from: gsa region 6, buildings services branch · from: gsa region 6, buildings services branch to:...

FROM: GSA Region 6, Buildings Services Branch TO: Tara VanBibber, Acting Director, St. Louis West Field Office Larry O’Neill, Deputy Director, St. Louis West Field Office Rocky Boice, Building Manager, St. Louis West Field Office

Jeremiah Nelson, St. Louis West CAB Leader, GSA R6 Asset Management Branch Kevin Phillips, Environmental Engineer, GSA R6 Buildings Services Branch Marvin Tigner, Vertical Transportation Specialist, GSA R6 Buildings Services Branch

CC: Chris Bolinger, Chief, GSA R6 Buildings Services Branch, GSA R6 FMD

Doug Papineau, Safety Project Manager GSA R6 Facilities Management Division (FMD) Javonne Robinson, Acting East Operations Branch Chief, GSA R6 FMD William McGowan, Director, GSA R6 FMD

John Topi, Director, GSA R6 DCD Cy Houston, Senior Advisor, GSA R6 Office of Chief of Staff

SUBJECT: Occupational Safety and Health Survey Report – Annual Building Survey REFERENCES: (a) GSA Occupational Safety and Health Program ADM P 5940.1A (b) Occupational Safety and Health Administration (OSHA) Title 29 Code of Federal Regulations Part 1910, 1926, and 1960 (c) National Fire Protection Association (NFPA) Codes ENCLOSURE(S): (1) Findings 1. An Occupational Safety and Health Survey of the work spaces in GSA Buildings GSA Buildings MO0601, MO0602, MO06005, MO0606, MO0607, MO0608, MO619, MO0610, MO0611, MO0612, MO0613, MO0614, MO0615, MO0616, MO0617, MO0618, MO0622, MO0623, MO0625, and MO0626, 4300 Goodfellow Boulevard, St. Louis, Missouri, was conducted October 12-17, 2014. The survey was conducted as part of the periodic safety survey program as required by reference (a) above. This report was not published until February 9, 2016 due to the complexity of the environmental contamination issue. However, a copy of the handwritten notes with findings was provided to the building manager prior to departing the site. All but finding number one and number two in the report enclosure was on the handwritten notes. At the time of the inspection, these findings could not be substantiated. 2. GSA occupied work spaces, facility common areas, and facility mechanical and electrical spaces were evaluated for existing and potential safety and occupational health areas of concern. The survey was performed using the above references as guides. Two-hundred and thirty-seven safety findings were noted, 64 of which was a repeat finding from 2012. Facility related findings will be taken care of by the field office. Findings with tenant work spaces/tenant purchased equipment will be addressed in a separate report to the tenant work space manager and are the responsibility of the tenant manager to correct, if applicable.

ENCLOSURE 1 - FINDINGS 3. Three significant complex wide contamination issues were noted – See Appendix A for details. 4. Three significant elevator issues were noted – See Appendix B for details. 5. Safety findings should be corrected as soon as possible/within 30 days. All facility occupants should be notified of the presence of the safety concerns that affect them via e-mail and/or posting the concerns in a location where employee notices are normally posted (until the concerns have been corrected). A list of safety concerns that have been corrected should be forwarded to this office upon completion/no later than 30 days after the receipt of this report. For those safety concerns that cannot be corrected within 30 days after the receipt of this report, an action plan addressing the circumstances of delay, a proposed timetable for completion, and a summary of steps being taken to protect occupants from being injured until corrected, should be submitted to this office for review and approval. 6. Safety findings identified in the highlighted (dashed) boxes require regional office support. This report has been addressed to those offices for required action. The field office still retains overall responsibility for the correction of those findings that require additional support and must submit the required action plan identified above and actively protect all GSA employees, building occupants, and visitors from the identified hazard(s) until corrected. 7. The survey was conducted by Jeffry Cushing, Region 6 Fire, Safety, and Environmental Branch. The survey was conducted in the presence of the O&M contractor representative Dave Larson. His assistance and cooperation is greatly appreciated. Questions regarding this survey may be directed to Jeffry Cushing at (816) 823-1441.

Jeffry Cushing, MS

Occupational Safety and Health Specialist Building Services Branch (6P2CMC) GSA Public Buildings Service – Heartland Region

APPENDIX A - CONTAMINATION

Location: Goodfellow Complex Wide

Tracking Number: S-MO0602-10-14-2014 - 1

Description: The following three significant site environmental

contamination issues that affect employee safety and health were noted

(See Appendix A for details):

1) Multiple facility spaces that contain air/soil/water/surface

contamination have not been properly evaluated to determine the

amount/toxicity/extent of the hazards involved and actions (i.e.

ventilation, limited access, abatement, etc.) required to protect

other federal agency occupants, GSA employees, contractors,

vendors, and visitors. These spaces include multiple facility

occupied spaces, basements, crawl spaces, utility tunnels, and the

spaces above suspended ceiling tiles in occupied space.

2) A proper hazard assessment has not been conducted to determine

the personal protective equipment required to protect employees

when entering contaminated spaces.

3) Contaminated spaces have not been properly posted or

communicated to warn employees, tenants, visitors, vendors, or

contractors of the hazards present.

NOTE: Multiple surveys/studies were commissioned by GSA Region 6

Environmental Program Managers between 2002 and 2013. Although

the majority of the reports/studies suggested action be taken to

protect the safety and health of federal complex personnel working in

contaminated spaces (particularly operations and maintenance, GSA

facilities operations personnel, and construction workers) no

substantial action prior to 2015 by GSA Region 6 Management was

taken to inform or protect them.

This finding is the responsibility of the SLW CAB with assistance from

the R6 Design and Construction and Facilities Management Divisions.

Recommendation: See Appendix A for a detailed description of these

issues and recommendations.

RAC: 2-IC

Reference: 29 CFR 1910.132(d)(1)/29 CFR 1910.1000(a)-(e)

29 CFR 1910.1200(a)(2)/29 CFR 1910.120(a)(2)(i)

JeffryRCushing

Highlight

JeffryRCushing

Highlight

ENCLOSURE 1 - FINDINGS

Location: Goodfellow Elevators


Description: The following three significant elevator equipment issues were

noted:

1) The following four elevators and associated equipment are

60 years past there service life…the age of this equipment

makes it a fire hazard and a fall hazard due to collapse.

Building 104 – B16



Building 105F – M36

2) Access to unguarded *75 year old electrical equipment

(40-400 VAC/DC) is open to unqualified personnel

…electrocution hazard.

3) *75 year old mechanical elevator equipment is not properly

guarded…amputation hazard.

This finding is the responsibility of the SLW CAB with assistance from the

Regional Elevator SME.

RAC: 2-IC

Reference: 29 CFR 1910.132(d)(1)/29 CFR 1910.1000(a)-(e)

29 CFR 1910.1200(a)(2)/29 CFR 1910.120(a)(2)(i)

NOTE: * The actual age of this equipment cannot be determined because the

equipment does not have any data plates nor are there any records of when it

was installed. The R6 elevator subject matter expert (SME) (35 years of

elevator industry experience) estimated the age from the equipment type and

manufacturer.

NOTE: Several other issues were noted concerning this elevator

equipment/equipment area that were not related to the age of the equipment.

Those issues are identified specifically throughout the report.


Location: Building 107 Basement


Description: Electrical circuit breaker panel LB-C13 has one unused

opening in the top of the panel box…electrical/fire hazard.

Recommendation: Properly close unused openings.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(7)(i)



Description: Electrical distribution cabinet cover has two missing cover

screws…electrical/fire hazard.

Recommendation: Ensure all cover screws are properly installed.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)



Description: Electrical switch box covers missing Arc Flash warning

labels…electrical hazard

Recommendation: Corrected on-the-spot.

RAC: 4-IVD





Description: BFD electrical control panel cover is loose and is missing

one cover screw…electrical/fire hazard.

Recommendation: Close cover and ensure all cover screws are properly

installed.

RAC: 3-IIC




Description: Server cabinet electrical power cord is lying in a puddle of

water…electrical hazard

Recommendation: Maintain floor in dry condition and raise power cord

off floor.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/29 CFR 1910.22(a)(2)



Description: Electrical circuit breaker panel PB1 circuit breakers are not

labeled…electrical hazard.

Recommendation: Properly label all circuits to indicate their purpose.

RAC: 3-IIC

Reference: 29 CFR 1910.303(f)(2)




Description: Electrical equipment cabinet that appears to be abandoned in

place is not locked out/tagged out; backup battery in cabinet is split

open…electrical/fire/corrosive chemical/environmental hazard.

Recommendation: Remove and properly dispose of batteries and properly

lock out/tag out/remove equipment. Abandoned equipment should be

labeled as such and all hazardous energy sources should be properly

isolated.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/29 CFR1910.333(a)(2)



Description: Electrical trough above circuit breaker panels FC1/FC2 has

seven missing cover screws…electrical/fire hazard.


RAC: 3-IIC


Location: Building 102E Electrical Closet


Description: Electrical distribution panel DP1 is missing to cover

screws…electrical/fire hazard. Note: This is a repeat concern from 2012.


RAC: 3-IIC



Location: Building 102E Mechanical Room


Description: Return Fan C.1 switch has one unused opening in the front of

the switch box exposing energized wiring inside…electrical/fire hazard.

Note: This is a repeat concern from 2012.

Recommendation: Properly close unused opening.

RAC: 3-IIC


Location: Building 102E Mechanical Room


Description: Unit Heater 1 junction/switch box has one unused opening in

the front of the box exposing energized wiring inside…electrical/fire

hazard. Note: This is a repeat concern from 2012.


RAC: 3-IIC


Location: Building 102E 1st Floor Restrooms


Description: Electrical wall outlet is not GFCI protected…electrical

hazard.

