OSHRC Docket No. 13801

Occupational Safety and Health Review Commission

January 6, 1977


Before BARNAKO, Chairman, MORAN and CLEARY, Commissioners.  


Baruch A. Fellner, Office of the Solicitor, USDOL

Marshall H. Harris, Reg. Sol., USDOL

J. Stephen Buis, for the employer



This case is before the Commission pursuant to a sua sponte order for review.   The parties have filed no objections to the Administrative Law Judge's decision, either by way of petitions for discretionary review or response to the order for review.   Accordingly, there has been no appeal to the Commission, and no party has otherwise expressed dissatisfaction with the Administrative Law Judge's decision.

In these circumstances, the Commission declines to pass upon, modify or change the Judge's decision in the absence of compelling public interest.   Abbott-Sommer, Inc., 3 BNA OSHC 2032, 1975-76 CCH OSHD para. 20,428 (No. 9507, 1976); Crane Co., 4 BNA OSHC 1015, 1975-76 CCH OSHD para. 20,508 (No. 3336, 1976); see also Keystone Roofing Co., Inc., v. O.S.H.R.C., 539 F.2d 960, 964 (3d Cir. 1976). The order for review in this case describes no compelling public interest issue.

The Judge's decision is accorded the significance of an unreviewed Judge's decision.    [*2]   Leone Constr. Co., 3 BNA OSHC 1979, 1975-76 CCH OSHD para. 20,387 (No. 4090, 1976).

It is ORDERED that the decision be affirmed.  



MORAN, Commissioner, Concurring:

In view of respondent's objections to a "substantive" review of Judge Brennan's decision, I agree with the affirmance of his decision which is attached hereto as Appendix A.

For the reasons expressed in my separate opinion in Secretary v. Schultz Roof Truss, Inc., OSAHRC Docket No. 14046, December 20, 1976, I disagree with my colleague's views regarding the significance of decisions rendered by Review Commission Judges.


Marshall H. Harris, Regional Solicitor and Howard K. Agran, U.S. Dept. of Labor, for the Secretary of Labor

J. Stephen Buis, for the Respondent

Brennan, W. E.; A.L.J.

This action arises under the provisions of Section 10(c) of the Occupational Safety and Health Act of 1970, 29 U.S.C. 659(c) (hereinafter the Act), to review Citations and proposed penalties issued pursuant to Sections 9(a) and 10(a) of the Act, 29 U.S.C. 658(a) and 659(a) by the Secretary of Labor through the Area Director of the Occupational Safety and Health Administration for Richmond, Virginia, (hereinafter Complainant),   [*3]   to Union Steel Erectors, Inc., of Chester, Virginia, (hereinafter Respondent), following an inspection of a building construction site at Ninth and Marshall Streets, Richmond, Virginia, (hereinafter worksite).

On May 21, 1975, Mr. William J. Duensing, a duly authorized Compliance Safety and Health Officer (CSHO) of Complainant's Richmond, Virginia office, conducted an inspection of Respondent's worksite.

As a result of this inspection, Respondent was issued on June 2, 1975, a Citation for Nonserious Violations (5 Items), two Citations for Serious Violations and a Citation for Willful Violation of 29 U.S.C. 654(a)(2) together with a Notification proposing a total of $7,405 in penalties for the alleged violations (R. pp. 1, 2). n1

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n1 An Amended Notification of Proposed Penalties was issued on June 10, 1975, which reduced the total penalties proposed to $6,990 (R. p. 2A).

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Through a letter dated June 18, 1975, from its counsel, Respondent noted its contest to the Citations and proposed penalties (R. p. 3).

After a   [*4]   Complaint and Answer thereto were filed, and pursuant to prior written notice (R. p. J-2) this matter came on for trial at Richmond, Virginia, both parties appearing through counsel.   No affected employees or representatives thereof desired party status (TR. 3).   Post-trial briefs were filed by both parties.

Having considered the entire record herein, the testimony and demeanor of the witnesses, the exhibits, stipulations, representations, admissions and arguments of the parties, it is concluded that the substantial, reliable and probative evidence of this record considered as a whole supports the following findings of fact and conclusions of law.

