A proposed rule for cranes and derricks in construction will soon be published in the Federal Register. The public comment period on the proposed rule will begin after the proposal has been formally published in the Federal Register.
"The cranes and derricks proposed rule comprehensively addresses the hazards associated with the use of cranes and derricks in construction, including tower cranes," said Edwin G. Foulke Jr., assistant secretary of labor for OSHA. "This draft rule will both protect construction employees and help prevent crane accidents by updating existing protections and requiring crane operators to be trained in the use of construction cranes."
The cranes and derricks proposed rule would apply to the estimated 96,000 construction cranes in the United States, including 2,000 tower cranes. The proposed standard addresses key safety issues associated with cranes, including ground conditions, the assembly and disassembly of cranes, the operation of cranes near power lines, the certification and training of crane operators, the use of safety devices and signals, and inspections of cranes. It significantly updates existing tower crane requirements and more comprehensively addresses tower crane safety, with respect both to erecting and dismantling, and to crane operations.
The proposed standard would establish four options for the qualification or certification of crane operators: 1) certification through an accredited third-party testing organization, 2) qualification through an audited employer testing program, 3) qualification issued by the U.S. military, and 4) qualification by a state or local licensing authority.
This proposed rule was developed through negotiated rulemaking by the Cranes and Derricks Advisory Committee (C-DAC). The federal Advisory Committee on Construction Safety and Health subsequently recommended that OSHA use that document for developing its proposed rule. Since then, and as required by law, OSHA has conducted a regulatory flexibility analysis, small business review, and paperwork burden analysis of the proposed rule. In addition, OSHA was required to write a preamble to the regulatory proposal that explains in detail the purpose and application of the proposed standard. That preamble is almost 1,000 pages. The members of C-DAC were sent an advance copy for review as part of their role in the negotiated rulemaking.
New eTool on Powered Industrial Trucks
Employers who use forklifts in their workplaces have a new resource to help keep their employees safe on the job.
This eTool, which identifies forklifts commonly used in general industry, provides a review of potential hazards and a summary of key OSHA requirements and industry-recommended practices for forklift operations. It includes four modules examining the types of forklifts, safe operating practices, workplace conditions affecting operation, and operator training.
OSHA to Hold Hearings Today on PPE and Employee Training
OSHA is inviting the public to participate in a public hearing on the agency’s proposal to clarify the remedies available for violations of its personal protective equipment (PPE) and employee training requirements. The hearing is scheduled for 10 a.m., Eastern time, on October 6 and 7 at the U.S. Department of Labor’s Frances Perkins Building in Washington.
On Aug. 19, 2008, OSHA published the proposal clarifying that when an OSHA standard requires an employer to provide PPE or training to employees, the employer must do so for each employee subject to the requirement, and that each employee not protected may be considered a violation for penalty purposes.
New Mold, Ventilation, and Indoor Air Quality Data Available From NIOSH
Three new NIOSH webpages with information on air quality have become available recently. The new webpages address the following topics:
This new webpage is a central repository of resources, targeting ways employers and employees can prevent construction-related falls.
OSHA to Hold Combustible Dust Explosion Seminars in Illinois
OSHA’s Chicago Region and the Illinois Safety Council (ISC) will be hosting combustible dust explosion inspection seminars on October 30 and November 20 in Naperville, Ill. The seminars will offer instructions on OSHA standards relating to combustible dust and best practices to protect employees against dust explosions. John Newquist, OSHA’s assistant regional administrator for cooperative and state programs, will be one of the featured speakers. The ISC has an alliance with OSHA’s area offices in Illinois.
Use of SCBA When Entering a Silo
If you must enter silos during the first four to six weeks after filling stops, or anytime the silo is full or partially full, wear a self-contained breathing apparatus (SCBA). A regular respirator or dust mask will not protect you in an oxygen-deficient atmosphere.
Trenching and Excavation Safety
Trenching and excavation work creates many hazards that can prove fatal to the employees doing the work. OSHA defines an excavation as any man-made cut, cavity, trench, or depression in the earth’s surface formed by earth removal. A trench is defined by OSHA as a narrow excavation that is deeper than it is wide, but no wider than 15 feet. OSHA also defines part of a bigger excavation as a trench if the distance from the edge of the excavation to an obstruction in the excavation, like a concrete form or basement wall, is 15 feet or less.