Recommendation: Install GFCI outlets or circuit breaker/remove outlet.

RAC: 3-IIC



Location: Building 102E 1st Floor Janitors Closet


Description: Top of electrical equipment is being used for storage (MSDS

Book)...electrical/fire hazard.

Recommendation: Maintain working space about electrical cabinet free

and clear.

RAC: 3-IIC

Reference: 29 CFR 1910.303(g)(1)(ii)

Location: Building 102E 2nd

Floor


Description: Access to electrical circuit breaker panel RP2 is blocked by

office furniture...electrical/fire hazard

Recommendation: Move the desk away from the electrical panel and

maintain proper access and working space at all times.

RAC: 3-IIC

Reference: 29 CFR 1910.303(g)(1)(i)

Location: Building 103D Restrooms


Description: Electrical outlets above sink are not GFCI

protected…electrical hazard. Note: This is a repeat concern from 2012.

Recommendation: Install GFCI outlets or circuit breaker/remove outlet.

RAC: 3-IIC



Location: Building 103D Mechanical Room


Description: Electrical distribution panel covers missing Arc Flash

warning labels…electrical hazard.

Recommendation: Install Arc Flash warning labels.

RAC: 4-IVD


Location : Building 103D Elevator Equipment Area


Description: Entrance to elevator equipment area is not posted with the

proper danger signage…electrical/amputation hazard. Note: This is a

repeat concern from 2012.

Recommendation: Properly post warning signs at all area

entrances.

RAC: 3-IIC

Reference: 29 CFR 1910. 145(c)(3)

Location: Building 103D Elevator Equipment Area


Description: Elevator equipment that appears to be abandoned in place is

not locked out/tagged out…electrical/amputation hazard. Note: This is a


Recommendation: Properly lock out/tag out/remove equipment.

Abandoned equipment should be labeled as such and all hazardous energy

sources should be properly isolated.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/1910.147(a)(3)


Location: Building 103D Basement


Description: Electrical switch box missing Arc Flash warning

label…electrical hazard.


RAC: 4-IVD


Location: Building 103D Basement


Description: Electrical switch box above sump pump is corroded;

electrical switch box cover missing Arc Flash warning

label…electrical/fire hazard.

Recommendation: Repair/replace box and install Arc Flash warning label.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(7)(iv)

29 CFR 1910.335(b)(1)

Location: Basement Sump Pits Throughout Complex


Description: Sump pump pit is missing a cover…trip/fall hazard.

Recommendation: Install cover.

RAC: 3-IIC

Reference: 29 CFR 1910.22(a)(3)/ 29 CFR 1910.23(a)(9)


Location: Basement Stairwells Throughout Complex


Description: Basement access stairwell drain is missing the drain

cover…tripping/fall hazard.

Recommendation: Install drain cover.

RAC: 3-IIC

Reference: 29 CFR 1910.22(a)(3)/ 29 CFR 1910.23(a)(9)

Location: Building 103 E Mechanical Room


Description: Tosvert electrical control panel is missing one cover screw;

panels are missing Arc Flash warning labels…electrical/fire hazard.

Recommendation: Ensure all cover screws are properly installed and

install Arc Flash warning labels.

RAC: 4-IID


29 CFR 1910.335(b)(1)

Location: Building 105 USDA Lab Hallway


Description: Circuit breaker panel has two missing cover screws;

personnel installed multiple sheet metal screws in place of the proper cover

screws in both panels negating the panel covers

listing/labeling…electrical/fire hazard. Note: This is a repeat concern

from 2012.

Recommendation: Replace panel covers/contact manufacturer for

authorized corrective action.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/29 CFR 1910.303(b)(2)


Location: Building 105 USDA Lab Hallway


Description: Personnel installed sheet metal screws in place of the proper

cover screws in both panels negating the panel covers

listing/labeling…electrical/fire hazard. Note: This is a repeat concern

from 2012.

Recommendation: Replace panel covers/contact manufacturer for

authorized corrective action.

RAC: 3-IIC


Location: Building 105 Room 362M


Description: Electrical transformers are missing one cover screw/bolt

each…electrical/fire hazard.


RAC: 3-IIC


Location: Building 105 Room 362M


Description: Electrical distribution panel is missing two cover



RAC: 3-IIC



Location: Building 105 USDA Warehouse


Description: Facility piping is improperly supported by 2x4 pieces of

lumber spanning from I-beam to I-beam (this is a specific concern in a

seismic event or fire)…collapse/fire hazard per the regional structural

engineer..

Recommendation: Properly brace/suspend/support suspended facility

piping.

RAC: 3-ID

Reference: Regional Mechanical and Structural Engineer/OSHA 5(a)(1)


Tracking Number: S – MO0612-10-14-2014 - 31

Description: Equipment above the I-beams leaking causing the beams

below to corrode…may affect the structural integrity of the beams/floor,

particularly during a seismic event.

Recommendation: Ensure equipment above has been repaired so it does

not leak and have a qualified structural engineer assess damage and repair

as necessary. Note: This issue was reported to building manager and

lab safety officer for immediate corrective action. This is a repeat

concern from 2012. It was originally noted on the St. Louis West Field

Office survey report however, it has since been determined this is a

shared responsibility because the equipment leaking belongs to the USDA

lab.

This finding remains the responsibility of the field office and the lab but

requires GSA Regional Design and Construction Division support.

RAC: 2-IC

Reference: 29 CFR 1910.22(d)(2)




Description: Electrical switch box in forklift battery charging area has one

unused opening in the top of the switch box. Note: This is a repeat

concern from 2012.


RAC: 3-IIC


Location: Building 105 1st Floor Mechanical Room


Description: Electrical circuit breaker panel P1-B50 has two unused

openings in the breaker panel (circuit breaker slot #42 and 44) exposing

energized electrical parts; circuit breakers 32 and 34 are improperly tied

together…electrical/fire hazard. Note: This is a repeat concern from

2012.

Recommendation: Properly close circuit breaker slots and install circuit

breaker in slot 32/34 that is designed for such use.

RAC: 3-IIC

Reference: 29 CFR 1910.303(g)(2)(i)/29 CFR 1910.303(b)(2)

Location: Building 105 1

st Floor Mechanical Room


Description: Electrical circuit breaker panel P1-B50A is missing three

cover screws…electrical/fire hazard.


RAC: 3-IIC





Description: Electrical circuit breaker panel L1-B50 has one or more

circuits that are not properly labeled…i.e. circuit breakers are on but not

labeled/circuit breakers are on but marked spare/circuit breakers are

marked one thing on the panel itself and another on the label card/entire

circuit breaker panel label is missing.…electrical hazard.


RAC: 3-IIC




Description: Exposed AHU flange bearing (rotating shaft) not properly


Recommendation: Install proper guard over rotating shaft.

RAC: 3-IIC

Reference: 29 CFR 1910.219(c)(2)(i)



Description: Unused electrical outlet/light switch boxes are missing covers

(wiring was not energized)…electrical/fire hazard.


RAC: 4-IID



Location: Building 103 1st Floor South Mechanical Room


Description: The AHU fan shaft and motor housing cover is not installed

leaving the fan shaft unguarded…amputation hazard. Note: This is a


Recommendation: Install cover - cover must be installed anytime fan is

operating.

RAC: 3-IIC


Location: Building 103 1st Floor South Mechanical Room


Description: Tosvert electrical control panel is missing three cover screws;

panel is missing Arc Flash warning label…electrical/fire hazard.


install Arc Flash warning label.

RAC: 4-IID


29 CFR 1910.335(b)(1)

Location: Building 103 South Penthouse – Roof Access


Description: Electrical circuit breaker panel missing one cover

screw…electrical/fire hazard. Note: This is a repeat concern from 2012.


RAC: 4-IID



Location: Building 103 Multiple Elevator Equipment Rooms/Areas


Description: Entrance to elevator equipment rooms/areas are not posted

with the proper danger signage…electrical/amputation hazard. Note: This

is a repeat concern from 2012.

Recommendation: Post appropriate signage on all elevator equipment

room access doors/area entrances.

RAC: 3-IIC

Reference: 29 CFR 1910. 145(c)(3)

Location: Building 103 – Elevator Equipment Room F31


Description: Oily rags improperly left lying about operating elevator hoist

equipment…fire hazard.

Recommendation: Remove rags and properly address any oil leaks.

RAC: 3-IIC

Reference: 29 CFR 1910.106(e)(9)(i)

Location: Building 103 – Penthouse D


Description: Electrical circuit breaker panel HU-2A has one unused

opening in the bottom of the panel box; panel circuit breakers are not

correctly labeled.


RAC: 3-IIC





Description: Electrical switch box has one unused opening in the top of

the box and one unused opening in the front of the box…electrical/fire

hazard.


RAC: 3-IIC


Location: Building 103 – Penthouse C


Description: Electrical circuit breaker panel P-1 has two unused openings

in the side of the panel box…electrical/fire hazard.


RAC: 3-IIC




Description: The back of the AHU fan motor and belt is not properly


Recommendation: Install a proper cover/guard.

RAC: 3-IIC





Description: Exposed AHU flange bearing (rotating shaft) not properly

guarded; electrical junction box has one unused opening in the side of the

box…amputation hazard/electrical/fire hazard.

Recommendation: Install proper guard over rotating shaft.

RAC: 3-IIC

Reference: 29 CFR 1910.219(c)(2)(i)/29 CFR 1910.303(b)(7)(i)



Description: Emergency light is not operating properly (will not reset after

test (lights stay on))…fire hazard.

Recommendation: Repair/replace.

RAC: 3-IIC

Reference: 29 CFR 1910.37(a)(4)

Location: Building 103 – Penthouse A


Description: Electrical circuit breaker panel HU1A has one unused

opening in the bottom of the panel box…electrical/fire hazard.