The following matters were stipulated to at the outset of the trial.   Respondent is a Virginia Corporation with its principal office located in Chester, Virginia.   At the times relevant herein, it was engaged in a business affecting commerce.   No injuries are associated with this case.   The American Crane, a self-propelled, mobile truck crane involved in this case, was owned and operated by Respondent herein.   Respondent had previously received a Citation for Serious Violation of the Act at another worksite which was affirmed.   (Tr. 4-9).   [*5]  

Based upon these stipulated facts it is concluded that Respondent is an employer engaged in a business affecting commerce who has employees, within the meaning of Sections 3(3), 3(5) and 3(6) of the Act, 29 U.S.C. 652(3), (5) and (6), and that the Act applies to the worksite involved herein, within the meaning of Section 4(a) of the Act, 29 U.S.C. 653(a).   Upon the filing of Respondent's Notice of Contest herein, the Review Commission has jurisdiction in this matter pursuant to Section 10(c) of the Act, 29 U.S.C. 659(c).

The Citations and Occupational Safety and Health Standards cited therein, provide as follows:


Description of Alleged Violation

Item No. 1

Citation No. 1 - Nonserious


The open sided floor at the north side

of the first floor which was more than

6 feet above the entrance to the base-

ment level, was not guarded by a stan-

dard railing and toeboard.

Item No. 2


A floor opening, designated as stairway

#5 did not have a standard railing on the

east side where there was a drop of more

than 10 feet.

Item No. 3

Chapter 5-2,

Crane inspection records for American

Sections 1.5 & 3.1,

Crane were not kept where readily avail-

American National Standards

able as follows:

B 30.5-968 as Adopted by

a) written, dated and signed inspection


reports and records made monthly on

critical items in use, such as brakes,

hooks, and ropes.

b) dated and detailed records

reflecting a preventative

maintenance program based on

manufacturer's recommendations.

Item No. 4


A record of the dates and results of

thorough annual inspection of the

American Crane was not available.

Item No. 5


Tag lines were not used to control loads

during structual steel assembly.


Immediate abatement was ordered for Item No. 1; by June 4, 1975, for Items numbered 2, 3, 4; and June 6, 1975 for Item No. 5.   No penalties were proposed for Items numbered 1 and 2; $40 for each of Items numbered 3 and 4 and $110 for Item No. 5.

Item No. 1

29 C.F.R. 1926.500(d)(1)

(d) Guarding of open-sided floors, platforms, and runways

(1) Every opensided floor or platform 6 feet or more above adjacent floor or ground level shall be guarded by a standard railing, or the equivalent, as specified in paragraph (f)(1) of this section, on all open sides, except where there is entrance to a ramp, stairway, or fixed ladder.   The railing shall be provided with a standard toeboard wherever, beneath the open sides, persons can pass, or there is moving machinery, or there is equipment with which falling materials could create a hazard.

Item No. 2

29 C.F.R. 1926.500(b)(1)

(b) Guarding of floor openings and floor holes

(1) Floor openings shall be guarded by a standard railing and toe boards or cover, as specified in paragraph (f) of this section.   In general, the railing shall be provided on all exposed sides, except at entrances to stairways.

Item No. 3

29 C.F.R.   [*7]    1926.550(b)(2)

(2) All crawler, truck, or locomotive cranes in use shall meet the applicable requirements for design, inspection, construction, testing, maintenance and operation as prescribed in the ANSI B30.5-1968, Safety Code for Crawler, Locomotive and Truck Cranes.

American National Standards

B30.5, 5-2.1.5 Written, dated and signed inspection reports and records shall be made monthly on critical items in use such as brakes, crane hooks, and ropes.

B30.5, 5-2.3.1 A preventative maintenance program based on the crane manufacturer's recommendations shall be established.   Dated and detailed records shall be readily available.

Item No. 4

29 C.F.R. 1926.550(a)(6)

(6) A thorough, annual inspection of the hoisting machinery shall be made by a competent person, or by a government or private agency recognized by the U.S. Department of Labor.   The employer shall maintain a record of the dates and results of inspections for each hoisting machine and piece of equipment.

Item No. 5

29 C.F.R. 1926.751(d)

(d) Tag lines shall be used for controlling loads.

