________________________________________|
|                                                                        |
| Status Codes:  C = Completed   T = Tracking (on schedule)              |
|                X = Behind schedule & threatens user need date          |
|                R = Rescheduled but does not threaten user need dates   |
|________________________________________________________________________|
|                           | |            | |                           |
|VII. Disaster preparedness/| |            | |                           |
|    fire prevention        | |            | |                           |
|    planning.              | |            | |                           |
|                           | |            | |                           |
| A. Fire prevention plan   | |            | |                           |
|                           | |            | |                           |
|   1. Develop fire         |R| Cotton     | | ____X thru June 30        |
|   prevention plan.        | |            | |                           |
|                           | |            | |                           |
|   2. Print and distribute |R| StClair/   | | X___X July 7 thru July 28 |
|   fire prevention plan.   | | Gillett    | |                           |
|                           | |            | |                           |
|   3. Develop briefing     |C| Cotton/    | | ____* thru May 19         |
|   instructions for        | | Bevans     | |                           |
|   managers on fire        | |            | |                           |
|   prevention plan.        | |            | |                           |
|                           | |            | |                           |
| B. Emergency evacuation   | |            | |                           |
|   plans.                  | |            | |                           |
|                           | |            | |                           |
|   1. Complete evacuation  |T| Callahan/  | | _______X thru Dec 22      |
|   guides and building plot| | Cain       | |                           |
|   plans.                  | |            | |                           |
|                           | |            | |                           |
|   2. Distribute guides,   |T| Callahan/  | |_(Completion by April 1990)|
|   train employees and     | | Cain       | |                           |
|   conduct drills.         | |            | |                           |
|                           | |            | |                           |
|   3. Identify buildings   |T| Callahan/  | | _______X thru Aug 25      |
|   needing alarms or P.A.  | | Cain       | |                           |
|   systems.                | |            | |                           |
|                           | |            | |                           |
|   4. Install/repair alarms| | Kramer     | | (TBD)                     |
|   and P.A. systems as     | |            | |                           |
|   required.               | |            | |                           |
|                           | |            | |                           |
| C. Establish a procedure  |C| Kramer     | | X____* May 5 thru May 26  |
|   for updating building   | |            | |                           |
|   plot plans when major   | |            | |                           |
|   changes to buildings    | |            | |                           |
|   occur.                  | |            | |                           |
|                           | |            | |                           |
|___________________________|_|____________|_|___________________________|
|                                                                        |
| X = Milestone      * = Completed Milestone    R = Rescheduled Milestone|
| X___X = Time Span  R____R = Rescheduled Span  B = Block Release        |
| # = Schedule Position      (TBO) = To be determined                    |
|________________________________________________________________________|
|                                                                        |
| Status Codes:  C = Completed   T = Tracking (on schedule)              |
|                X = Behind schedule & threatens user need date          |
|                R = Rescheduled but does not threaten user need dates   |
|________________________________________________________________________|
|                           | |            | |                           |
|VIII. Fire inspection/     | |            | |                           |
|     prevention program    | |            | |                           |
|                           | |            | |                           |
| A. Review the current fire|C| Cotton     | | ____* thru May 19         |
|   safety inspection       | |            | |                           |
|   program and as approp-  | |            | |                           |
|   riate redefine the areas| |            | |                           |
|   that need to be incorp- | |            | |                           |
|   orated into the scope of| |            | |                           |
|   coverage.               | |            | |                           |
|                           | |            | |                           |
| B. Using the results of   |T| Cotton     | | X____X May 26 thru June 30|
|   VIII.A. Establish review| |            | |                           |
|   schedules for each of   | |            | |                           |
|   the elements defined in | |            | |                           |
|   A above. Schedule(s)    | |            | |                           |
|   should identify inspec- | |            | |                           |
|   tion activity, locations| |            | |                           |
|   and frequency.          | |            | |                           |
|                           | |            | |                           |
| C. For each inspection    |T| Cotton     | | X____X May 26 thru July 14|
|   activity defined in     | |            | |                           |
|   VIII. B. Establish      | |            | |                           |
|   adequate procedures to  | |            | |                           |
|   document that the       | |            | |                           |