RAC: 3-IIC





Description: Adjustable Speed Drive control panels are missing Arc Flash



RAC: 4-IVD


Location: Building 103 – Penthouse A Elevator Equipment Room


Description: Electrical trough/junction box covers are not installed

exposing energized wiring inside…electrical/fire hazard.

Recommendation: Properly close access door when equipment is not

being serviced.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/29 CFR 1910.303(g)(2)(ii)



Description: Elevator hoist motor junction boxes have three unused

openings, two in the sides of one box and one in the side of the other box.


RAC: 3-IIC





Description: Window is open to the next lower level (not properly

guarded)…fall/struck-by hazard.

Recommendation: Properly guard per OSHA requirements.

RAC: 3-IIC


Location: Building 103 – Chiller Room


Description: Chiller room not

properly posted; other entrance

does not have an alarm

…asphyxiation hazard.

Recommendation: Install signage

at all room entrances; install alarm

light at all room entrances.

RAC: 3-IIC

Reference: ANSI/ASHREA

Standard 15, Para. 8.11.2.1



Description: Multiple entrances to water storage tank under floor are not

posted with Permit Required Confined Space danger signage…

asphyxiation hazard. Note: This issue was reported to the facility manager

for immediate corrective action. Note: This is a repeat concern from

2012.

Recommendation: Permanently close (weld) entrances/post all entrances

with proper signage.

RAC: 2-IC

Reference: 29 CFR 1910.146(c)(2)

CHILLER ROOM

AUTHORIZED PERSONNEL ONLY DO NOT ENTER WHEN REFRIGERANT

WARNING LIGHT IS FLASHING - FLASHING

LIGHT INDICATES POTENTIAL HAZARDOUS

ATMOSPHERE FROM REFRIGERANT LEAK.

CONTACT THE GSA BUILDING MANAGER

FOR INSTRUCTIONS.




Description: Pipes running across floor are not properly identified (not

painted yellow)…tripping hazard.

Recommendation: Paint hazards yellow/mark with caution/hazard tape so

they are clearly visible.

RAC: 3-IIC




Description: Hole in floor grate larger than one inch wide creating tripping

hazards; access to tank not posted as a Permit Required Confined

Space…tripping/asphyxiation hazard. Note: This is a repeat concern from

2012.

Recommendation: Properly close hole in floor grate and post PRCS

signage.

RAC: 4-IID




Description: Electrical distribution cabinet DP6 is missing two cover

screws/plugs; working space at the side of the cabinet is being used for

storage…electrical/fire hazard

Recommendation: Ensure all cover screws/plugs are properly installed

and maintain working space about electrical equipment

RAC: 4-IID

Reference: 29 CFR 1910.303(b)(1)/29 CFR 1910.303(g)(1)




Description: Electrical circuit breaker panel A2 Section 2 is missing four

cover screws…electrical/fire hazard


RAC: 3-IIC


Location: Building 103 – Driveway


Description: Vehicle barriers/gates not posted with the proper warning

labels…struck by hazard.

Recommendation: Install warning labels on the

front and back of each gate/barricade.

RAC: 3-IIC


Location: Building 103 – Throughout Facility


Description: Abandoned electrical equipment is not locked out/tagged or

labeled…electrical/fire hazard.

Recommendation: Abandoned equipment should be locked out/tagged out

until all hazardous energy sources have been properly removed. Once all

energy sources have been removed, equipment should be labeled as

abandoned.

RAC: 3-IIC

Reference: 29 CFR 1910.147(a)(3)/29 CFR 1910.333(b)(2)


Location: Building 104F – Electrical Closet


Description: Working space in front of electrical equipment is being used

for storage…electrical/fire hazard.

Recommendation: Maintain working space about electrical equipment.

RAC: 4-IID

Reference: 29 CFR 1910.303(g)(1)



Description: Electrical distribution panels L1A and L1B have

loose/missing cover screws; electrical panels missing Arc Flash warning

labels…electrical/fire hazard.



RAC: 3-IIC


Location: Building 104F – Southeast Stairwell


Description: Holes in the stairwell landing/floor next to the 2nd

floor door

are larger than one inch wide creating a tripping hazard.

Recommendation: Properly close holes in stairwell landing. Note: This

issue was reported to the facility manager for immediate corrective action.

RAC: 3-IIC



Location: Building 104E – 2nd

Floor Mechanical Room


Description: Electrical circuit breaker panels 2LP2 and 2RP1 are missing

one cover screw each…electrical/fire hazard.


RAC: 4-IID


Location: Building 104E – Penthouse Elevator Equipment Room


Description: Entrance to elevator equipment room/area is not posted with

the proper danger signage…electrical/amputation hazard. Note: This is a



room access doors/area entrances.

RAC: 3-IIC

Reference: 29 CFR 1910. 145(c)(3)

Location: Building 104E – Penthouse Elevator Equipment Room


Description: Electrical panel covers on two energized elevator relay panels

are not installed…electrocution hazard. Note: This is a repeat concern

from 2012.

Recommendation: Covers should be installed anytime equipment is not

being serviced. Note: This issue was reported to the facility manager for

immediate corrective action.

RAC: 2-IC



Location: Building 104 – 2nd

Floor Hallway


Description: Southwestern Bell telephone panel has an electrical outlet

inside the panel that is not properly installed, mounted, and/or

secured…electrical/fire hazard.

Recommendation: Properly install outlet/remove outlet.

RAC: 3-IIC


Location: Building 104E – 1st Floor Electrical Closet


Description: Electrical circuit breaker panel LP is missing two cover



RAC: 3-IIC


Location: Building 104E – 1

st Floor Electrical Closet


Description: Electrical circuit breaker panel RP-R is missing two cover

screws; circuit breaker panel circuit breakers are not



properly label all circuits to indicate their purpose.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/29 CFR 1910.303(f)(2)


Location: Building 104E – 1st Floor Electrical Closet


Description: Electrical circuit breaker panel 1-RP-L has four loose/missing

cover screws…electrical/fire hazard.


RAC: 3-IIC


Location: Building 104E – 1

st Floor Electrical Closet


Description: Over 20 fluorescent light bulbs are improperly stored

(standing loose in the corner)…chemical/laceration hazard.

Recommendation: Properly store light bulbs.

RAC: 3-IIC

Reference: 29 CFR 1910.176(b)

Location: Building 104E – Basement


Description: Electrical distribution panel MDP is missing two cover

screws/plugs...electrical/fire hazard. Note: This is a repeat concern from

2012.

Recommendation: Ensure all cover screws/plugs are properly installed.

RAC: 4-IID





Description: Light strand throughout the basement is constructed from

parts not listed/labeled for this type of use (wiring not in conduit, light

fixtures not properly mounted/guarded …electrical/fire hazard. Note: This


Recommendation: Remove current lighting and install proper lighting.

Note: This issue was reported to the facility manager for immediate

corrective action.

RAC: 2-IC




Description: Electrical wall outlet is severely corroded compromising the

integrity of the equipment…electrical/fire hazard.

Recommendation: Repair/replace corroded electrical equipment. Note:

This issue was reported to the facility manager for immediate corrective

action.

RAC: 2-IC

Reference: 29 CFR 1910.303(b)(7)(iii)-(iv)

Location: Building 115 – Electrical Closet


Description: Electrical panels missing Arc Flash warning labels…electrical

hazard.


RAC: 4-IID



Location: Building 115 – Janitors Closet


Description: Electrical light switch is missing one cover



RAC: 4-IID


Location: Building 115 – Basement


Description: Abandoned electrical equipment is not locked out/tagged or


Recommendation: Abandoned equipment should be locked out/tagged out

until all hazardous energy sources have been properly removed. Once all

energy sources have been removed, equipment should be labeled as

abandoned.

RAC: 3-IIC


Location: Building 115 - Basement


Description: Top three steps leading to basement are a different height

than the rest of the steps (risers are not uniform)…fall hazard. Note: This


Recommendation: Riser height throughout the flight of stairs should be

made uniform.

RAC: 3-IIC

Reference: 29 CFR 1910.24(f)


Location: Building 105L – Electrical Closet


Description: Electrical circuit breaker panel LB has seven unused

openings in the top of the panel box and three unused openings in the

bottom of the panel box…electrical/fire hazard.

Recommendation: Properly close unused openings. Note: This issue was

reported to the facility manager for immediate corrective action.

RAC: 2-IC




Description: Electrical wiring hanging from a ceiling junction box/conduit

is unguarded (energized wiring at head level …electrical/fire hazard.

Recommendation: Properly install wiring and close junction boxes. Note:


action.

RAC: 2-IC

Reference: 29 CFR 1910.303(g)(1)



Description: Electrical circuit breaker panel LC has one unused opening in

the bottom of the panel box.


RAC: 3-IIC





Description: Multiple electrical trough/control panel covers are not

installed exposing energized wiring/parts inside.

Recommendation: Close electrical equipment covers when not being

serviced. Note: This issue was reported to the facility manager for

immediate corrective action.

RAC: 2-IC


Location: Building 105L – Mechanical Room


Description: Numerous electrical panels/switch boxes are missing Arc

Flash warning labels…electrical hazard.


RAC: 4-IID


Location: Building 105L – Northeast (Outside) Electrical Closet


Description: Electrical closet is not adequately illuminated…tripping

hazard.

Recommendation: Install proper lighting.

RAC: 3-IIC

Reference: 29 CFR 1910.303(g)(1)(v)


Location: Building 105L – Northeast (Outside) Electrical Closet


Description: Siemans electrical circuit breaker panel circuit breakers are

not labeled…electrical hazard.


RAC: 3-IIC


Location: Building 105L – Outside East Wall


Description: Electrical switch box is corroded…electrical/fire hazard.