Citation No. 2 - Serious

1926.28(a) and

The employer failed to require wear-


ing of appropriate personal protective

equipment or to provide safety nets

at a workplace more than 25 feet above

the ground where employees are exposed

to the hazard of falling.


Abatement was ordered completed by June 10, 1975, and a $850 penalty was proposed.

29 C.F.R. 1926.28(a)

(a) The employer is responsible for requiring the wearing of appropriate personal protective equipment in all operations where there is an exposure to hazardous conditions or where this part indicates the need for using such equipment to reduce the hazards to the employees.

29 C.F.R. 1926.105(a)

(a) Safety nets shall be provided when workplaces are more than 25 feet above the ground or water surface, or other surfaces where the use of ladders, scaffolds, catch platforms, temporary floors, safety lines, or safety belts is impractical.

Citation No. 3 - Serious


A tight and substantial floor was not

maintained within at least 2 stories

or 30 feet, which ever is less, below

and directly under that portion of each

tier of beams on which any work was being



Immediate abatement was ordered and a $850 penalty was proposed.

29 C.F.R. 1926.750(b)(2)(i)

(i) Where skeleton steel erection is being done, a tightly planked and substantial floor shall be maintained within two stories or 30 feet, whichever is less, below and directly under [*9]   that portion of each tier of beams on which any work is being performed, except when gathering and stacking temporary floor planks on a lower floor, in preparation for transferring such planks for use on an upper floor. Where such a floor is not practicable, paragraph (b)(1)(ii) of this section applies.

Citation No. 4 - Willful

Chapter 5.3

The employer permitted the crane operator

Section 2.3(e)

to hoist, swing and lower a load between

American National

the ground and roof while employees were

Standards B 30.5-1968

on the load, exposing the employees to

as Adopted by 1926.550(b)(2)

the hazard of a fall of as much as 55 ft.


Immediate abatement was ordered and a $5,100 penalty proposed.

29 C.F.R. 1926.550(b)(2)

(2) All crawler, truck, or locomotive cranes in use shall meet the applicable requirements for design, inspection, construction, testing, maintenance and operation as prescribed in the ANSI B30.5-1968, Safety Code for Crawler, Locomotive and Truck Cranes.

American National Standard

Chapter 5.3 - Section 2.3(e)

The operator shall not hoist, lower, swing or travel while anyone is on the load or hook.

The evidence of record reveals that Respondent, at [*10]   all time material herein, was engaged in erecting the structural steel skeleton of the new Marshall Courts Building loated at Ninth and Marshall Streets in Richmond, Virginia.   This construction site was across the street from the Richmond area office of the Occupational Safety and Health Administration, and because of this close proximity, was used as a training tool to acquaint newer OSHA employees with construction methods.   On May 21, 1975, CSHO Duensing, while observing this construction site from the area office with newer compliance officers Galloway and Benson, observed workers riding the hook and headache ball of a crane high above the building under construction.   Officer Galloway took Polaroid photographs of the two men riding the hook and ball as well as photographs of two men riding on a load of steel decking being hoisted by the same crane, somewhat later on (Exh. C-1, C-2, C-3, C-4, C-5, C-6). n2

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n2 At the trial herein, Respondent moved for the exclusion of these photographs on the ground that they were taken before any inspection began from the "non-public" OSHA office (TR. 21-25).   This motion was denied, which ruling is hereby affirmed.   The subject matter of these photographs, workers riding high above the building under construction on the hook and ball of the crane, and on a load being hoisted by this crane, were open to public view.   See: Secretary of Labor v. Accu-Namics, Inc., 8 OSAHRC 890, (May 30, 1974) and cases cited therein, affirmed sub nom, Accu-Namics v. OSAHRC, et al., 515 F2d 828 (CA 5, 1975).


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These photographes were immediately shown to the area director, who ordered an inspection of this worksite forthwith in view of the imminent danger to the workers riding the crane and hoisted load.

Officer Duensing, accompanied by officers Galloway and Benson, did then go to this worksite and conducted an inspection which resulted in the Citations and proposed penalties here at issue.