Cave-ins are perhaps the most dangerous trenching hazard and can be minimized or prevented by protective systems, such as shielding (trench boxes) or benching, sloping, and shoring. Other potential hazards exist including falls, falling loads, hazardous atmospheres, vehicular traffic, and operating equipment.
The following are some general trenching and excavation safety rules:
- Keep spoils and other surcharge loads at least 2 feet (0.6 meters) from edges.
- Keep mobile equipment away from edges; use signals, barricades, or stop logs.
- Locate underground utilities before excavating; approach them with caution.
- Test for hazardous atmospheres, low oxygen, flammability, and toxicity.
- Inspect trenches prior to the start of each shift and as needed throughout the shift.
- Inspect trenches following rainstorms and other hazard-increasing occurrences.
- Do not work under loads and stand clear of vehicles being loaded and unloaded.
- Position ladders no more than 25 feet from employees in trenches.
Oregon OSHA Adopts New Employee Involvement Rule
Oregon OSHA has revised a key rule to provide greater clarity and flexibility to employers seeking to involve their workers in discussions of health and safety on the job.
Previously, a stricter set of safety committee requirements applied to employers with more than 10 employees. Smaller employers also had to have a safety committee, regardless of size, if they were in a high-risk industry or if they had a high rate of claims requiring time off work, compared to their industry as a whole.
“For almost all small employers, that meant that a single disabling claim required
them to have a formal safety committee, even if they only had one-part time employee,” said Michael Wood, administrator of Oregon OSHA. “Small employers could slip in and out of the requirement depending on their claim history without any change in the way they did business—or in the risks their employees faced.”
Under the new rules, all employers will need either to have a safety committee or to use the less formal option of safety meetings to involve their employees in addressing jobsite safety. For those fixed-site employers who were administering safety committees in the past, the rule will have little effect. Construction employers, who typically were required to have safety committees under the previous rule, will have the option of using safety meetings. Even large construction companies can choose to rely upon the safety meeting model.
According to the Oregon Employment Department, small businesses employing 10 or fewer employees represent 80% of the state’s employers. These small employers, mobile employers, and companies with primarily office environments now have the option to hold safety meetings with a significant reduction in paperwork. The rule does not require employers in low-hazard industries using the safety meeting option to keep records of the meetings if everyone is present, although Oregon OSHA recommends it as a “best practice.”
“In order to effectively prevent injury and illness on the job, you need meaningful involvement by employees,” Wood said. “The rules before were confusing for small employers. This change not only provides greater clarity and increases flexibility, but we also believe it will promote more conversation about health and safety issues on the job. That has always been the purpose of the safety committee requirement.”
On Sept. 19, 2009, the rule will take effect for small employers (10 or fewer employees) not in construction. The rule change also eliminates the mandatory penalty of at least $100 for not having a safety committee.
Updated eTool for Healthcare Industry Helps Employees Avoid Injuries
"These new and updated modules are examples of the many resources developed through our Alliances that address common hazards in the healthcare industry," Assistant Secretary of Labor for OSHA Edwin G. Foulke Jr. said. "We will continue our mission of providing useful information to ensure employees remain safe and healthy while on the job."
Employees face many occupational safety and health hazards while working in a hospital. OSHA originally developed the Hospital eTool with modules describing common hazards and possible solutions for tasks performed in administration, central supply, clinical services, dietary, emergency, engineering, heliport operations, housekeeping, laboratories, laundry, pharmacy, the intensive care unit, and the surgical suite.
The sonography module provides guidance on how sonographers—medical professionals who use high-frequency ultrasound to create diagnostic images—can reduce their risk of musculoskeletal disorders. The surgical module now features updated information on bloodborne pathogens, waste anesthetic gases, laser safety, and other topics related to workplace safety and health in surgical suites.
OSHA Cites Pepsi-Cola and National Brand Beverage Ltd. for Exposing Employees to Machine Hazards
OSHA has cited Pepsi-Cola and National Brand Beverage Ltd. of Pennsauken, N.J. with $195,000 in proposed penalties for alleged workplace safety and health violations.
OSHA initiated its investigation on April 1 in response to a complaint alleging that employees were exposed to hazards when clearing jams on the machine used to stack and transport pallets.
