Tier 1 Critical

FAURECIA EMISSIONS CONTROL SYSTEMS NA, LLC

📍 2301 COMMERCE CENTER DR, FRANKLIN, OH 45005🏭 Manufacturing (NAICS 336390)📅 2019-01-16
$188,329.20
Total Penalties
13
Citations
91/100
Risk Score
632
Analysis Words
Enforcement Analysis

According to U.S. Department of Labor enforcement records, FAURECIA EMISSIONS CONTROL SYSTEMS NA, LLC — a manufacturing facility located at 2301 COMMERCE CENTER DR, FRANKLIN, OH 45005 — was the subject of a formal OSHA inspection that resulted in 13 citation(s) and cumulative proposed penalties of $188,329.20. The inspection case was opened on 2019-01-16.

This facility represents one of the most severe enforcement actions in the OSHA SVEP database. Willful violations combined with penalties exceeding $100,000 indicate a pattern of deliberate non-compliance that poses an imminent danger to workers.

Industry Benchmark: The total penalty of $188,329.20 is more than 29.3× the national average of $6,436.62 for facilities in the Manufacturing sector (NAICS 336390). This sector encompasses 82,943 inspected facilities nationwide with aggregate penalties totaling $533.9M.

State Context: Within OH, this facility's penalty places it at the 100th percentile among 91,405 inspected facilities. The statewide average penalty is $3,818.37.

Citation Analysis: The inspection produced 13 citations spanning 3 distinct OSHA regulatory standards. The citation breakdown includes: 6 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 willful — The employer intentionally and knowingly committed the violation, demonstrating either an intentional disregard for the requirements of the OSH Act or plain indifference to employee safety and health. 4 repeat — A substantially similar violation was found during a previous inspection and the original citation has become a final order. 2 other-than-serious — The violation has a direct relationship to job safety and health but is unlikely to cause death or serious physical harm.

Enforcement Timeline: Citations were issued beginning July 3, 2019 with the latest abatement deadline set for January 31, 2020. Of the 13 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 $188,329.20 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 $14,486.86 falls within the standard penalty range.

The enforcement action against Faurecia Emissions Control Systems reveals a profound breakdown in chemical hygiene and respiratory protection protocols, specifically regarding hexavalent chromium (Cr(VI)) exposure. The presence of a "Willful" violation under 1910.1026(k)(1)(i)(A) is the most damning element of this record; it signifies that management either acted with intentional disregard for OSHA requirements or demonstrated plain indifference to employee safety regarding medical surveillance. This legal designation significantly elevates the facility's liability profile, as it moves the needle from simple negligence to a conscious failure to protect workers from a known carcinogen. The high frequency of "Repeat" violations further indicates a systemic failure to implement sustainable corrective actions. When a facility is cited repeatedly for the same standards—specifically concerning Cr(VI) communication and training—it suggests that previous citations were treated as a cost of doing business rather than a catalyst for safety culture reform. The $188,329 penalty is substantially higher than the industry average for NAICS 336390, reflecting the high gravity assigned to these hazards. Practically, workers were subjected to an environment where the fundamental barriers against chronic lung disease and skin ulcerations were bypassed. The interplay between inadequate respiratory fit testing and the failure to provide proper hygiene facilities and medical monitoring points to a facility-wide breakdown in the hierarchy of controls, transforming a manageable industrial risk into a severe long-term health liability.

Citation Matrix — 13 Citations
29 CFR 1910.134(k)(05)
Fall Protection — General Requirements
Serious
Penalty: $6,251.40Gravity: 5Issued: July 3, 2019Abated: Pending
29 CFR 1910.1026(c)
Serious
Penalty: $6,251.40Gravity: 5Issued: July 3, 2019Abated: Pending
29 CFR 1910.1026(f)(01)
Serious
Penalty: $0.00Gravity: 5Issued: July 3, 2019Abated: Pending
29 CFR 1910.1026(h)(01)
Serious
Penalty: $3,750.60Gravity: 1Issued: July 3, 2019Abated: Pending
29 CFR 1910.1026(i)(03)
Serious
Penalty: $5,001.00Gravity: 5Issued: July 3, 2019Abated: Pending
29 CFR 1910.1026(i)(05)
Serious
Penalty: $0.00Gravity: 5Issued: July 3, 2019Abated: Pending
29 CFR 1910.1026(k)(01)
Willful
Penalty: $79,558.80Gravity: 10Issued: July 3, 2019Abated: Pending
29 CFR 1910.1026(l)(01)
Repeat
Penalty: $43,758.00Gravity: 10Issued: July 3, 2019Abated: Pending
29 CFR 1910.1200(h)(03)
Hazard Communication Standard (Chemical Safety)
Repeat
Penalty: $0.00Gravity: 10Issued: July 3, 2019Abated: Pending
29 CFR 1910.1026(l)(02)
Repeat
Penalty: $43,758.00Gravity: 10Issued: July 3, 2019Abated: Pending
29 CFR 1910.1026(l)(02)
Repeat
Penalty: $0.00Gravity: 10Issued: July 3, 2019Abated: Pending
29 CFR 1910.1026(i)(04)
Other-than-Serious
Penalty: $0.00Gravity: nanIssued: July 3, 2019Abated: Pending
29 CFR 1910.1200(g)(08)
Hazard Communication Standard (Chemical Safety)
Other-than-Serious
Penalty: $0.00Gravity: nanIssued: July 3, 2019Abated: 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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