|   inspection has completed| |            | |                           |
|   (e.g., central logs,    | |            | |                           |
|   sticker/decals with date| |            | |                           |
|   inspected for equipment | |            | |                           |
|   inspections, etc.,).    | |            | |                           |
|                           | |            | |                           |
| D. Evaluate fire dept.    |T| Cotton     | | X____X June 2 thru July 28|
|   staffing after consider-| |            | |                           |
|   ing results of VIII A-D.| |            | |                           |
|                           | |            | |                           |
|___________________________|_|____________|_|___________________________|
|                                                                        |
| X = Milestone      * = Completed Milestone    R = Rescheduled Milestone|
| X___X = Time Span  R____R = Rescheduled Span  B = Block Release        |
| # = Schedule Position      (TBO) = To be determined                    |
|________________________________________________________________________|
|                                                                        |
| Status Codes:  C = Completed   T = Tracking (on schedule)              |
|                X = Behind schedule & threatens user need date          |
|                R = Rescheduled but does not threaten user need dates   |
|________________________________________________________________________|
|                           | |            | |                           |
|IX. Maintenance Activities | |            | |                           |
|                           | |            | |                           |
| A. Evaluate the adequacy  | |            | |                           |
|   of the plan maintenance | |            | |                           |
|   program in the shop     | |            | |                           |
|   areas.                  | |            | |                           |
|                           | |            | |                           |
|   1. Survey Users         |C| Kramer/    | | _* thru May 5             |
|                           | | Brewer     | |                           |
|   2. Evaluate results of  |T| Kramer     | | X (completion by 5-31-90  |
|   surveys and information | |            | |                           |
|   from the W-T-W house-   | |            | |                           |
|   keeping sweeps and      | |            | |                           |
|   implement any changes   | |            | |                           |
|   to planned maintenance  | |            | |                           |
|   programs. Evaluate if   | |            | |                           |
|   current staffing levels | |            | |                           |
|   are adequate.           | |            | |                           |
|                           | |            | |                           |
| B. General "Housekeeping" | |            | |                           |
|    maintenance activities | |            | |                           |
|    in all areas.          | |            | |                           |
|                           | |            | |                           |
|    1. Develop housekeeping| |Kramer/Allyn| | See Task II G             |
|    procedure to be        | | Branches   | |                           |
|    performed by branches. | |            | |                           |
|                           | |            | |                           |
|    2. Re-evaluate premises|C| Kramer     | | _____* thru May 26        |
|    for janitorial coverage| |            | |                           |
|    make any changes needed| |            | |                           |
|    and propose actions    | |            | |                           |
|    necessary to attain    | |            | |                           |
|    premised coverage.     | |            | |                           |
|                           | |            | |                           |
|X. Review and revise as    |C| Pleasant/  | | ____* thru May 19         |
|  appropriate emergency/   | | Cotton     | |                           |
|  accident response        | |            | |                           |
|  procedures.              | |            | |                           |
|                           | |            | |                           |
|XI. Revise Safety Manual   | | Allyn      | | X_____ June 30 thru Dec 22|
|                           | |            | |                           |
|XII. Evaluate the effects  |C| Faeder     | | X____* May 5 thru June 9  |
|    of the above tasks on  | |            | |                           |
|    EPSO's manpower        | |            | |                           |
|    requirements.          | |            | |                           |
|                           | |            | |                           |
|XIII. Company wide         | | Allyn      | |                           |
|     compliance assessment | |            | |                           |
|     program.              | |            | |                           |
|                           | |            | |                           |
| A. Develop Plan           |T|            | | ______X thru July 7       |
|                           | |            | |                           |
| B. Implement              | |            | | X (Completion 06/30/90)   |
|                           | |            | |                           |
|___________________________|_|____________|_|___________________________|
|                                                                        |
| X = Milestone      * = Completed Milestone    R = Rescheduled Milestone|
| X___X = Time Span  R____R = Rescheduled Span  B = Block Release        |
| # = Schedule Position      (TBO) = To be determined                    |
|________________________________________________________________________|
|                                                                        |
| Status Codes:  C = Completed   T = Tracking (on schedule)              |
|                X = Behind schedule & threatens user need date          |
|________________________________________________________________________|