As a result of the investigation, OSHA issued three willful citations that include:
- Failure to provide training on lockout/tagout procedures, which prevent the inadvertent start-up of machinery or the release of hazardous energy
- Failure to apply lockout/tagout procedures when machines were being serviced
- Failure to properly guard machinery
OSHA issues a willful violation when an employer exhibits plain indifference to or intentional disregard for the law.
“The machine hazards identified at this facility pose a serious safety threat to employees if left unabated,” said Gary Roskoski, director of OSHA’s Marlton, N.J., area office. “A proven way of ensuring future abatement of all serious hazards, compliance with OSHA regulations, and the prevention of employee injury, illness, and death is for Pepsi-Cola and National Brand Beverage Ltd. in Pennsauken to establish an effective safety and health management system.”
The company has 15 business days from receipt of its citations to contest them before the independent Occupational Safety and Health Review Commission. The inspection was conducted by OSHA’s Marlton Area Office; telephone 856-396-2594.
N.Y. Contractor Faces More Than $147,000 in OSHA Fines for Construction Safety Hazards
OSHA has cited Painting and Decorating Inc. of Ronkonkoma, N.Y., for 20 alleged willful, repeat, and serious violations of safety standards with $147,200 in proposed fines. The stucco and exterior/interior painting company was cited for failing to adequately protect its employees against falls and several other construction hazards at a King’s Point, N.Y. jobsite.
OSHA issued four willful, seven serious, and nine repeat citations for a variety of deficiencies including, but not limited to, failure to provide:
- Guardrails and/or fall protection while working on a scaffold
- Adequate planking
- A competent person to oversee the work
- Training for employees working on scaffolds
- Base plates
- An access ladder
- Fall protection for employees working 6 feet above a lower level
- Fall protection training to employees
- Failure to inspect scaffolds for defects
The willful violations address failure to fully plank the working platforms of the scaffold, use base plates, provide an access ladder, and provide guard rails on a scaffold. A willful citation is issued when the evidence shows either an intentional violation of the law or plain indifference to its requirements.
“Employees working at heights greater than 6 feet must be adequately protected against falls, which are one of the leading killers in construction work,” said Patricia Jones, OSHA’s area director for Long Island. “Employers must take seriously both this hazard and their responsibility to ensure that employees are well equipped to do their jobs safely.”
The serious violations address Painting and Decorating Inc.’s failure to: maintain a power tool in a safe condition, install a guard on a table saw, use equipment in accordance with instructions, maintain electric cords, lay platforms on scaffolds correctly when the scaffold changes direction, tie in a scaffold four or more tiers high, and have handrails on stairways. A serious citation is issued when death or serious physical harm is likely to result from a hazard about which the employer knew or should have known.
“One of the best means of ensuring a safe workplace is to establish an effective safety and health management system through which management and employees can work together to actively identify, analyze, and eliminate work-related hazards,” said Robert Kulick, OSHA’s regional administrator in New York.
Design and Display Inc. Fined More Than $70,000 for Safety Violations
Federal OSHA has cited a Middletown, N.Y., manufacturer of wire, sheet metal, and other types of displays for 28 alleged willful, serious, and other-than-serious violations of safety and health standards. Flanagan Design and Display Inc. faces $70,750 in proposed fines following OSHA inspections of its Midland Avenue production facility conducted in March and April of this year.
OSHA issued the company one willful citation, with a $33,000 proposed fine, for lack of required eye protection for employees operating power presses or performing cutting and grinding.
Twenty-four serious citations, carrying $34,750 in fines, were issued for:
- Missing or inadequate guarding of mechanical power presses and press brakes
- Uninspected power presses
- Ungrounded electrical equipment
- Lack of training for forklift operators
- Lack of a hearing conservation program
- Lack of a written respiratory protection and medical evaluation program
- Lack of a lockout/tagout program to prevent the unintended startup of machinery during maintenance
“These citations address a cross-section of health and safety hazards associated with manufacturing,” said Edward Jerome, OSHA’s area director in Albany, N.Y. “Left uncorrected, these hazards expose employees to potential lacerations, amputations, electrocution, hearing loss, crushing injuries, eye injuries, and being caught in the unexpected startup of machinery.”
OSHA also issued the company three other-than-serious citations, with $3,000 in fines, for failing to properly maintain illness and injury logs, and for lack of a hazard communication program and training. An “other-than-serious violation” is a hazardous condition that would probably not cause death or serious physical harm but would have an immediate relationship to the safety and health of employees.