When officer Duensing informed Respondent's foreman, Mr. Robert Belcher, Jr., that the inspection was occasioned by observing workers riding the crane hook, ball, and hoisted loads, Mr. Belcher replied, "Where have you been all week?" (TR 34).   In explanation, Mr. Belcher advised that his ironworkers had been lifted by the crane for a period of a week prior to the inspection, but that no one was doing it anymore.   The two workers who had been photographed riding the hook and ball of the crane were identified as Respondent's employees Whedbee and Martin.   Foreman Belcher knowingly permitted Respondent's employees to be lifted by Respondent's crane for the period of a week before the May 21 inspection. He never instructed [*12]   either the crane operator, Respondent's longtime employee Grubb, or any other of his employees not to ride either the crane hook or ball, or loads being hoisted by this crane. Both Mr. Belcher and Respondent's other employees knew that the OSHA area office was across the street from this construction site.

Mr. Robert Miller, the Project Superintendent for the general contractor of this job, J.A. Jones Construction Co., testified that he was aware that ironworkers were riding the hook and ball of Respondent's crane to the top of this three-storied building and above the roof level, which was some fifty feet above ground level.   Further, that on one or two occasions he had told Respondent's Foreman, Belcher, that this practice "was a violation of safety regulations" (TR 80, 87), that the OSHA area office was across the street from this worksite and asked Mr. Belcher not to allow his men to do this (TR. 78-89).

Further, Respondent's crane operator, Grubb, testified that he had been aware for years that the law prohibited workers from riding the crane hook and ball, or loads being hoisted (TR. 209).   Despite this knowledge, however, he admitted that on this jobsite the general vertical [*13]   movement of Respondent's employees to various elevations on the building being constructed was by riding this crane (TR. 212-213).

When Respondent's employees rode the crane hook or ball, or load, they hung on to the cable with their hands with their feet on the ball or hook. No means were employed to protect these employees from falling.

All the vertical steel members on the first floor level, and the perimeter vertical members on the second and third floors were encased with steel tubes.   From 75 to 100 such tubes were installed by Respondent, and its employees rode the crane ball or hook in each of these installations.   Respondent's employees rode on the steel beams during the installation thereof.

At the close of the evidence, Complainant orally moved to amend the "Description" of the alleged "Willful" Citation to include the allegation that Respondent permitted its employees to ride the hook and ball of its crane at this jobsite, a practice prohibited by the American National Standard originally cited.   This motion was denied (TR. 215-218).   This ruling is reversed herein, and Complainant's motion is granted.   The issue of whether Respondent's employees did ride the crane [*14]   hook and ball, as well as hoisted loads, was fully litigated by the parties and pursuant to the provisions of Federal Rule of Civil Procedure 15(b), made applicable to these proceedings by Commission Rule 2(b), 29 C.F.R. 2200.2(b), the motion to amend is granted.

The Willful Violation set forth in Citation No. 4 is fully established by the evidence of this record, and is therefore affirmed.

Under any of the various extant tests for establishing a Willful Violation, n3 Respondent herein did, knowingly, consciously, intentionally, deliberately and voluntarily violate the Act by permitting its employees to ride the hook and ball of its crane and loads being hoisted by said crane. Furthermore, this Willful Violation was a Serious Violation in that a fall from the crane's hook, ball or loads being hoisted, a distance at times of from 50 to 70 feet to the ground or onto previously erected steel beams, could result in death or serious physical harm.   29 U.S.C. 666(j).

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n3 See: F.X. Messina Construction Corp. v. OSHRC, et al., 505 F2d 701 CA 1, 1974)

Frank Irey, Jr., Inc. v. OSHRC, et al., 519 F2d 1200 (CA 3, 1974) Intercounty Construction Co. v. OSHRC, 522 F2d 777, (CA 4, 1975)


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As to Citation No. 3, alleging a Serious Violation of the Standard set forth at 29 C.F.R. 1926.750(b)(2)(i), this Standard provides that where skeleton steel erection is being done, a tightly planked and substantial floor shall be maintained within two stories or 30 feet, whichever is less, below and directly under that portion of each tier of beams on which any work is being performed.

