OSHA Inspection: SCHLAGE LOCK, INC.

Issued

Jun 29, 1990

Abate by

Aug 15, 1990

Penalty

Initial $810 · Current $648 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
employer did not furnish employment and a place of employment which were
free from recognized hazards that were causing or likely to cause death
or serious physical harm to employees in that employees were exposed to
the hazard of oxygen deficient or toxic atmosphere from entry into
confined spaces:
a) Employees enter the Bag Houses' Air Ducts to remove the buildup
of grinding, polishing, and buffing waste materials twice per week.
These "Non-hazardous" and "Harzardous Bag Houses" contain toxic
air contaminants which include but are not limited to: Lead dust,
Copper dust, Iron Oxide dust, Arsine and Zinc Oxide dust at the
time "clean out" procedures occur.
Procedures established for confined space entry are inadequate in that:
1) Procedures had not been established nor implemented for situations
where the American Optical full-face respirator provided with
cartridges TC 21C 249/250 - TC 21C 417 would become clogged with
dust from the "clean out" procedure. These procedures would include
but are not limited to:
a) Determining appropriate respirator selection based on degree of
health hazard and frequency of occurence.
2) Employees entering the Bag Houses and Air Ducts to perform Bag House
cleaning operations and Air Duct cleaning operations were not
equipped with adequate safety/rescue equipment.
3) No emergency procedures were established for rescue operations from
confined spaces.
4) Standby personnel were not always accessible for communication
responsibilities required for adequate emergency/rescue procedures.
5) A training program was not established to effectively inform all
individuals who will perform the Bag House cleaning operations or
maybe assigned as standby or rescue persons on the following
criteria:
a) Specific hazards that may be encountered;
b) Safe work practrices and techniques.
Among other methods, one feasible and acceptable method to correct this
hazard is to implement and enforce a comprehensive confined space entry
program which would include the following elements:
1) Written procedures for work performed in dangerous atmospheres in
confined space including:
a) Procedures covering selections, use, limitations, and maintenance
of self-contained breathing apparatus or air-line respirator;
b) Procedures covering the use of 5-minute, emergency escape, self
contained breathing apparatus;
c) Procedures covering the use of oxygen concentration, toxic and
combustible gas monitors for atmosphere testing within confined
spaces;
d) A permit system for entry into confined spaces;
e) Rescue and training;
f) Procedures covering standby personnel with suitable rescue equipment;
g) Procedures covering the use of appropriate safety equipment such as
lifelines and body harnesses.
2) Training procedures for work performed in confined spaces including:
a) All personnel working in confined spaces shall be trained and
informed about any hazards (fire, explosive, asphyxiation) they may
encounter in connection with the work they are about to perform;
b) Rescue standby worker(s) shall be trained in rescue techniques,
first-aid, and resuscitation;
c) Personnel assigned to test confined space atmospheres shall be
trained in the proper use of gas detection equipment. Also, their
knowledge of testing methods and equipment use shall be periodically
tested.
3) Pre-entry procedures for confined spaces including:
a) Where applicable, the following atmosphere tests shall be performed
by a competent person prior to allowing employees to enter confined
spaces:
i) Oxygen deficiency test to detect levels of oxygen below 19.5%;
ii) Combustible gas test to detect the presence of combustible gases
and vapors;
iii) Toxic gas test to detect presence of toxic gases likely to be
encountered;
iv) Test equipment shall be calibrated pre- & post-entry.
b) All valves and switches connected with the operation of the confined
space shall be closed and locked to prevent accidental introduction
of contaminants on starting of equipment within the confined space;
c) Confined spaces shall be purged for as long as necessary to reduce
any contaminants to safe levels;
d) All sources of ignition shall be removed if flammable or combustible
materials are present or capable of being produced;
e) Personal protective clothing and equipment shall be provided as may
be necessary;
4) Confined space work procedures including:
a) Continuous ventialtion shall be provided during occupancy when a
contaminant is being continuously generated or an approved air-
supplied breathing apparatus shall be provided;
b) Personnel working in confined spaces shall be under observation
of or in communication with a competent standby rescue worker(s)
outside the hazardous location;
c) Personnel working in confined spaces shall be provided with a
rescue harness, safety belt or wrist harness, and a proper lifeline;
d) Personnel working in confined spaces shall be provided with an
air-supplied respirator or 5-minute, emergency-escape, self-contained
breathing apparatus;
e) Respirators, either supplied-air of self-contained, shall be
immediately available for use by the rescue worker(s). The
respirators shall be in a constant state of readiness;
f) Monitoring of the confined space during operations shall be conducted
periodically during work operations to ensure a safe working
environment.
g) The completion and posting of a confined space entry permit including
at a minimum, the following information:
i) Identity of permit space;
ii) Purpose of entry;
iii) Date of entry and authorized duration;
iv) Authorized entrants and persons in charge;
v) Eligible attendants/stand-by personnel;
vi) Signature of authorizing individual verifying that actions
and conditions necessary for safe entry have been performed.

Issued

Jun 29, 1990

Abate by

Jul 6, 1990

Penalty

Initial $540 · Current $432 Reduced

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Jul 6, 1990

Penalty

Initial $720 · Current $576 Reduced

Hazardous substances 07300260068518400230

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Penalty

Initial $540 · Current $432 Reduced

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Penalty

Initial $720 · Current $576 Reduced

Issued

Jun 29, 1990

Abate by

Jul 6, 1990

Hazardous substances 9010

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Hazardous substances 9010

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Hazardous substances 9010

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Hazardous substances 9010

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Penalty

Initial $720 · Current $576 Reduced

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Hazardous substances 0730Z102

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Penalty

Initial $720 · Current $576 Reduced

Hazardous substances 1520

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Hazardous substances 9010

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Penalty

Initial $720 · Current $576 Reduced

Hazardous substances Z102

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Penalty

Initial $720 · Current $576 Reduced

Hazardous substances 91309135

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Hazardous substances 9010

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Penalty

Initial $810 · Current $648 Reduced

Hazardous substances 1591

Issued

Jun 29, 1990

Abate by

Dec 31, 1990

Penalty

Initial $810

Hazardous substances 1591

Issued

Jun 29, 1990

Abate by

Jul 6, 1990

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Jul 6, 1990

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Penalty

Initial $720 · Current $576 Reduced

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Penalty

Initial $720 · Current $576 Reduced

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Penalty

Initial $720 · Current $576 Reduced

Issued

Jun 29, 1990

Abate by

Jul 16, 1990

Penalty

Initial $720 · Current $576 Reduced

Hazardous substances 1591

Issued

Jun 29, 1990

Abate by

Jul 3, 1990

Hazardous substances 1591

Issued

Jun 29, 1990

Abate by

Jul 30, 1990

Hazardous substances 1591

Issued

Jun 29, 1990

Abate by

Jul 6, 1990

Penalty

Initial $720 · Current $576 Reduced

Issued

Jun 29, 1990

Abate by

Jul 6, 1990

Issued

Jun 29, 1990

Abate by

Jul 3, 1990

Hazardous substances 1591