OSHA Inspection: WATSON, INC.

Issued

Aug 1, 1994

Abate by

Nov 29, 1994

Penalty

Initial $875 · Current $525 Reduced

Hazardous substances H130

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of
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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:
a.Painter was exposed to the hazards of skin and
respiratory allergic sensitization which are associated
with excessive levels of 1,6-Hexamethylene diisocyanate
homopolymer, a HDI polyisocyanate, in a spray painting
operation.  Employee was exposed to HDI polyisocyanates
at short term intervals which exceeded the recommended
guideline for a 15 minute short term exposure limit
(STEL) established as 1.0 mg/m3.  These exposures were
derived from 4 of 8 samples collected over an 125
minute period.  Employee was exposed to STEL levels of
4.1 mg/m3 over a 16 minute period, 3.1 mg/m3 over a 19
minute period, 5.6 mg/m3 over a 15 minute period, and
1.4 mg/m3 over a 13 minute period.
Feasible and useful abatement methods for reducing or eliminating
this hazard, among other methods are:
1.Substitution with paint systems which do not contain
diisocyanates.
2.Design and build a paint spray booth/room.
3.Modify the existing area to increase ventilation.
Investigate the possibility of lowering the existing
fan along the southeast wall and add an additional fan
along the northeast wall.  This might require adding a
new exit door on the north wall of the spray area.
Consideration should be given to ignition sources at
the point of exhaust if the fans are lowered.
Installation of a false ceiling above the track of the
overhead crane could also reduce the volume of air to
evacuate and result in increased air flow.  If this
approach is taken, consideration should be given to
installing partitions to isolate any light fixtures in
the false ceiling and the overhead crane should be
moved out of the area during painting activities.
3.Use of a different paint application system to reduce
the amount of overspray generated.
Abatement Schedule
Step 1 - Effective respiratory protection shall be provided by
09/29/94 and used by exposed employees as an interim protective
measure until feasible engineering and/or administrative controls
can be implemented or whenever such controls fail to reduce
employee exposure to within permissible exposure limits.
Step 2 - A written detailed plan of abatement shall be submitted
to the Area Director by 10/28/94 outlining a schedule for the
implementation of engineering and/or administrative measures to
control employee exposures to hazardous substances as referenced
in this citation.  This plan shall include, at a minimum, target
dates for the following actions which must be consistent with the
dates required by this citation:
(1)Evaluation of engineering/administrative control
options;
(2)Selection of optimum control method and completion of
design;
(3)Procurement, installation and operation of selected
control measures;
(4)Testing and acceptance or modification/redesign of
controls;
All proposed control measures shall be approved for each
particular use by a competent industrial hygienist or other
technically qualified person. 30-day progress reports are
required during the abatement period.
Step 3 - Abatement shall have been completed by the
implementation of feasible engineering and/or administrative
controls.  Verification of their effectiveness in achieving
compliance shall be submitted by 11/29/94.

Issued

Aug 1, 1994

Abate by

Aug 15, 1994

Hazardous substances H130

Issued

Aug 1, 1994

Abate by

Aug 5, 1994

Hazardous substances H130

Issued

Aug 1, 1994

Abate by

Sep 16, 1994

Penalty

Initial $875 · Current $525 Reduced

Issued

Aug 1, 1994

Abate by

Aug 5, 1994

Penalty

Initial $2,500 · Current $1,500 Reduced

Issued

Aug 1, 1994

Abate by

Aug 5, 1994

Issued

Aug 1, 1994

Abate by

Aug 5, 1994

Penalty

Initial $700 · Current $420 Reduced

Issued

Aug 1, 1994

Abate by

Aug 8, 1994

Issued

Aug 1, 1994

Abate by

Aug 15, 1994

Penalty

Initial $875 · Current $525 Reduced

Issued

Aug 1, 1994

Abate by

Aug 5, 1994

Penalty

Initial $525 · Current $315 Reduced

Issued

Aug 1, 1994

Abate by

Nov 29, 1994

Penalty

Initial $875 · Current $525 Reduced

Issued

Aug 1, 1994

Abate by

Nov 29, 1994

Issued

Aug 1, 1994

Abate by

Aug 5, 1994

Issued

Aug 1, 1994

Abate by

Nov 2, 1994

Issued

Aug 1, 1994

Abate by

Aug 25, 1994