Compliance45
Worker Safety60
Inspector Confidence50
Cold Open — The Inspection
Inspection Start // 08:17 CST // Midland, TX

Inspector at the Gate

You are Jordan Ellis, EHS Manager at Crestline Industries. The HCS 2024 employer deadline for substances passed three weeks ago. An OSHA Compliance Officer just arrived at reception. The clock starts now.

OPS
ALERT — OSHA INSPECTION. Compliance Officer Rachel Solis, Region VI Dallas. Unannounced. Credentials verified, 08:17 local.
OPS
Program Status: 14 SDSs last updated Q3 2024 (pre-GHS Rev 7). 3 Crestline-made products still shipping with Rev 3 signal words. 23 of 41 warehouse staff overdue on HazCom retraining. Written program header still says "HCS 2012." Substance deadline passed Nov 20, 2026.
Jordan
Forty-five minutes of walkaround. I know the gaps. Question is what she finds first, and whether she frames us as distributor or manufacturer. We're both.
Solis
Good morning. I'd like to start with your SDS library and Blend Line 2, then training records, the written program, and the three products I believe you're shipping under outdated labels.
Live Feed // Compliance Dashboard

What You're Walking Into

Your in-house EHS dashboard is loading. Read each feed entry as it appears — these are the live gaps you're walking into the inspection with.

Decision 1 of 3 // Triage

Triage: Where Do You Start?

The inspector is ready to begin. Where do you take her first? Your choice determines the order of findings AND triggers a background action.

Activity // Document Redline

Rev 3 vs Rev 7 — CR-44 Hydrocarbon Solvent

Solis is reviewing Crestline's outbound SDS for CR-44 — the one we ship to customers. That's our manufacturer duty under 1910.1200(d). Click each cell on the RIGHT where the updated version differs from the current one. Flag 5 real changes. Submit when ready.

Flagged: 0 / 5 target · Click cells to flag differences

Current Crestline SDS (GHS Rev 3)
Required SDS (GHS Rev 7)
Section 2 — Hazard Identification
Flammable Liquid, Category 2 (Flash point 23–60°C)
Flammable Liquid, Category 1 (Flash point below 23°C, initial boiling point ≤35°C)
Section 2 — Signal Word
WARNING
DANGER
Section 7 — Handling and Storage
Store away from heat and ignition sources.
Store in a cool, well-ventilated place. Keep container tightly closed. Ground and bond container and receiving equipment. Use explosion-proof equipment.
Section 1 — Product Identifier
CR-44 Hydrocarbon Solvent — Industrial Grade
CR-44 Hydrocarbon Solvent — Industrial Grade
Section 14 — Transport Information
UN1268 Petroleum Distillates, Flammable Liquid, 3, PG II
UN1268 Petroleum Distillates, Flammable Liquid, 3, PG I
Section 16 — Other Information
Last revised: March 2024
Last revised: October 2026
Activity // Classification

Pictogram Matching — Crestline Product Line

Inspector Solis asks you to match each of the six Crestline products to the correct updated GHS pictogram(s). Some require more than one. Drag tiles onto each product. Labelling rules under 1910.1200(f) require the label to reflect current classification.

Pictogram Tray — Drag to Products
🔥Flame
❗Exclamation
☣Health Hazard
⚗Corrosion
⚫Gas Cylinder
☠Skull (Distractor)

Tiles are reusable — click a placed tile to remove it.

Activity // Timed Response

Spill — Blend Line 2

Response Window 15

Choices vanish when the timer hits zero.

Decision 2 of 3 // Corrective Action

Label Correction Approach

Solis
Three of your product labels — CR-44, CR-61, CR-78 — carry GHS Rev 3 signal words. You manufacture these. Every customer you've shipped to in the last 18 months has the old labels. I'd like to hear your corrective action plan before I finalise inspection notes.

Inspector Solis has confirmed that three product labels are non-compliant. Because Crestline manufactures these, the defect is on outbound shipments too. What's your play?

Activity // Calibration

Inspector's Question Round

Inspector Solis has four direct HazCom questions. For each: select your answer, then rate your confidence 1–5. Your confidence vs accuracy is shown in the debrief. HCS 2024 reference.

Activity // Document Audit

Training Record Audit

Inspector Solis is reviewing your training records. This document has 4 compliance errors. Click any value that is wrong before she reaches the end of the page. 1910.1200(h)(3) sets the topic requirements.

Errors flagged: 0 / 4 target

HazCom Training Record — Crestline Industries
Training Date
February 14, 2024
GHS Revision covered
GHS Revision 3 (UN, 3rd revised edition)
Topics covered
How to read an SDS; where to find SDSs; what to do if exposed to a hazardous chemical
Chemicals covered
General HazCom overview — all chemicals used at facility
Trainer name
J. Ellis, EHS Manager
Number of employees trained
41 employees
Retraining trigger
Next scheduled training: February 2025 (annual cycle)
Decision 3 of 3 // Abatement Timeline

Timeline Commitment

Solis
I've identified four citation categories: SDS non-compliance — received and Crestline-shipped. Labelling violations on your own products. Training record deficiencies. Written program deficiencies. Propose your abatement timeline. What you commit to becomes the formal abatement period — failure to meet it triggers per-day penalties at $16,550 per violation per day.

Your commitment becomes a binding abatement clock. Pick the timeline that matches what you can actually deliver.

Citation Summary // Inspection #DAL-2026-08841

Citations Issued

OPS
OSHA Citation Summary — Crestline Industries, Inspection #DAL-2026-08841
OPS
Serious violation: 29 CFR 1910.1200(g) — SDS non-compliance, 14 received documents + 3 outbound. Proposed penalty: $12,400.
OPS
Serious violation: 29 CFR 1910.1200(f) — Label deficiencies on 3 Crestline-manufactured products. Proposed penalty: $9,200.
OPS
Other-than-serious: 29 CFR 1910.1200(h) — Training record deficiencies (23 employees expired + 6 language-effectiveness concern). Proposed penalty: $5,600.
OPS
Other-than-serious: 29 CFR 1910.1200(e) — Written program references HCS 2012; multi-employer section inadequate. Proposed penalty: $3,200.
Jordan
Total exposure: $30,400. It could have been much worse. If the spill response had gone wrong, or if she'd found QC Lab sample jars before Mike did, we'd be looking at willful violation territory — one willful alone is $165,514.
Outcome // Cooperative Inspection Closed

Inspection Closed — Cooperative Outcome

0

Inspector Solis notes "cooperative employer with initiated on-site corrective action." The citation package stays at $30,400 or less, with aggressive abatement. Your proactive disclosure changed the character of the inspection.

Outcome // Citations Issued — Abatement Period Active

Citations Issued — Partial Compliance

0

You carry the citation risk for the abatement period. Per-day penalties loom at $16,550 per violation per day if the standard timeline slips. You did the work — and still have a month of exposure.

Module complete. Continue when you're ready.
Outcome // Formal Investigation — Willful Exposure

Formal Investigation — Multiple Violations

0

Inspector Solis records "contested findings." The inspection is no longer cooperative. Willful-violation analysis is underway. A single willful is $165,514 — and more than one is on the table.