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June 2021

Iowa OSHA Fines Storage Operator

The Iowa Occupational Safety and Health Administration (OSHA) recently conducted in on-site inspection of an Iowa Self Storage Association member, resulting in an initial fine of nearly $40,000. Please review the information below carefully; what may seem to be a fairly routine oversight can lead to a hefty fine.

The operator was cited for eight “serious” violations and four “other-than-serious” violations, including:

• IAC 875 - Chapter 10. 1910.23(b)(9): The employer did not ensure that ladders are inspected before initial use in each work shift, and more frequently as necessary, to identify any visible defects that could cause employee injury.
• IAC 875 - Chapter 10. 1910.28(b)(3)(ii): The employer did not ensure each employee is protected from tripping into or stepping into or through any hole that is less than 4 feet (1.2 m) above a lower level by covers or guardrail systems.
• IAC 875 - Chapter 10. 1910.37(b)(2): Each exit was not clearly visible and marked by a sign reading "Exit".
• IAC 875 - Chapter 10. 1910.37(b)(5): Each doorway or passage along an exit access that could be mistaken for an exit must be marked "Not an Exit" or similar designation, or be identified by a sign indicating its actual use (e.g., closet).
• IAC 875 - Chapter 10. 1910.110(f)(2)(ii): Containers when stored inside were located near exits, stairways, or in areas normally used or intended for the safe exit of people.
• IAC 875 - Chapter 10. 1910.304(g)(5): The path to ground from circuits, equipment, and enclosures was not permanent, continuous, and effective.
• IAC 875 - Chapter 10. 1910.334(a)(2)(i): Flexible cord sets (extension cords) were not visually inspected before use on any shift for external defects (such as loose parts, deformed and missing pins, or damage to outer jacket or insulation) and for evidence of possible internal damage (such as pinched or crushed outer jacket).
• IAC 875 - Chapter 10. 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program.
• IAC 875 - Chapter 10. 1904.32(b)(6): The OSHA 300-A Summary was not posted by February 1 of the year following the year covered by the records and/or kept in place until April 30.
• IAC 875 - Chapter 10. 1910.1200(f)(6): The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked.
• IAC 875 - Chapter 10. 1910.1200(g)(8): The employer did not maintain in the workplace copies of the required safety data sheets for each hazardous chemical and did not ensure that they were readily accessible during each work shift to employees when they were in their work area(s).

Given the recent self storage inspection, owners should assess their facilities for these and similar workplace hazards and potential compliance shortfalls. Owners should also consider retaining a consulting firm to assist with a compliance audit. These audits can assist with identification and remediation of any workplace health and safety issues.

Please contact Joe Doherty or Daniel Bryant if you have any questions.