Recommendation: Repair/replace corroded electrical equipment.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(7)(iii)-(iv)

Location: Building 105F – Basement


Description: Multiple electrical switch box covers are missing Arc Flash

warning labels …electrical hazard.


RAC: 4-IID



Location: Building 105F – Hallway


Description: Electrical circuit breaker panel PK1 Sec 1 has one unused

opening (circuit breaker slot #1) improperly covered using electrical tape

not listed and labeled for such use; circuit breaker panel PK1 Sec 2 has one

circuit breaker taped off (not properly locked out/tagged out)…electrical

hazard …electrical/fire hazard.

Recommendation: Remove electrical tape and properly close unused

opening/properly lockout/tag out equipment instead of tapping circuit

breakers in the off position.

RAC: 3-IIC


Location: Building 105F – Hallway


Description: Electrical circuit breaker panel L1N35 circuit breaker #6 is


Recommendation: Ensure all circuits are properly labeled to indicate their

purpose.

RAC: 3-IIC


Location: Building 105F – Mechanical Room


Description: Electrical distribution panel covers missing Arc Flash

warning labels; distribution panel covers missing three cover

screws…electrical/fire hazard. Note: This is a repeat concern from 201

Recommendation: Install Arc Flash warning labels and ensure all cover

screws are properly installed.

RAC: 3-IIC



Location: Building 105F – Mechanical Room


Description: Electrical switch box “A/C In A.C.D.” has two unused

openings in the bottom of the switch box…electrical/fire hazard.


RAC: 3-IIC



Floor Electrical Closet


Description: Electrical distribution panel CU-3AOC panel covers missing

Arc Flash warning labels; distribution panel cabinet is missing four cover




RAC: 3-IIC


Location: Building 104 – Throughout NITC Server Room and Offices


Description: Numerous electrical circuit breaker panels are missing cover

screws/have unused openings in the front of the panel (circuit breaker

slots)/circuit breakers are taped off (not properly locked out/tagged

out)…electrical/fire hazard. Note: This is a repeat concern from 2012.

Recommendation: Ensure all cover screws are properly installed; properly

close all unused openings; and properly lockout/tag out instead of taping

circuit breakers off.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/29 CFR 1910.303(b)(7)(i)

29 CFR 1910.333(b)(2)


Location: Building 104 – All Penthouse Elevator Equipment

Rooms/Areas


All Elevator Equipment Rooms/Areas:

Description: Entrance to elevator equipment rooms/areas are not posted

with the proper danger signage…electrical/amputation hazard. Note: This


Penthouse B

Elevated elevator equipment work platforms (platforms over four feet to the

next lower level) not properly protected at the entry way with a ladder

gate/complete guardrail system…fall hazard. Note: This is a repeat concern

from 2012.


room access doors/area entrances. Complete the guardrail system at each

entryway and install ladder gates for those elevated platforms that are four

feet or more above the mechanical room floor.

RAC: 3-IIC

Reference: 29 CFR 1910.23(a)(2)/29 CFR 1910.23(c)(1)

29 CFR 1910.145(c)(3)


Location: Building 104 – Penthouse B


Description: Electrical circuit breaker panel RB18 has one unused opening

in the front of the panel exposing energized electrical parts (circuit breaker

slot # 24 is open)…electrical/fire hazard.


RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(7)(i)/29 CFR 1910.303(g)(2)(i)



Description: Electrical distribution panel RTDP1 panel covers are missing

Arc Flash warning labels; distribution panel covers are missing two cover



install Arc Flash warning labels,

RAC: 4-IID




Description: Electrical distribution panel RTDP1A panel covers are

missing two cover screws…electrical/fire hazard. Note: This is a repeat

concern from 2012.


RAC: 4-IID





Description: GFCI outlet will not test; outside outlet missing weather

cover…electrical/fire hazard.

Recommendation: Repair/replace.

RAC: 3-IIC


Location: Building 104 – Roof


Description: Ladderway on multiple HVAC equipment platforms four feet

or higher above the roof deck do not have ladder gates for fall

protection…fall hazard. Note: This is a repeat concern from 2012.

Recommendation: Install ladder gates or equivalent.

RAC: 3-IIC




Description: Electrical circuit breaker panel RG-7 has one unused opening

in the bottom of the switch box…electrical/fire hazard. Note: This is a



RAC: 3-IIC





Description: Electrical switch boxes BP 1 and 2 have one unused opening

in the top of the switch box each…electrical/fire hazard.


RAC: 3-IIC




Description: Electrical trough is missing the front cover exposing wiring

inside…electrical/fire hazard.


RAC: 3-IIC


Location: Building 104 – Outside Penthouse A


Description: Equipment pylons located outside on roof next to the

penthouse floor are not properly identified (not painted yellow/not flagged

so they can be seen when roof is snow covered)…tripping hazard

Recommendation: Remove/paint yellow/mark.

RAC: 3-IIC





Description: Electrical distribution panel RTDP panel covers missing Arc

Flash warning labels; distribution panel cabinet is missing two cover




RAC: 3-IIC










RAC: 3-IIC




Description: Multiple protrusions/equipment pedestals/bases on the floor

are not properly identified (not painted yellow)…tripping hazard.



RAC: 3-IIC





Description: Electrical circuit breaker panel RF26 cover is missing one

cover screw…electrical/fire hazard.


RAC: 4-IID




Description: Stack of unstable wooden cable reels, plywood, air filters,

etc. are precariously positioned on top of a two foot high equipment

pedestal…struck-by hazard.

Recommendation: Remove items from wall and properly store.

RAC: 3-IIC




Description: Multiple holes in floor are larger than one inch

wide…tripping hazard.

Recommendation: Cover holes.

RAC: 3-IIC





Description: Wiring to fire alarm pull station hanging out of conduit is

improperly terminated…electrical/fire hazard.

Recommendation: Determine if pull station is required and properly

install/remove or terminate wiring.

RAC: 3-IIC




Description: Electrical junction boxes/troughs mounted on wall have three

unused openings, one in the top of one box and two in the top of the other

box…electrical/fire hazard. Note: This is a repeat concern from 2012.


RAC: 3-IIC








RAC: 3-IIC







Recommendation: Cover holes.

RAC: 3-IIC




Description: Electrical switch box has one unused opening in the front of

the box and one unused opening in the side of the box. Note: This is a



RAC: 3-IIC


Location: Building 104 – Penthouse E






RAC: 3-IIC











RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/1910.147(a)(3)



Description: Electrical wall outlet on the outside wall of the penthouse is

not GFCI protected…electrical hazard.

Recommendation: Install GFCI outlet/circuit breaker protection.

RAC: 3-IIC




Description: Penthouse is not adequately illuminated…tripping/electrical

hazard.

Recommendation: Install lighting. Note: This issue was reported to the

facility manager for immediate corrective action.

RAC: 3-IIC

Reference: 29 CFR 1910.303(g)(1)(v)


Location: Building 104 – Penthouse F


Description: Electrical distribution panel RTDP3 panel covers are missing

Arc Flash warning labels.


RAC: 4-IID


Location: Building 104 – Penthouse G








RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/1910.147(a)(3)

Location: Building 104 – Penthouse G






RAC: 3-IIC




Floor Vending Machine Area


Description: Electrical wall outlet vending machines are plugged into are

missing cover plates exposing energized electrical parts.

Recommendation: Install cover plates. Note: This issue was reported to

the facility manager for immediate corrective action.

RAC: 3-IIC


Location: Building 104 – Southwest Stairwell




Recommendation: Cover holes. Note: This issue was reported to the


RAC: 3-IIC


Location: Building 104 – 1st Floor Column J48


Description: Electrical circuit breaker panels 1RJ48 and 1LJ48 are each

missing one cover screw…electrical/fire hazard. Note: This is a repeat

concern from 2012.


RAC: 4-IID



Location: Building 104 – Elevator Equipment Room Column B48


Description: Electrical circuit breaker panel 1RB48 is missing one cover

screw...electrical/fire hazard.


RAC: 4-IID


Location: Building 104 – Elevator Equipment Room Column J52



proper danger signage…electrical/amputation hazard.

Recommendation: Properly post warning signs on all entrance doors.

RAC: 3-IIC

Reference: 29 CFR 1910. 145(c)(3)

Location: Building 104 – Elevator Equipment Room Column B48


Description: Electrical circuit breaker panel 1RB48A has one unused

opening in the top of the panel box…electrical/fire hazard. Note: This is a



RAC: 3-IID



Location: Building 104 – Column B31Electrical Room


Description: Electrical circuit breaker panel 1RB31A circuit breakers are

not labeled…electrical hazard. Note: This is a repeat concern from 2012.


RAC: 3-IIC


Location: Building 104 – Column B42 Electrical Room


Description: Electrical distribution panel (ULUR and HDP6) and

transformer covers are missing Arc Flash warning labels; distribution panel

cabinet covers are missing two cover screws…electrical/fire hazard. Note:

This is a repeat concern from 2012.



RAC: 4-IID




Description: Electrical circuit breaker panel 1RB31 circuit breakers are

not labeled correctly…electrical hazard.


RAC: 3-IIC





Description: Electrical distribution panel (HDP4 and RDP4) and

transformer covers are missing Arc Flash warning labels; distribution panel

cabinet cover is missing one cover screw…electrical/fire hazard. Note:




RAC: 4-IID




Description: Electrical circuit breaker panel 1LB31 is missing one cover



RAC: 4-IID




Description: Electrical circuit breaker panels 1RB21 and 1RB21A have

improper cardboard danger signs posted on the front of the cabinet for no

apparent reason…electrical/fire hazard. Note: This is a repeat concern

from 2012.