The evidence reveals that connecting operations, that is the initial placement of steel beams and connection thereof with a small number of bolts, were being carried on by two of Respondent's connectors on the north side of the Marshall Court Building at the third floor and roof levels.   The only solid surface below these connectors a concrete floor, 51 feet below them.   No temporary floors of a tight and substantial nature had been placed not more than 30 feet below them, nor were they using any other personal protective equipment to protect them against a fall.   It is generally recognized in the steel erection trade that it is not feasible to have connectors tie off to already erected steel beams because the connecting [*16]   operation is a relatively brief operation and the connectors thus move about quite frequently.   The connecting task is of brief duration.   Further, safety nets are not considered feasible on jobs such as the one here involved because of the danger of connectors striking intervening steel beams when falling toward a net, or the lack of adequate room to allow the net to properly stretch if a connector does fall into one.   Thus, the only protection provided connectors under the Standards is the erection of temporary floors under them so that no fall would be for a distance greater than 30 feet.

Respondent argues here that the installation of the building's decking was the responsibility of another subcontractor, who had fallen behind the pace of the steel erection. Further, Respondent was under pressure to complete its phase of steel erection and the placement of temporary floors would have been expensive and time consuming.

These arguments are not persuasive nor do they justify the clear violation of the cited Standard.   The evidence does not establish that the erection of temporary floors or platforms under the connectors was impossible or not feasible.   Respondent should have erected [*17]   such floors or platforms or had its connectors wait until the decking subcontractor installed decking not more than 30 feet below them.   The evidence establishes the violation as charged in Citation for Serious Violation No. 3.

Citation No. 2 charging a Serious Violation of the Standards set forth at 29 C.F.R. 1926.28(a) and 1926.105(a), involves six of Respondent's "bolters" who were observed working on the third and fourth levels at the south end of this building, who were exposed to the hazard of falling from 17 to 51 feet to metal decking or concrete surfaces below them.   The bolting operation follows the initial connection operation.   Bolters are steel erection workers who accomplish the final alignment and complete the bolting together of the structural steel beams. This job varies in the length of time required to accomplish it, depending upon the accuracy of alignment of the beams, which may need adjustments and the number of bolts to be finally and permanently installed.   The required time may vary from several minutes to up to an hour per beam.

Respondent's bolters were observed performing this bolting operation without benefit of any personal protective equipment in   [*18]   excess of 25 feet above adjacent surfaces and without safety nets below them (Exh. C-7).

Although Respondent's bolters were wearing tool belts, identified as "American Bridge quick release belts" (TR. 150), reportedly capable of supporting a man by the short lanyard or "pig tail" affixed thereto, the evidence conclusively establishes that none of these bolters tied off these lanyards to any support, i.e., around a beam, and thus no effective personal protective measures were followed.   The violation as alleged has been established.   Respondent's argument that to tie off during the bolting operation might be hazardous because the bolter may forget he is tied off and be jerked off his feet when he goes to leave a given spot, is not persuasive nor does it constitute a defense to this violation.   Adequate training of the bolters and supervised compliance with the cited Standard will result in correcting dangerous work practices and afford protection to this class of employees mandated by the Act and cited Standards.

As to the Citation for Nonserious Violations, Items numbered 1 and 2 are concerned with the first floor of this building, some 19 to 20 feet above the basement floor. On [*19]   the north side of this building there was located a set of stairs by which Respondent's employees gained access to the building.   Immediately adjacent and to the right of these stairs there was an opening in the first floor below which was a ramp leading from ground level down into the basement level.   For several days there was no guardrail or other perimeter protection along the side of this opening which Respondent's employees passed in gaining access to the interior of the building.   These employees at times passed within two feet of the unguarded edge of this opening. Exhibit C-8 is a diagram of the first floor level showing the path of employee travel, the dotted line, by the side of this unguarded floor opening (Item No. 1).   Within the interior of this building there was an unguarded opening in the first floor level, designated as Stairway No. 5.   This Opening measured approximately 8 feet by 12 feet and was about 20 feet above the basement floor below.   Respondent's employees walked within a few feet of this unguarded floor opening in their path of travel to a ladder leading to the second floor level (Exh. C-8), Item No. 2.

Items numbered 3 and 4 of this Citation involve [*20]   Respondent's crane at this worksite. It is not contested that this American Crane was owned and operated by Respondent, and that no written records of any description covering any time period were kept concerning any inspections or maintenance work performed on the crane.