“One of the best means of preventing serious workplace hazards and resulting penalties is to establish an effective safety and health management system through which management and employees can work together to actively identify, analyze, and eliminate work-related hazards,” Jerome said.
Congress Fails to Pass $10 Billion Health Bill for 9/11 Workers
The weekend of September 28, Congress opted not to fund a $10 billion bill that would include providing health care and compensation for Ground Zero workers. Congress’ decision may have been influenced by opposition against the bill from New York City’s Mayor Michael Bloomberg.
Mayor Bloomberg objected to a provision in the bill that would have required the city to pay 10% of the cost of a long-term program providing health care to those sick from working amid toxic World Trade Center debris in the wake of the Sept. 11, 2001, attacks. The total cost of the 10-year health program would have been $5.1 billion. New York City’s share was to be $500 million.
The bill also would have reopened the Sept. 11 Victim Compensation Fund with an estimated $6 billion for those who became sick after working amid the debris.
A new bill may be introduced next year, but supporters said there are no guarantees it will pass. Supporters had hoped to vote on the package over the weekend, but they ran out of time and support amid intense congressional negotiations over the $700 billion financial bailout package and the resistance from city officials.
Continuing the Fight Against Black Lung Disease
“It’s progressing faster than in the past,” said Dennis O’Dell of Fairmont, a former miner and administrator of health and safety for the United Mine Workers of America. “From 1995 until recently, we noticed that with miners with 10 years or less (experience in the field), black lung shows up at an alarming rate. It’s a problem that’s hard to get a handle on.”
Black lung, a serious disease that is treatable but not curable, is caused by exposure to coal dust, which destroys lung tissue. Its symptoms range from shortness of breath during exertion to, in its advanced stages, patients becoming invalids. The disease starves the body of oxygen and forces the heart to work harder, leading to heart attacks and early deaths.
Federal Coal Mine Health and Safety Act of 1969 mandates that coal dust in an underground mine should not exist in concentrations higher than 2 milligrams per cubic meter of air. That standard is stricter when the dust contains at least 5 percent silica.
The good news is that passage of the act led to a dramatic drop in black lung rates. Now, though, rates are rising again, and the disease appears to be striking miners at an earlier age than it has in the past.
Nationally, black lung killed nearly 15,000 people in the United States from 1990 to 1999, according to the National Institute for Occupational Health and Safety. The median age of death was 78.
Fines for safety violations, he noted, were doubled in 2006. It is hoped that better compliance with the law will be achieved by increasing the penalties for non-compliance.
Dr. Edward Petsonk of NIOSH would appreciate more data, including mandatory tests to detect black lung for employees and permission for researchers to monitor dust levels at various operations in the mines.
Some—including NIOSH and a 1996 congressional committee—have argued that the dust standard should be made more stringent. MSHA was on track to do just that until 2001, when President Bush took office.
MSHA’s refusal has prompted a lawsuit from the Appalachian Center for the Economy and the Environment, which wants it set at 1 milligram per cubic meter of air. The lawsuit is currently before the Sixth Circuit Court, where a judge in Cincinnati is weighing a request by MSHA to dismiss it.
If the lawsuit is dismissed, it would be a serious setback. The more we can learn about black lung and the ability to prevent it, the better for coal miners and, ultimately, the coal-mining industry that will continue to be a contributor to America’s energy future.
Pesticide Poisoning Surveillance Program Obtains Funding Support in North Carolina
In July 2008, legislation was passed in North Carolina that provided the NC Division of Public Health (NC DPH) with funds to continue surveillance of acute pesticide poisonings. Developments leading to this event began in May 2006 when the NC DPH concluded an investigation involving three migrant farm women who delivered babies with birth defects within several months of each other. All three women worked on the same farms in North Carolina and Florida in 2004.
The investigation determined that these women had likely experienced unacceptable levels of pesticide exposure, based on hours worked during restricted entry periods, and that one birth outcome was possibly due to pesticides. Consequently, in partnership with the North Carolina Agromedicine Institute/Southern Coastal Agromedicine Center at East Carolina University, NC DPH, along with federal partners (NIOSH/CDC and EPA), initiated efforts to highlight pesticides as an important issue needing more attention.