Recommendation: Determine if actual danger exists and appropriately

danger tag equipment if necessary. Note: This issue was reported to the


RAC: 3-IIC





Description: Fire protection telecom switch box/control box has one

unused opening in the front of the box exposing energized electrical

parts…electrical/fire hazard.

Recommendation: Properly close unused opening. Note: This issue was

reported to the facility manager for immediate corrective action.

RAC: 3-IIC




Description: Electrical distribution panels missing Arc Flash warning

labels …electrical/fire hazard. Note: This is a repeat concern from 2012.


RAC: 4-IID




Description: Electrical switch box/panel covers throughout space are

missing Arc Flash warning labels; electrical equipment appears to be

abandoned is not properly locked out/tagged out..

Recommendation: Install Arc Flash warning labels; Abandoned

equipment should be labeled as such and all hazardous energy sources

should be properly isolated.

RAC: 4-IID





Description: Electrical circuit breaker panel TLP-5 circuit breakers are not

properly labeled.


RAC: 3-IIC




Description: Electrical circuit breaker panel DP-1 circuit breakers are not

properly labeled…electrical hazard.


RAC: 3-IIC




Description: Wooden stair platforms to crawl space (over 4 feet above the

floor) do not have proper guardrails/stair rails…fall hazard.

Recommendation: Install proper guardrails/platforms.

RAC: 3-IIC





Description: Metal locker being used to support piping…struck-by hazard.

Note: This is a repeat concern from 2012.

Recommendation: Remove locker and properly support piping. Note:


action.

RAC: 3-IIC

Reference: OSHA Act 5(a)(1)




Properly posted; other entrance

does not have an alarm light




light at other entrance.

RAC: 3-IIC





Description: Chiller room is not monitored by a refrigerant leak detection

system…asphyxiation hazard.

Recommendation: Install monitor system with alarms at each entrance.

Note: This issue was reported to the facility manager for immediate

corrective action.

RAC: 3-IIC

Reference: ASHREA 15, Paragraph 8.11.2.1

CHILLER ROOM

AUTHORIZED PERSONNEL ONLY DO NOT ENTER WHEN REFRIGERANT WARNING

LIGHT IS FLASHING - FLASHING LIGHT

INDICATES POTENTIAL HAZARDOUS


CONTACT THE GSA BUILDING MANAGER FOR

INSTRUCTIONS.


Location: Building 104 VA Loading Dock Area


Description: Electrical circuit breaker panel 1RD3 has one unused opening

in the top of the panel box…electrical/fire hazard. Note: This is a repeat

concern from 2012.


RAC: 3-IIC


Location: Building 104 – VA Loading Dock Area


Description: Electrical circuit breaker panel 1RB3 cover is missing one

cover screw…electrical/fire hazard.


RAC: 3-IIC




Description: Electrical circuit breaker panel 1SD3 spare circuit breakers

are on indicating they are not properly labeled…electrical hazard.


RAC: 3-IIC





Description: Electrical circuit breaker panel 1LB3 circuit breaker switch

#11 is broken off…electrical/fire hazard.

Recommendation: Replace.

RAC: 3-IIC




Description: Electrical circuit breaker panel 1RJ31A circuit breakers are

not properly labeled…electrical hazard.


RAC: 3-IIC




Description: Electrical switch box cover above the door (outside) is

missing an Arc Flash warning label…electrical hazard.

Recommendation: Install Arc Flash warning label.

RAC: 3-IIC





Description: Electrical circuit breaker panel 1RJ31 circuit breaker #4 is



RAC: 3-IIC


Location: Building 104 – 1

st Floor Column J30


Description: Electrical circuit breaker panel 1LJ31 circuit breaker #21 and

#23 is not labeled correctly…electrical hazard.


RAC: 3-IIC



st Floor Column J30


Description: Electrical circuit breaker panel 1LJ31B circuit breaker #30 is



RAC: 3-IIC





Description: Electrical circuit breaker panel 1IJ31 circuit breaker #11-17

and # 23-25 are not labeled correctly; working space next to electrical

panel is improperly being used for storage…electrical/fire hazard.

Recommendation: Properly label all circuits to indicate their purpose and

maintain area around electrical panels free and clear.

RAC: 3-IIC

Reference: 29 CFR 1910.303(f)(2)/29 CFR 1910.303(g)(1)(i)[A]


st Floor Column J40


Description: Electrical circuit breaker panel 1RJ40 circuit breaker #11-23,

#12-14, and # 20-22 are not labeled correctly; working space next to/in

front of electrical panel is improperly being used for

storage…electrical/fire hazard.



RAC: 3-IIC

Reference: 29 CFR 1910.303(f)(2)/29 CFR 1910.303(g)(1)(i)[A]


st Floor Column J40


Description: Electrical circuit breaker panel 1LJ40 circuit breaker #9-17

and # 8-18 are not labeled correctly; working space next to/in front of

electrical panel is improperly being used for storage…electrical/fire

hazard.



RAC: 3-IIC

Reference: 29 CFR 1910.303(f)(2)/29 CFR 1910.303(g)(1)(i)


Location: Building 110 – Dock Area


Description: Electrical circuit breaker panel PP8 Sec 1 circuit breakers #6-

17 and # 8-18 are not labeled correctly; panel cover is missing an Arc

Flash warning label…electrical hazard. Note: This is a repeat concern

from 2012.


install an Arc Flash warning label.

RAC: 3-IIC

Reference: 29 CFR 1910.303(f)(2)/29 CFR 1910.335(b)(1)

Location: Building 110 – 1st Floor South Electrical Closet

Tracking Number: S-MO0602-10-14-2014 -158

Description: Electrical circuit breaker panel PP3 Sec 1 has one unused

opening (circuit breaker slot #42) in the front of the panel exposing

energized electrical parts…electrical/fire hazard. Note: This is a repeat

concern from 2012.


RAC: 3-IIC

Reference: 29 CFR 1910.303(b(7)(i)

Location: Building 110 – 1st Floor North Electrical Closet


Description: Electrical circuit breaker panel PP4 Sec 1 circuit breaker #41

and #42 are not labeled correctly; Electrical circuit breaker panel PP4 Sec

2 circuit breaker #84 is not labeled correctly…electrical hazard.


RAC: 3-IIC



Location: Building 110 – 1st Floor South Electrical Closet


Description: Electrical circuit breaker panel E1S Sec 1 circuit breaker #10

and 21 are not labeled correctly…electrical hazard. Note: This is a repeat

concern from 2012.


RAC: 3-IIC


Location: Building 110 – South Penthouse


Description: AHU switch box/control panel and electrical distribution

panel DLP3 covers are missing Arc Flash warning labels…electrical


Recommendation: Install an Arc Flash warning labels.

RAC: 3-IIC


Location: Building 110 – North Penthouse


Description: AHU switch box/control panel and electrical distribution

panel DLP4 covers are missing Arc Flash warning labels…electrical



RAC: 3-IIC









RAC: 3-IIC




Description: Electrical switch box covers on outside wall of penthouse are

missing Arc Flash warning labels…electrical hazard.

Recommendation: Install an Arc Flash warning label.

RAC: 3-IIC


Location: Building 106 – Mechanical Closet


Description: Electrical circuit breaker panel has one missing and one loose

cover screw; working space next to electrical panel is improperly being

used for storage…electrical/fire hazard.



RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/29 CFR 1910.303(g)(1)(i)[A]


Location: Building 110 – Room B5


Description: Abandoned/unused electrical equipment is not properly

labeled/locked out/tagged out…electrical hazard.

Recommendation: Equipment should be properly locked out/tagged

out/abandoned equipment should be labeled as such and all hazardous

energy sources should be properly isolated. Install Arc Flash warning label

if not abandoned.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/1910.147(a)(3)

Location: Building 110 – ACU #2 Room


Description: Electrical switch box covers missing Arc Flash warning

labels…electrical hazard.


RAC: 3-IIC


Location: Building 110 – ACU #2 Room


Description: The back of the AHU fan motor and belt is not properly

guarded…amputation hazard…amputation hazard.

Recommendation: Install a proper cover/guard.

RAC: 3-IIC






properly posted; other entrance

does not have an alarm




light at all room entrances.

RAC: 3-IIC





Description: Electrical circuit breaker panel circuit breaker is taped

on/off…electrical hazard.

Recommendation: Verify status of circuit breaker, remove tape from

circuit breaker and lockout/tag out if required.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/29 CFR 1910.303(b)(7)(iii)



Description: Fire Alarm and chiller emergency stop switches are covered

by storage…fire hazard.

Recommendation: Remove storage and maintain access to emergency

equipment free and clear.

RAC: 3-IIC


CHILLER ROOM






INSTRUCTIONS.




Description: Multiple electrical control panels/switch boxes are missing

Arc Flash warning labels…electrical hazard.


RAC: 3-IIC



Tracking Number: S-MO0602-10-14-2014 – 172

Description: Electrical switch box (AC-1) has one unused opening in the

side of the box…electrical/fire hazard.


RAC: 3-IIC




Description: Electrical trough next to chiller #1 has unused openings in the

side of the trough box…electrical/fire hazard.


RAC: 3-IIC



Location: Building 110 – Room B20


Description: Electrical control panel (MCC1) covers missing Arc Flash



RAC: 4-IID


Location: Building 110 – Elevator Equipment Room #2



proper danger signage…electrical/amputation hazard. Note: This is a


Recommendation: Properly post warning signs on all entrance doors.

RAC: 3-IIC

Reference: 29 CFR 1910. 145(c)(3)


Tracking Number: S-MO0602-10-14-2014 -176

Description: Pump control panel appears to be abandoned in place (not

properly locked out/tagged out…electrical hazard. Note: This is a repeat

concern from 2012.

Recommendation: Verify equipment is no longer in service and

remove/properly lock out/tag out panel. Abandoned equipment should be

labeled as such and all energy sources should be removed.