Item No. 5 of this Citation involves the failure of Respondent to use "tag lines," i.e., lengths of rope, to control loads of material being off-loaded from delivering trucks and during the hoisting of steel beams for assembly.   The evidence is not in dispute that no tag lines were used during either operation.   Respondent's crane operator for 25 years readily admitted that he has hoisted loads of steel without using tag lines "all [his] life.", believing the use of such lines to be more dangerous than non use (TR. 197).   Such a practice is clearly violative of the cited Standard and Respondent's argument is neither persuasive nor a defense to this violation.

Thus, the credible evidence of record clearly establishes all five violations set forth in this Citation for Nonserious Violations.

There remains for determination the appropriateness of the proposed penalties.

Area Director Ewing testified at length concerning [*21]   the considerations given to those penalty criteria mandated by Section 17(j) of the Act, 29 U.S.C. 666(i), (TR. 105-120, Exhs. C-10, C-11, C-12).   With respect to Respondent's size, Mr. Belcher, Sr., its President, sole stockholder and chief official testified that Respondent employed from 35 to 40 employees as an average in 1974, although it had only 12 employees on the jobsite in question when inspected (TR. 61).   From gross revenues of about one million dollars last year, the corporation netted about a $50,000 income (TR. 189-190).   Mr. Belcher claimed to have lost about $14,000 on the construction job in question, and although the Respondent corporation is not on the "verge of bankruptcy," it is "awfully short on funds" (TR. 183).

As to respondent's good faith, the uncontradicted evidence establishes that Respondent had no formal safety program, no formal employee training program and no employee involvement in any safety program (TR. 118).   Further, the work practices of this Respondent established by the Willful and Serious Violations which were observed when inspected clearly show a lack of Respondent's involvement in or dedication to employee safety.   No consideration for [*22]   good faith is permissible on this record.

As to prior history, the record reveals that Respondent had previously received a Citation for Serious Violation of the Act, which has become a final order prior to the inspection herein. n4

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n4 Area Director Ewing testified to a rather vague recollection of an additional prior Citation for Nonserious Violation (TR. 118, 119).   It is suggested that accurate penalty computation would be facilitated if the Complainant introduced copies of prior Citations as Exhibits in these proceedings.   This was not done in this case.

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As to the gravity of the violations, in my view all violations herein found to have existed have been accurately characterized under the Act.   The possibility of death or serious physical harm resulting from the violations set forth in both Citations for Serious Violation, is in the medium range in view of the fact that Respondent's bolters and connectors were all experienced in their trade.   Further the number of these employees was relatively small, two connectors [*23]   and six bolters. The danger to which the employees riding the hook and ball of Respondent's crane, or loads lifted by this crane, on the other hand, was high.   There is no question that a fall from 50 to 70 feet to either steel beams or the ground below will result in death or serious bodily harm.   The evidence further reveals that most, if not all, of Respondent's ironworkers were lifted about this construction site by this means.   No measures to protect such employees from falling were taken.

Based upon an independent consideration of the provisions of Section 17(j) of the Act, 29 U.S.C. 666(i), it is concluded that all penalties proposed for the Nonserious Violations are appropriate.   The penalties proposed for each of the two Serious Violations should be reduced to $500 each, and the penalty proposed for the Willful Violation should be reduced to $3,000.   These reductions are based primarily upon Respondent's relative small size and financial condition.

Based upon the foregoing findings and conclusions and pursuant to the provisions of Sections 10(c) and 12(j) of the Act, 29 U.S.C. 549(c) and 661(i), it is hereby,


1.   All Citations herein are AFFIRMED.   [*24]  

2.   The following civil penalties, based upon the violations herein found to have existed, are ASSESSED

Citation for Nonserious Violations

Item No. 1 - 0 -

Item No. 3 - $40

Item No. 2 - 0 -

Item No. 4 - $40

Item No. 5 - $110


Citation No. 2

Serious Violation - $500

Citation No. 3

Serious Violation - $500

Citation No. 4

Willful Violation - $3,000

Total penalty $4,190



March 17, 1970

Hyattsville, Maryland