In February 2008, North Carolina Governor Mike Easley assembled the Governor’s Task Force on Preventing Agricultural Pesticide Exposure, which consisted of key government leaders in health and agriculture. Task force recommendations resulted in surveillance funding from North Carolina and new anti-retaliation and recordkeeping laws to help protect farmworkers.
Efforts to Prevent Work-Related Burn Injuries in Oregon
Work-related burn injuries are a priority area for NIOSH and the Oregon Worker Illness and Injury Prevention Program (OWIIPP). While the overall number of work-related burn injuries in Oregon has remained relatively constant, workers in certain industries (e.g., accommodations and food services, manufacturing), occupations (e.g., cooks), and populations (e.g., young workers) are disproportionately affected. Burns can be very serious and may result in thousands of dollars in healthcare costs and lost work days.
OWIIPP partners with NIOSH to prevent work-related burns in Oregon by tracking the number of burns that occur on-the-job and sharing data findings with partners and stakeholders throughout Oregon to increase awareness and promote prevention. Routinely, OWIIPP analyzed commercial insurance carrier data for burn injury claims. The findings are used to do targeted prevention among policy holders. The agency generated demographic data on the costs associated with hospitalized burn injuries to increase awareness of its financial burden.
Work-related burn injuries are preventable. Efforts to raise awareness and to develop prevention strategies for high-risk groups should be continued.
OSHA Awards $6.7 Million in Safety and Health Training Grants
“Education is the cornerstone for assuring safe and healthful work environments,” said Assistant Secretary of Labor for OSHA Edwin G. Foulke Jr. “The Susan Harwood grants will assist these organizations and academic institutions in educating employers and employees on ways to prevent safety and health hazards in the workplace.”
The Susan Harwood Training Grants support workplace safety and health training programs that educate employees in industries with high hazard and fatality rates, employees with limited English proficiency, hard-to-reach employees, and small business employers. The grants support training programs that address topics such as construction and general industry hazards, and other safety and health topic areas, including shipbreaking hazards and Native American tribal safety and health issues.
The training grants are named in honor of the late Susan Harwood, a former director of the Office of Risk Assessment in OSHA’s health standards directorate, who died in 1996. During her 17-year tenure with the agency, Harwood helped develop OSHA standards to protect employees exposed to bloodborne pathogens, cotton dust, benzene, formaldehyde, asbestos, and lead in construction.
Hurricane Recovery Webpage Features New Public Service Announcements
Heat stress is the focus of new public services announcements (PSAs) from Assistant Secretary Edwin G. Foulke Jr. posted to OSHA’s website to help protect employees from sun and heat hazards during cleanup and recovery operations along the Gulf Coast following Hurricanes Gustav and Ike.
OSHA Publishes Advanced Notice of Proposed Rulemaking on Tree Care Operations
OSHA is accepting public comments on an Advanced Notice of Proposed Rulemaking addressing tree care operations. The agency is requesting data, information, and comments on effective measures to control hazards and prevent injuries. Comments must be submitted by Dec. 17, 2008.
Pennsylvania Governor’s Occupational Safety and Health Conference
The 82nd Annual Governor’s Occupational Safety and Health Conference will be held Oct. 27–28, 2008, at the Hershey, Pa., Lodge and Convention Center. This event attracts nearly 1,000 participants and features more than 50 exhibitors. The conference will recognize outstanding employers by presenting them with the 2008 Governor’s Award for Safety Excellence, and will feature workshops and presentations designed to educate employers and employees on current workplace issues. Compliance Assistance Specialist Dale Glacken of OSHA’s Harrisburg, Pa., Area Office will host a workshop on evacuation hazards and safety measures, and John McFee of OSHA’s Philadelphia Regional Office will conduct a workshop on fall hazards at construction sites.
AIHA Will Ensure That Its Labs Can Register as CPSC Third-Party Labs
The American Industrial Hygiene Association (AIHA) has announced that it is working on an action plan to address Consumer Product Safety Commission (CPSC) requirements that were issued on September 22 for the accreditation of third-party conformity assessment bodies (laboratories) to test children’s products for lead content.
The CPSC will require laboratories that will test children’s products to demonstrate that the laboratories can follow recently-issued CPSC test methods for analyzing lead paint in children’s products and to become registered third-party laboratories through the CPSC.