RAC: 3-IIC





Description: The elevator control room is not industrial clean (oily rags

not properly stored; chemicals improperly stored, etc.)…fire/chemical


Recommendation: Clean and maintain room and properly store chemicals.

RAC: 3-IIC

Reference: 29 CFR 1910.22(a)(1)/29 CFR 1910.106(d)(5)(iii)



Description: Electrical switch panel cover is missing an Arc Flash warning

label.


RAC: 4-IID


Location: Building 110 – Basement Column F14


Description: Electrical trough has seven unused openings in the bottom of

the box and one unused opening in the side of the box…electrical/fire



RAC: 3-IIC





Description: Electrical circuit breaker panel PP1 Sec 1 circuit breakers are

not correctly labeled; circuit breaker panel PP1 Sec 2 circuit breakers are

not labeled; circuit breaker panel has one unused opening in the bottom of

the box…electrical/fire hazard.


close unused opening.

RAC: 3-IIC




Description: Electrical circuit breaker panel LP1 Sec 1 circuit breaker #8

is not labeled…electrical hazard.


RAC: 3-IIC


Location: Building 110 – Basement Column H11


Description: Energized electrical lighting (277VAC) wiring hanging down

from lighting fixture unguarded at head level…electrocution hazard.

Recommendation: This was immediately corrected.

RAC: 2-IC



Location: Building 110 – Basement Telephone Closet


Description: Telephone closet is not adequately illuminated; holes in

raised flooring that are larger than one inch wide…tripping/electrical

hazard.

Recommendation: Install lighting and properly cover holes.

RAC: 3-IIC

Reference: 29 CFR 1910.303(g)(1)(v)/29 CFR 1910.23(a)(9)

Location: Building 110 – Basement AHU #6


Description: Electrical equipment taken out of service is not properly

locked out/tagged out…electrical hazard.




RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/1910.333(a)(2)

Location: Building 110 – Basement Tunnel Entrance


Description: Light fixture is falling apart exposing energized (277VAC)

wiring inside…electrical/fire hazard.

Recommendation: This was immediately corrected.

RAC: 2-IC





Description: Pallet holding three 55 gallon drums of oil is collapsing

making the 55 gallon drums unstable (two drums are on the verge of

tipping over onto their side).

Recommendation: Replace pallet and properly store drums. Note: This


RAC: 3-IIC


Location: Building 110 – Basement Electrical Closet at Column G3


Description: Electrical circuit breaker panel LP2 Sec1 circuit breaker #6 is



RAC: 3-IIC


Location: Building 110 – Basement Electrical Closet at Column G3


Description: Electrical circuit breaker panel PP2 Sec1 has one unused

opening in the bottom of the panel box…electrical/fire hazard.


RAC: 3-IIC



Location: Building 103F – Cafeteria Dock Area


Description: Working space about electrical equipment is being used for

storage…electrical/fire hazard.

Recommendation: Move items away from the electrical panel and

maintain proper access and working space at all times.

RAC: 3-IIC




Description: Electrical circuit breaker panel Panel-B circuit breakers are

not correctly labeled…electrical hazard.


RAC: 3-IIC




Description: Electrical circuit breaker panel Panel-C circuit breaker #25 is

on but is marked spare indicating it is not properly labeled…electrical

hazard.


RAC: 3-IIC





Description: Electrical circuit breaker panel DB circuit breaker is tagged

out but not locked out; panel cover has one loose screw…electrical/fire

hazard.

Recommendation: Lockout breaker and ensure all cover screws are

properly installed.

RAC: 3-IIC

Reference: 29 CFR 1910.333(b)(2)(iii)[A]/29 CFR 1910.303(b)(1)



Description: Electrical circuit breaker panel EP circuit breakers 19-21 are

improperly tied together (not listed and labeled for such use)...electrical

hazard.

Recommendation: Install circuit breaker designed for such use.

RAC: 3-IIC




Description: Energized electrical wiring hanging down from junction box

unguarded…electrical/fire hazard.

Recommendation: Properly enclose wiring in junction box.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/29 CFR 1910.303(g)(2)(i)




Description: Compressed gas cylinders are improperly stored (not properly

secured from tipping over)…projectile hazard.

Recommendation: Secure cylinders.

RAC: 3-IIC


Location: Building 103F – Penthouse


Description: HVAC equipment fan motor, belt and pulleys, and fan shaft

are not properly guarded (equipment housing is not installed)…amputation

hazard.

Recommendation: Install housing when equipment is not being serviced.

RAC: 3-IIC




Description: Condenser equipment electrical panel box cover is not

installed exposing energized electrical parts inside; junction box cover has

one unused opening in the side of the box…electrical/fire hazard.

Recommendation: Install panel cover and properly close unused opening.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(7)(i)/29 CFR 1910.303(g)(2)(i)




Description: Condenser equipment electrical trough is missing two cover



RAC: 3-IIC




Description: Four condenser equipment fans/fan motors are not properly

guarded; energized condenser equipment electrical wiring is not properly

protected (wiring is exposed)…electrical/fire/amputation hazard.

Recommendation: Install guarding.

RAC: 3-IIC

Reference: 29 CFR 1910.212(a)(5)/29 CFR 1910.303(g)(2)(i)

Location : Building 103F – Penthouse


Description: Electrical circuit breaker panel D2 panel cover latch is

broken (panel circuit breakers are not readily accessible)…electrical

hazard.

Recommendation: Repair/replace latch.

RAC: 3-IIC





Description: Electrical switch C3 has one unused opening in the side of

the switch box…electrical/fire hazard.


RAC: 3-IIC




Description: Two five gallon open buckets of contaminated liquid are

improperly stored (buckets are not properly labeled as to their

contents)…chemical hazard.

Recommendation: Properly label, secure, and store container/dispose as

hazardous wastes.

RAC: 3-IIC

Reference: 29 CFR 1910.1200(f)(6)/29 CFR 1910.22(a)(1)



Description: HVAC equipment duct work front and back edges present a

physical hazard (edge is below 6 feet and unpadded)…struck-by hazard.

Recommendation: Pad bottom edges and mark with yellow caution tape.

RAC: 3-IIIB





Description: Multiple electrical control panels/switch boxes are missing

Arc Flash warning labels…electrical hazard.


RAC: 4-IID




Description: The electrical control box on boiler #2 is missing the cover

exposing the energized electrical wiring inside…electrical/fire hazard.


RAC: 3-IIC





Properly posted; other entrance






RAC: 3-IIC



CHILLER ROOM





CONTACT THE GSA BUILDING MANAGER

FOR INSTRUCTIONS.




Description: Electrical switch TWP1 has one unused opening in the side

of the switch box...electrical/fire hazard.


RAC: 3-IIC




Description: Electrical conduit is being used to support other

items…electrical/fire hazard. Note: This is a repeat concern from 2012.

Recommendation: Remove support from electrical equipment and

properly support.

RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/(b)(2)



Description: Electrical control/switch panels appear to be abandoned in

place (not properly locked out/tagged out)…electrical hazard. Note: This





RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/1910.333(a)(2)




Description: Hole in floor drain grate is larger than one inch


Recommendation: Cover hole/replace grate/cover.

RAC: 3-IIC


Location: Building 105 – Switch Gear Room


Description: Electrical transformer cover is missing an Arc Flash warning

label…electrical hazard.


RAC: 4-IID




Description: Electrical circuit breaker panel LDP7 circuit breaker cover is

not properly adjusted (gap at bottom of cover exposing energized electrical

parts); panel cover has one loose cover screw…electrical/fire hazard.

Recommendation: Adjust cover to eliminate gap and ensure all cover


RAC: 3-IIC

Reference: 29 CFR 1910.303(g)(2)(i)/29 CFR 1910.303(b)(1)




Description: One entrance into the switch gear room is not posted with the

proper danger signage (Danger High Voltage)…electrical hazard.

Recommendation: Properly post all electrical switch gear room entrances

with proper signage.

RAC: 4-IID


29 CFR 1910.335(b)(1)



Description: Multiple exposed AHU flange bearing (rotating shaft) not

properly guarded…amputation hazard.

Recommendation: Install proper guard over rotating shaft…amputation

hazard.

RAC: 3-IIC




Description: Electrical distribution panel covers are missing Arc Flash

warning labels; panel covers have four loose cover screws and one missing

cover screw…electrical hazard. Note: This is a repeat concern from 2012.


RAC: 3-IIC

Reference: 29 CFR 1910.335(b)(1))

http://www.google.com/imgres?q=high+voltage+signs&um=1&hl=en&sa=N&biw=1054&bih=603&tbm=isch&tbnid=l7vnN6luE2zLjM:&imgrefurl=http://www.seton.net.au/danger-signs-high-voltage-authorised-personnel-only-s6654.html&docid=sH9CSryxb_QgcM&w=546&h=406&ei=HHNSTtv6AajJsQKJp6XVBg&zoom=1&iact=rc&dur=389&page=2&tbnh=134&tbnw=180&start=15&ndsp=16&ved=1t:429,r:13,s:15&tx=93&ty=58




Description: Abandoned chiller equipment appears to still have a

refrigerant charge however, it appears the chiller is not being maintained or

monitored for leaks…asphyxiation hazard.

Recommendation: Verify the exact status of the refrigerant and ensure a

leak monitor is installed for equipment inside penthouse if necessary.

Monitor to comply with EPA regulations as well.

RAC: 3-IIC

Reference: ANSI/ASHREA Standard 15, Para. 8.11.2.1

Location: Building 105 – Roof


Description: Ladderways on chiller tower platforms do not have ladder

gates…fall hazard. Note: This is a repeat concern from 2012.

Recommendation: Install ladder gates.

