Tier 3 Elevated

CLARKE PRODUCTS INC.

📍 2100 B ORCHARD LANE, WACO, TX 76705🏭 Plastics Plumbing Fixture Manufacturing (NAICS 326191)📅 2018-04-19
$154,883.50
Total Penalties
53
Citations
65/100
Risk Score
489
Analysis Words
Enforcement Analysis

According to U.S. Department of Labor enforcement records, CLARKE PRODUCTS INC. — a plastics plumbing fixture manufacturing facility located at 2100 B ORCHARD LANE, WACO, TX 76705 — was the subject of a formal OSHA inspection that resulted in 53 citation(s) and cumulative proposed penalties of $154,883.50. The inspection case was opened on 2018-04-19.

Cumulative penalties significantly exceed the national median for OSHA enforcement actions. The penalty amount suggests multiple high-gravity citations, indicating conditions that presented a substantial probability of death or serious physical harm to employees.

BLS Injury Data: According to the Bureau of Labor Statistics (2022), this industry sector has an occupational injury rate of 3.3 per 100 full-time workers — 22% above the national average of 2.7. The sector fatality rate is 2.3 per 100,000 workers.

EPA Environmental Record: regulated under: Toxics Release Inventory. Toxic Release Inventory reports 20030 lbs in releases/transfers. Source: EPA ECHO database.

Industry Benchmark: The total penalty of $154,883.50 is more than 18.4× the national average of $8,414.32 for facilities in the Manufacturing sector (NAICS 326191). This sector encompasses 52,095 inspected facilities nationwide with aggregate penalties totaling $438.3M.

State Context: Within TX, this facility's penalty places it at the 100th percentile among 119,485 inspected facilities. The statewide average penalty is $3,783.80.

Citation Analysis: The inspection produced 53 citations spanning 8 distinct OSHA regulatory standards. The citation breakdown includes: 14 serious — A workplace hazard that could cause death or serious physical harm exists, and the employer knew or should have known about the condition. 1 repeat — A substantially similar violation was found during a previous inspection and the original citation has become a final order.

Enforcement Timeline: Citations were issued beginning August 14, 2015 with the latest abatement deadline set for October 30, 2018. Of the 53 total citations, 0 (0%) have been marked as abated in DOL records, which may indicate ongoing compliance gaps requiring further regulatory attention.

Penalty Assessment: The cumulative penalty of $154,883.50 reflects OSHA's gravity-based penalty calculation methodology, which considers the severity of potential injury, the probability of occurrence, the employer's size, good faith, and violation history. The per-citation average of $2,922.33 falls within the standard penalty range.

The inspection of Clarke Products Inc. revealed a pervasive breakdown in safety management systems, characterized by high-gravity violations across multiple critical domains. The sheer volume of citations—exceeding fifty—indicates a systemic failure rather than isolated oversights. Most concerning was the presence of a repeat violation regarding respiratory protection (1910.134), which signaled a legal failure to correct previously identified hazards and exposed the workforce to ongoing inhalation risks. The high-gravity ratings (Gravity 10) associated with flammable liquid storage and spray finishing operations (1910.106 and 1

Citation Matrix — 53 Citations
29 CFR 1910.95(c)(01)
Serious
Penalty: $2,700.00Gravity: 5Issued: August 14, 2015Abated: Pending
29 CFR 1910.134(k)
Fall Protection — General Requirements
Serious
Penalty: $2,700.00Gravity: 5Issued: August 14, 2015Abated: Pending
29 CFR 1910.1200(e)(01)
Hazard Communication Standard (Chemical Safety)
Serious
Penalty: $3,600.00Gravity: 5Issued: August 14, 2015Abated: Pending
29 CFR 1910.1200(h)(01)
Hazard Communication Standard (Chemical Safety)
Serious
Penalty: $0.00Gravity: 5Issued: August 14, 2015Abated: Pending
29 CFR 1910.134(e)(01)
Fall Protection — General Requirements
Repeat
Penalty: $5,040.00Gravity: 5Issued: August 14, 2015Abated: Pending
OSHA Std. 5A0001
Serious
Penalty: $4,979.50Gravity: 10Issued: October 1, 2018Abated: Pending
29 CFR 1910.29(b)(02)
Serious
Penalty: $2,845.50Gravity: 5Issued: October 1, 2018Abated: Pending
29 CFR 1910.36(e)(02)
Serious
Penalty: $3,557.00Gravity: 5Issued: October 1, 2018Abated: Pending
29 CFR 1910.106(e)(06)
Serious
Penalty: $4,979.50Gravity: 10Issued: October 1, 2018Abated: Pending
29 CFR 1910.107(b)(09)
Serious
Penalty: $4,979.50Gravity: 10Issued: October 1, 2018Abated: Pending
29 CFR 1910.107(c)(06)
Serious
Penalty: $4,979.50Gravity: 10Issued: October 1, 2018Abated: Pending
29 CFR 1910.107(g)(07)
Serious
Penalty: $3,557.00Gravity: 5Issued: October 1, 2018Abated: Pending
29 CFR 1910.147(c)(04)
Control of Hazardous Energy (Lockout/Tagout)
Serious
Penalty: $4,979.50Gravity: 10Issued: October 1, 2018Abated: Pending
29 CFR 1910.147(c)(07)
Control of Hazardous Energy (Lockout/Tagout)
Serious
Penalty: $4,979.50Gravity: 10Issued: October 1, 2018Abated: Pending
29 CFR 1910.147(c)(07)
Control of Hazardous Energy (Lockout/Tagout)
Serious
Penalty: $0.00Gravity: 10Issued: October 1, 2018Abated: Pending
This report is compiled from publicly available U.S. Department of Labor enforcement data under the Freedom of Information Act. SVEP Navigator is an independent research and analysis platform and is not affiliated with, endorsed by, or connected to OSHA, the Department of Labor, or any federal agency. Information is provided for research, educational, and compliance planning purposes only and does not constitute legal advice. Penalty amounts shown are proposed penalties and may have been modified through contest proceedings or settlement.
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