AIHA is one of the largest international associations serving the needs of occupational and environmental health and safety (OEHS) professionals in industry, government, labor, academic institutions, and independent organizations. AIHA has been a leader in the area of laboratory accreditation since 1974. Under its Environmental Lead Laboratory Accreditation Program (ELLAP), AIHA has a formal agreement with the EPA to accredit laboratories performing analysis of lead in environmental samples including paint, soil, dust wipes, and air.
October is Breast Cancer Awareness Month
October is Breast Cancer Awareness Month and women should become informed about their risks of developing cancer and how effective screening for the disease is. Breast cancer is the most common type of cancer diagnosed in women regardless of race or ethnicity. Screening and early detection can help identify cancer in its early stages when the disease is most treatable.
According to the American Cancer Society, in 2008, it is estimated that 182,460 new cases of breast cancer will be diagnosed, and 40,500 will die from the disease—that’s just in the United States.
Three ways are used to screen for the disease:
- Mammogram—an x-ray of the breast is the best method to detect breast cancer early. Regular mammograms should begin at the age of 40 and be done every 1–2 years. Mammograms can lower the risk of dying from breast cancer by detecting cancer at an early, highly treatable stage.
- Clinical Breast Exam—an examination by a doctor or nurse to feel for lumps or other changes in the breasts. This should be used for women in their 20s and 30s.
- Breast self-exam—can be done by a woman on a monthly basis to self-check for change in the size and shape of the breast or under the arm. Beginning in their 20s, women should conduct monthly breast self exams.
Centers for Disease Control (CDC) statistics indicate that while mammogram and clinical breast exam rates rose during the 1990s, from 1999 to 2002, rates decreased by about 2%. The decrease in screening rates nationally may be attributed to a number of factors, including a shortage of breast-imaging facilities, shortages of key medical personnel, malpractice concerns, and financial constraints, according to the CDC. In addition, many women lack a primary health provider, are uninsured, or may be recent immigrants without access to health care.
The Kansas Department of Health and Environment (KDHE) promotes breast cancer screening for all women and provides services for age-appropriate, low-income, uninsured women through its Early Detection Works program. This program served about 6,000 women in 2007, providing clinical breast exams and mammograms through a network of providers across Kansas.
U.S. House Approves Breast Cancer Patient Protection Bill
The bill passed unanimously out of the Committee on Energy and Commerce on Sept. 17, 2008.
“Despite 10 years of objections from the insurance industry, today we passed legislation to ensure that breast cancer patients receive quality care and will not be forced to leave the hospital before it is medically safe to do so,” said Rep. John D. Dingell (D-MI), chairman of the Committee on Energy and Commerce and one of the bill’s original cosponsors. “Guaranteeing that treatment decisions are made by medical providers and the patients they treat is the cornerstone of good medical care and an important part of what makes H.R. 758 a critical bill.”
The legislation, which was originally introduced by Rep. Rosa DeLauro (D-CT), would require health insurers to cover minimum lengths of stay for patients undergoing procedures to treat and diagnose breast cancer. Specifically, insurers would be required to pay for hospital stays of at least 48 hours in the case of mastectomies and lumpectomies and 24 hours in the case of lymph node dissection for the treatment of breast cancer. The bill would also provide for secondary consultations and ensure that women have access to the most medically appropriate treatment.
“The House took action on an important public health measure to protect breast cancer patients,” said Frank Pallone Jr. (D-NJ), chairman of the Subcommittee on Health. “By passing the Breast Cancer Patient Protection Act, we are one step closer to providing better protection to women who suffer from breast cancer and putting an end to drive-through mastectomies.”
Boiler Recall Due to Fire Hazard
The U.S. Consumer Product Safety Commission, in cooperation with Viessmann Manufacturing Co. Inc., of Canada announced a voluntary recall of the following consumer product. If you have one of these boilers, you should stop using recalled products immediately unless otherwise instructed.
The recall involves the Vitodens 200 boiler. The gas-fired boilers are white, wall-mounted, and have “Viessmann” and “Vitodens 200” printed on the exterior in silver letters. The model number is located on the silver rating plate on the side of the boiler. Contact your certified HVAC contractor to open the boiler and locate the serial number on a white label on the side of the boiler, or under the bottom support panel. Vitodens 100 boilers are not included in this recall.
