OSHA Inspection: GILL STUDIOS

Issued

Aug 1, 1991

Abate by

Aug 19, 1991

Penalty

Initial $4,500 · Current $4,500

Hazardous substances V107

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:
Employees performing operations related to silkscreening were exposed
to airborne concentrations of N-vinyl pyrrolidone that were in excess
of the manufacturers recommended exposure level of 0.1 ppm as an 8-hour
time weighted average.  Exposure to N-vinyl pyrrolidone may cause
health effects such as, but not necessarily limited to, benign or
malignant tumors of the nasal tissue:
(a)  The Press Operator working in the Production Area, sampled
for a total of 458 minutes on May 21, 1991, was exposed to N-vinyl
pyrrolidone at an 8-hour time weighted concentration of .57 ppm,
with zero exposure being assumed for the unsampled 22 minute
period of time.
(b)  The Press Operator working in the Production Area, sampled
for a total of 461 minutes on May 21, 1991, was exposed to N-vinyl
pyrrolidone at an 8-hour time weighted concentration of .67 ppm,
with zero exposure being assumed for the unsampled 19 minute
period of time.
(c)  The Die Cutter working in the Die Cutting Area, sampled for a
total of 422 minutes on May 21, 1991, was exposed to N-vinyl
pyrrolidone at an 8-hour time weighted concentration of .2 ppm,
with zero exposure being assumed for the unsampled 58 minute
period of time.
(d)  The Die Cutter working in the Die Cutting Area, sampled for a
total of 456 minutes on May 21, 1991, was exposed to N-vinyl
pyrrolidone at an 8-hour time weighted concentration of .33 ppm,
with zero exposure being assumed for the unsampled 24 minute
period of time.
(e)  The Carosel Operator working in the Production Area, sampled
for a total of 456 minutes on May 21, 1991, was exposed to N-vinyl
pyrrolidone at an 8-hour time weighted concentration of .44 ppm,
with zero exposure being assumed for the unsampled 24 minute
period of time.
(f)  The Screen Washer Lead working in the Screen Washing Dept.,
sampled for a total of 427 minutes on June 12, 1991, was exposed
to N-vinyl pyrrolidone at an 8-hour time weighted concentration
of .28 ppm, with zero exposure being assumed for the unsampled
53 minute period of time.
(g)  The Screen Washer working in the Screen Washing Dept.,
sampled for a total of 470 minutes on June 12, 1991, was exposed
to N-vinyl pyrrolidone at an 8-hour time weighted concentration of
.31 ppm, with zero exposure being assumed for the unsampled 10
minute period of time.
(h)  The Screen Washer working in the Screen Washing Dept.,
sampled for a total of 463 minutes on June 12, 1991, was exposed
to N-vinyl pyrrolidone at an 8-hour time weighted concentration of
.44 ppm, with zero exposure being assumed for the unsampled 17
minute period of time.
(i)  The Screen Washer working in the Screen Washing Dept.,
sampled for a total of 459 minutes on June 12, 1991, was exposed
to N-vinyl pyrrolidone at an 8-hour time weighted concentration of
.14 ppm, with zero exposure being assumed for the unsampled 21
minute period of time.
Feasible means of control for this hazard include, but are not
necessarily limited to, the following:
1.  Substitution to inks which do not contain N-vinyl pyrrolidone.
2.  Installation of local exhaust ventilation, at the source(s)
of N-vinyl pyrrolidone air contaminant generation.
3.  Increase levels of dillution ventilation.
Note that the employer, based upon superior knowledge of the
operation and working conditions, is responsible for the selection
and implementation of control measures to abate this hazard in
accordance with the following abatement schedule:
STEP 1:  Effective respiratory protection shall be provided and
used by exposed employees as an interim protective measure until
feasible engineering controls can be implemented, or whenever such
controls fail to reduce employee exposure to within the manu-
facturer's recommended exposure limit.
STEP 2:  Submit to the District Supervisor a written, detailed
plan of abatement, outlining a schedule for the implementation
of engineering measures, to control employee exposure to hazardous
substances as referenced in this citation.  This plan shall
include, at a minimum, the target dates for the following actions:
1.  Evaluation of engineering control options;
2.  Selection of optimum control methods and completion of design;
3.  Procurement, installation and operation of selected control
measures;
4.  Testing and acceptance or modification/redesign of control
measures;
5.  Abatement shall have been completed by the implementation of
feasible engineering controls, upon verification of their
effectiveness at achieving compliance.