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You are the safety manager for ACE specialty contractor providing Hydro-Blast services for Big Dog Construction, a general contractor at Specialty Chemicals plant. ACE Hydro-Blast has been awarded the contract to remove and clean two heat exchangers. Specialty Chemicals has performed this task numerous times over the years. Specialty Chemicals has provided an MSDS for the residue and a lift plan for removal of the tubes, but no other information. The exchangers have tube bundles that require the inserting of high pressure 4' wands directed into each tube for cleaning which are provided by Specialty Chemicals. ACE Hydro-Blast has no experience with this type of configuration or the wands. Several of your employees have been injured, and one has filed a complaint with OSHA. OSHA has determined there are several serious violations of the standards and will issue citations for training, PPE, and the General Duty Clause.

Describe the possible issues with Multi-Employer Worksite Policy. How will OSHA assess the citations? Big Dog Construction and Specialty Chemicals would be subject to what, if any, citations? Why?

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