RFX2025XJR339X0086 - POSITIVE SPRAY FOAM LLC

According to U.S. Department of Labor enforcement records, RFX2025XJR339X0086 - POSITIVE SPRAY FOAM LLC — a roofing contractors facility located at 711 W MADISON STREET, PHOENIX, AZ 85053 — was the subject of a formal OSHA inspection that resulted in 11 citation(s) and cumulative proposed penalties of $57,899.00. The inspection case was opened on 2024-12-10.

Federal investigators determined that one or more violations at this facility were committed willfully — meaning the employer either knowingly failed to comply with OSHA standards or acted with plain indifference to employee safety. Willful violations carry the highest penalty multipliers under the OSH Act.

BLS Injury Data: According to the Bureau of Labor Statistics (2022), this industry sector has an occupational injury rate of 2.8 per 100 full-time workers — 4% above the national average of 2.7. The sector fatality rate is 9.6 per 100,000 workers.

Industry Benchmark: The total penalty of $57,899.00 is more than 16.0× the national average of $3,609.14 for facilities in the Construction sector (NAICS 238160). This sector encompasses 532,749 inspected facilities nationwide with aggregate penalties totaling $1,922.8M.

State Context: Within AZ, this facility's penalty places it at the 100th percentile among 28,263 inspected facilities. The statewide average penalty is $1,378.92.

Citation Analysis: The inspection produced 11 citations spanning 6 distinct OSHA regulatory standards. The citation breakdown includes: 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. 2 repeat — A substantially similar violation was found during a previous inspection and the original citation has become a final order. 8 serious — A workplace hazard that could cause death or serious physical harm exists, and the employer knew or should have known about the condition.

Enforcement Timeline: Citations were issued beginning April 24, 2025 with the latest abatement deadline set for May 15, 2025. Of the 11 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 $57,899.00 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 $5,263.55 falls within the standard penalty range.

The enforcement record for Positive Spray Foam LLC reveals a deeply concerning pattern of systemic non-compliance that transcends simple administrative oversight. The presence of a Willful violation under 1926.501(b)(1) serves as the legal focal point of this inspection; it demonstrates that management acted with either intentional disregard for or plain indifference to fall protection requirements. In the roofing and insulation sector (NAICS 238160), where falls remain the leading cause of fatalities, such a designation indicates a profound breakdown in the company’s safety culture. The $57,899 total penalty is significantly higher than the industry average for small-to-mid-sized contractors, reflecting the gravity of exposing workers to unprotected edges. Beyond fall hazards, the citation cluster involving respiratory protection (1910.134) and hazard communication (1910.1200) highlights a failure to manage the chemical risks inherent in spray foam operations. The repeat violations (Type R) for failing to maintain safety data sheets and provide adequate training suggest that previous warnings went unheeded, escalating the legal and financial exposure for the firm. By failing to implement medical evaluations and fit testing while simultaneously neglecting chemical hazard training, the employer created a high-risk environment for long-term pulmonary illness. This combination of willful fall exposure and repeated chemical safety failures points to a comprehensive collapse of the firm’s safety management system rather than an isolated incident.