March 11, 1986
| MEMORANDUM FOR: |
ASSISTANT REGIONAL ADMINISTRATORS
AREA DIRECTORS
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| FROM: |
BYRON R. CHADWICK
Regional Administrator
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| SUBJECT: |
Long-Term Abatements: Monitoring Inspections |
Paragraph II, E.1.c. of the FOM provides specific guidance on how frequently
we are to make monitoring inspections when a long-term abatement plan is in
effect, and for PMAs on serious, willful, and repeated violations. If these
inspections are not made, the possibility exists that assigned interim
abatement action will not be done on time, resulting in unnecessary
continuing exposure for the affected employees.
I believe it is very important for us to make monitoring inspections in
cases where abatement periods in excess of six months are involved. The exact
frequency of these monitoring inspections will be determined on a
case-by-case basis. Factors to be considered in setting monitoring
inspection frequency include the severity of the hazard and number of
employees exposed, any correspondence between you and the employer and
employees which will verify interim abatement, the number and type of interim
abatement steps involved, and other pertinent factors. Note that per FOM
paragraph III.I.2, these monitoring inspections are conducted in the same
manner as follow-up inspections.
Effective immediately, one or more monitoring inspections shall normally be
made in every case which has an abatement period in excess of six months, in
addition to any final follow-up inspection that might be conducted. You
shall document in each such case file the reinspection schedule, briefly
justifying the inspection frequency chosen. If the monitoring inspection is
not made, you shall thoroughly document in the case file the reasons why an
inspection was not made.
For PMAs, a monitoring visit shall be made on those which result in a final
abatement date of six months or more from the original or most recent
abatement date. This inspection shall be conducted as soon as possible after
first contact with the employer, but no later than 15 working days following
the receipt of certification of posting. For PMAs which will result in very
long abatement periods, monitoring visits shall be made every six months.
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