RAC: 3-IIC

Reference: 29 CFR% 1910.23(a)(2)




properly guarded…amputation hazard. Note: This is a repeat concern

from 2012.


hazard.

RAC: 3-IIC





Description: Electrical switch 2A2 has one unused opening in the top of

the switch box…electrical/fire hazard.


RAC: 3-IIC




Description: 120 VAC Damper wiring conduit/box cover is not properly

installed exposing energized wiring inside…electrical/fire hazard.


RAC: 3-IIC




Description: Electrical distribution panel DPA cover is missing two cover

screws…electrical hazard. Note: This is a repeat concern from 2012.


RAC: 3-IIC






properly guarded…amputation hazard.


hazard.

RAC: 3-IIC




Description: Electrical switch 1C2 has one unused opening in the top of

the switch box


RAC: 3-IIC




Description: Electrical distribution panel DPC covers are missing Arc

Flash warning labels; panel covers have three loose cover screws and one

missing cover screw


RAC: 3-IIC





Description: Electrical control box covers are open exposing energized

electrical wiring/parts inside…electrical/fire hazard.

Recommendation: Ensure covers are properly closed when equipment is

not being serviced.

RAC: 3-IIC




Description: Access hatches to the inside of the boilers are not posted with

Permit Required Confined Space signage…asphyxiation hazard.

Recommendation: Post sign on/next to boiler access covers. Note: This


RAC: 4-IID





Properly posted; outside entrance






RAC: 3-IIC



CHILLER ROOM






INSTRUCTIONS.




Description: Electrical circuit breaker panel RP3A31 has one missing

cover screw…electrical/fire hazard. Note: This is a repeat concern from

2012.


RAC: 3-IIC




Description: Emergency light is not properly mounted on the wall

(improperly setting on top of electrical circuit breaker panel

RP3A31)…fire hazard.

Recommendation: Properly mount emergency light and keep electrical

equipment free and clear of storage.

RAC: 3-IIC

Reference: 29 CFR 1910.303(g)(1)/29 CFR 1910.303(b)(8)(i)



Description: Electrical switch gear panel covers are missing Arc Flash

warning labels…electrical hazard. Note: This is a repeat concern from

2012.


RAC: 4-IID





Description: Electrical chiller control/switch cabinet covers are missing

Arc Flash warning labels.


RAC: 4-IID




Description: Abandoned boiler equipment appears is not properly locked

out/tagged out (must lock out/tag out electrical power, gas, and

water)…electrical/fire hazard.




RAC: 3-IIC




Description: Electrical switch box SD1 has one unused opening in the

front of the box where the switch used to be…electrical hazard. Note:



RAC: 3-IIC





Description: Electrical distribution panel covers are missing Arc Flash

warning labels; panel covers have two loose cover screws and one missing

cover screw.

Recommendation: Install an Arc Flash warning labels and ensure all cover


RAC: 4-IID




Description: Electrical circuit breaker panel PPE 43-A has two unused

openings in the front of the panel (circuit breaker slots #24 and #32);

circuit breakers are not labeled; circuit breaker panel covers have one loose

and one missing cover screw…electrical/fire hazard.

Recommendation: Properly close unused openings and ensure all cover


RAC: 3-IIC

Reference: 29 CFR 1910.303(b)(1)/29 CFR 1910.303(b)(7)(i)



Description: Electrical circuit breaker panel PPE 43 has two unused

openings in the front of the panel (circuit breaker slots #38 and #40);

circuit breakers are not labeled…electrical/fire hazard.


RAC: 3-IIC



Location: Building 105 – Throughout Complex


Description: Monthly inspections and annual maintenance checks have not

been accomplished on fire extinguishers throughout the complex; multiple

fire extinguishers are not properly mounted on wall…fire hazard.

Recommendation: Perform monthly inspections/annual maintenance

checks.

RAC: 4-IID

Reference: 29 CFR 1910.157(c)(1)-(4)/29 CFR 1910.157(e)(1)-(5)

APPENDIX A - CONTAMINATION

The following three significant environmental contamination issues that affect employee safety and health

were noted:

1) Multiple facility spaces that contain approximately 83 air, soil, water, and surface

contaminates have not been properly evaluated to determine the amount, toxicity, or extent of the

hazards involved and actions (i.e. engineering controls, administrative controls, personal

protective equipment, etc.) required to protect GSA personnel and other federal agency

employees, contractors, vendors, and visitors. These spaces include multiple facility occupied

spaces, basements, crawl spaces, utility tunnels, and the spaces above suspended ceiling tiles in

occupied space in buildings 101, 102, 102D, 102E, 103, 103D, 103E, 103F, 104, 104E, 104F,

105, 105E, 105F, 108A, 108B, 110, 115, 122B, 141C and the utility tunnels. The reported

contaminants include arsenic, asbestos, cyanide, explosive compounds, antimony, beryllium,

copper, lead, mercury, silver, polychlorinated biphenyls (PCBs), phosphorus, acetone, multiple

semi-volatile organic and volatile organic compounds that include total petroleum hydrocarbons

(TPHs) – gasoline/diesel/oil organic compounds. Approximately 27 of these contaminates were

found in concentrations that exceed various federal or state environmental action thresholds and

pose a potential safety and health hazard to workers.

The Goodfellow Federal Complex is part of a WWII vintage Army Ammunition Plant that was

converted to federal office space in the 1960’s and 1970’s. GSA R6 Environmental Program

Managers have known the Goodfellow Federal Complex was potentially contaminated since 2002

or before. Several studies/investigations between 2002 and 2008 confirmed the complex was

environmentally contaminated. In 2008, SCS engineers reported in their Combined Preliminary

Assessment/Site Inspection Report the complex was environmentally contaminated with specific

recommendations to protect employees while working in contaminated spaces. With the

exception of several asbestos mitigation projects, a search of records did not turn up any evidence

that the regional management took any action, other than initiating additional investigations

and/or studies, to inform or protect personnel when working in contaminated building spaces

prior to September, 2015.

Of particular concern is the friable asbestos contamination in the basement/basement crawlspace

soil identified in the 2013 Tetra Tech Occupational Exposure Evaluation. Tetra Tech

recommended “GSA implement engineering or institutional controls to prevent occupational

exposure to and the unauthorized disturbance or dispersion of contamination” in the

basement/basement crawl spaces in buildings 102E, 103, 103D, 103E, 103F, 104, 104E,105,

105E, and 105F. Friable asbestos laden soil/dust is easily disturbed and can become airborne and

remain airborne for several days before settling back out into the dirt. Since friable asbestos

becomes airborne so easily when disturbed, immediate action to protect worker safety and health

for personnel working in those areas should have been taken. GSA R6 Environmental Program

Managers, Field Office Managers, and Design and Construction Project Managers could not

provide any indication action was taken to account for the friable asbestos laden dust/soil in these

facilities except Building 107. The basement crawl space soil in Building 107 was contaminated

with friable asbestos laden dust/soil that was abated during the GSA office renovation project in


2012. How or why the contamination in Building 107 crawl space was known by the regional

environmental manager and not the rest of the buildings is not understood.

Particulate lead is also of particular concern. The region has conducted multiple studies

specifically identifying particulate lead since at least 2008. Lead has been identified in multiple

building basement, basement crawl spaces, and utility tunnels in both surface wipe and soil

sampling. Particulate lead has also been identified in wipe samples in first and second floor

occupied spaces as well the spaces above the suspended ceiling. Several additional

assessments/studies to address particulate lead were commissioned by GSA regional

environmental program managers reconfirmed the issue between 2009 and 2013. Multiple

construction projects and several extensive renovation projects have taken place in spaces

contaminated with particulate lead. Even though most of the reports provided specific

recommendations to address the issues to protect personnel working in contaminated spaces,

GSA R6 environmental program managers, field office managers, and design and construction

project managers could not provide any indication action was ever taken to account for lead dust

contamination in these facilities.

Mercury vapor was reported in the basement/basement crawl spaces in buildings 102, 102D, 103,

103D, 103F and 104 and the utility tunnels associated with them. Mercury vapor in particular

presents a difficult issue to address because of the required respiratory protection it would take to

protect employees entering those spaces. Two samples collected in 2008 by SCS Engineers

indicated particulate mercury and/or mercury vapor was present. Test results were high enough

to warrant concern by the current GSA R6 Industrial Hygienist. The current GSA R6 Industrial

Hygienist determined the most conservative PEL/TLV from the American Conference of

Governmental Industrial Hygienist (ACGIH) was the most appropriate PEL for this situation and

determined additional sampling was required. In October 2015, the R6 Industrial Hygienist,

Safety Specialist, and Environmental Engineer dispatched to the Goodfellow Federal Complex to

perform additional sampling. Twenty-seven additional samples were taken in October, 2015. All

but two samples were below the non-detectable level and those two were barely above the non-

detectable level and well below the ACGIH PEL/TLV. However, the most recent uncovered

report identified two additional spaces that require testing. Unless testing in those two areas

indicates otherwise, the R6 Industrial Hygienist has determined that the mercury vapor has

dissipated over the past seven years and is no longer an issue for all the buildings except Building

102 and 102D, which are no longer in service and off-limits.

In addition to asbestos and lead, the soil in the basement crawl spaces of multiple complex

facilities and the surrounding exterior grounds is contaminated with a variety of semi-volatile

organic compounds, volatile organic compounds, explosives compounds, toxic metals and PCBs.

Some of the activities that take place in the building basement/basement crawl spaces and utility

tunnels include operations and maintenance to support the facility infrastructure such as heating,

ventilation, and air conditioning, fire protection equipment, facility plumbing, and electrical

system and information technology and communications equipment and cabling.


Plumbing maintenance is a given concern because the complex is World War II vintage and the

in-ground piping and sewer system are failing and require extensive repairs/replacement. In

addition to disturbing the soil, just walking in these spaces has the potential to create a respirable

dust issue. Activities in surrounding grounds include a large scale sewer replacement project.

Cross contamination of office spaces and individuals homes is also a possibility because the

proper precautions have not been in place to decontaminate upon leaving contaminated spaces.

2) A proper hazard evaluation has not been conducted to determine the personal protective

equipment required to protect employees when entering contaminated spaces. OSHA regulations

require employers to access the workplace to determine if hazards are present, or likely to be

present, which necessitates the use of personal protective equipment. Although several of the

reports identifying contamination issues had specific recommendations to protect employees

working in contaminated spaces, those recommendations were spread out over a seven year

period with no evidence most were ever acted upon.

These types of environmental contamination issues are difficult to assess because they do not

correlate directly to OSHA permissible exposure limits. OSHA requirements are very task

specific i.e. the level of protection and monitoring is determined by the who, what, when, where,

and how the specific task being performed and the level of exposure to contaminants at the time.

The assessment is only good for that one specific task. A change in the task, number of personnel

performing the task, environmental, space, or equipment condition, or the task itself can render

the assessment invalid and a new assessment and monitoring are then required to be

accomplished.

3) Contaminated spaces have not been properly posted or communicated to warn employees,

tenants, visitors, or contractors of the hazards present. Interviews revealed St. Louis West Field

Office managers, field office and regional construction project managers, and regional

contracting officers were unaware of facility contamination issues prior to putting together this

report. There was no warning signage posted in any contaminated spaces. Field office employee

interviews revealed many of the new field office personnel were unaware of any contamination

related safety or health issues in the facilities on the complex or any precautions that needed to

take when entering contaminated spaces. Many of the field office employees perform duties in

contaminated spaces on a daily/weekly basis without taking any precautions. Regional and field

office managers also stated they have not communicated or incorporated the contamination issue

to contractors, particularly the Operations and Maintenance Contractor responsible for operating

the facilities on the complex. A quick review of several major renovation projects completed

within the past five years in facilities with contamination issues revealed project scopes of work

did not contain information concerning contaminants or any actions required to protect worker

and building tenant safety and health.


The following recommendations are provided:

Due to the scope and magnitude of this issue, the responsibility to correct these items has shifted

from the St. Louis West Field Office to the Region 6 CAB with assistance from the Design and

Construction and Facilities Management Divisions. An action plan has been developed and a

senior executive manager, project manager, and project team have been assigned to this issue.

1) Field Office – Post and maintain signage at the entrance to contaminated spaces and

communicate the contamination issue to employees, tenants, visitors, and contractors/vendors as

required.

NOTE: The basement/basement crawl spaces have been posted. The basement and

basement crawl spaces have been placed off-limits to unauthorized personnel until a site

specific safety plan with the proper hazard assessments and protocols can be put into

place.

2) Field Office – Control access to all contaminated spaces to authorized personnel. Do not

allow personnel into contaminated spaces until the proper site specific safety plan is fully

developed that identifies the proper protocols. Provide the proper personal protective equipment

and training to all field office personnel accessing contaminated spaces and follow all prescribed

safety and health protocols set forth in the site specific safety plan when it is complete. Ensure

contamination is communicated through contract language and contamination safety protocols are

addressed in all field office construction projects.

NOTE: Contract language was issued in early January, 2016 to notify all contractors of

the contamination. It is currently being modified to provide more information. A

regional project team has been assigned as of January 30, 2016 and an action and

communications plan along with a site specific safety plan is under development. This

includes additional sampling to verify contaminates in building spaces. Region 6 has also

contracted for a remedial investigation (RI) study for the entire complex to characterize

environmental conditions in the soil, groundwater, and air. The RI will be complete by

the end of this summer, 2016.

3) Regional Office – Communicate the contamination issue to employees, tenants, visitors, and

contractors/vendors as required.

NOTE: See note for recommendation number 2) above.

4) Regional Office – Control access to all contaminated spaces to authorized regional personnel.

Do not allow personnel into contaminated spaces until the proper site specific safety plan is fully

developed that identifies the proper protocols. Provide the proper personal protective equipment

and training to all regional office personnel accessing contaminated spaces and follow all

prescribed safety and health protocols set forth in the site specific safety plan when it is complete.


Ensure contamination is communicated through contract language and contamination safety

protocols are addressed in all regional office construction projects.

NOTE: See note for recommendation number 2) above.

5) Regional Office – Develop and publish a site specific safety plan to be followed by all

affected GSA employees.

NOTE: A draft safety plan was issued in October, 2015 and regional personnel were

notified of the contamination. The final plan was pending mercury vapor sampling

results from testing performed in October, 2015. However, discovery of two reports

identifying additional contaminants/hazards rendered the plan obsolete. As of December

21, 2015 contaminated basement/basement crawl spaces and utility tunnels have been

placed off-limits until a new plan is developed.

6) Regional Office – Conduct testing/sampling to validate/verify contamination issues in

occupied space and basement/and utility tunnel areas.

NOTE: Because multiple spaces in question have changed over the past several years

due to substantial construction and renovation projects, additional sampling to verify the

spaces as they are situated today is required. The newly formed GSA R6 Goodfellow

Contamination Project Team was putting together the contract for testing/sampling to

address this item as of January 31, 2016.

7) Regional Office – Develop and implement an action plan to immediately verify/validate any

corrective action that may have already taken place and address remaining actions required

to mitigate contamination in basement/basement crawl spaces, utility tunnels, spaces above

suspended ceilings, and any occupied space with contamination issues.

NOTE: Initial planning started in September, 2015 but significantly slowed down as

additional environmental reports were uncovered, identifying additional contamination

issues. Several of the most serious contaminants were not uncovered until mid-

December, 2015. A lack of communication between the GSA R6 Facilities Division,

Design and Construction Division, and construction contractors currently working

projects in contaminated spaces may have exposed construction workers to

contamination. It is not clear where the breakdown occurred.

8) Regional Office – Develop and implement an action plan to address contamination at the

Goodfellow Federal Complex.

NOTE: GSA R6 has put together a project management team in January, 2016 to address

all the Goodfellow Federal Complex contamination issues. The team has been tasked to


address both short term and long term environmental and occupational safety and health

concerns.

9) Regional Office – Offer one time medical testing to employees determine that have

potentially been exposed to contaminants. The medical testing should be limited to the specific

contaminants personnel were exposed to.

APPENDIX B - ELEVATORS

The following four significant elevator issues were noted:

1) Four elevators in complex buildings (Building 104 - B16, Building 105 – B16, Building 105 –

B45, and Building 105F – M26) and their associated support equipment are operating well past

their service life. The actual age of this equipment cannot be precisely determined because the

equipment does not have any data plates nor are there any records of when it was installed. The

R6 elevator SME (35 years of elevator industry experience) estimated the age from the equipment

type and manufacturer. According to the regional elevator SME, these elevators have an

intended useful life of 30 to 35 years and appear to have been installed as original equipment

back in the 1940’s making them approximately 70 years old and approximately 35 to 40 years

past their service life expectancy.

Note: A concern that is larger than the elevator issues here is that there is no specific replacement

program or process that captures the end of service life of equipment in the region. This is a

systemic issue across the region that has surfaced multiple times across multiple disciplines in the

past few years. This issue was brought up as part of the Goodfellow electrical vault issue in 2012

and again in 2015 as part of the 2306 Bannister electrical transformer emergency replacement

issue. The region is in the beginning stage of addressing this issue through the Consolidated

Maintenance Management System (CMMS) program.

Due to the age of the elevator infrastructure, i.e. support rails, beams, car, sheaves, pulleys,

connecting hardware, and mechanical parts and assemblies, the serviceability of this equipment is

very questionable. Three of these elevators are freight elevators that have seen high use and

heavy loads in the past. Additionally, the building infrastructure housing this equipment has not

been well maintained in the recent past because this complex was slated for disposal. The light

use the elevators receive today, the craftsmanship of the equipment itself, and the ability of the

elevator service technicians to keep them operating masks this issue and may create a false sense

of security for field office and regional managers.

2) Access to unguarded 70 year old electrical equipment (40-400 VAC/DC) is open to

unqualified personnel. OSHA regulations require unguarded electrical equipment be protected by

an approved enclosure (such as a cabinet) or separated by location (such as a room) only

accessible to qualified persons. OSHA defines qualified person as one who has received training

in and has demonstrated skills and knowledge in the construction and operation of electric

equipment and installation and hazards involved. None of the four elevator equipment areas meet

this requirement. They are in open penthouse areas that can be accessed by anyone.

3) The mechanical aspect of the elevator equipment is not properly guarded. OSHA requires

personnel be protected from accidental contact with moving parts such as flywheels, sheaves,

governors, etc. to prevent amputation. This was not a requirement when the equipment was

installed 70 years ago however, it did become a requirement approximately 30 years ago and is

still a requirement today. GSA has the responsibility to protect all employees who work in

elevator equipment areas including elevator technicians.

APPENDIX B - ELEVATORS

Due to the scope and magnitude of this issue, the responsibility to correct these items has shifted

from the St. Louis West Field Office to the Region 6 CAB with assistance from the Facilities

Division.

1) Field Office – Determine if any of the elevators can be removed from service

completely. NOTE: The Regional Elevator SME recommends de-commissioning the B-

16 elevators in both building 104 and 105, replacing the B-45 elevator in building 105

and the M-36 elevator in building 105F.

2) Regional Office – Develop an action plan to decommission/replace all four elevators.

Careful consideration must be given to the current state of equipment condition and how

much longer, if at all, the elevators can remain in service. In addition, careful

consideration must also be given in meeting OSHA equipment guarding requirements

and controlling access to the equipment areas remaining in service until it is replaced.

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