OSHA Inspection: FREUDENBERG NOK

Issued

Nov 30, 1993

Abate by

Jan 1, 1995

Penalty

Initial $1,625 · Current $100 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 inhalation hazard of chemical asthma from
isocyanate
compounds and feasible administrative or engineering controls were not
determined and
implemented to reduce employee exposures:
a.   Employee demolding parts on Line 3 (Canadian Line) on or about
7/15/93,
was exposed to isocyanates in the form of 2,6-Diisopropylphenyl
isocyanate
(DIPPI) at a time weighted average (TWA) of .014 ppm,
approximately 2.8
times the limit recommended by NIOSH and the chemical
manufacturer which
was established to prevent the development of chemical asthma;
the exposure
level was derived from two samples collected over 406 minutes
on
one shift.
Zero exposure was assumed for the 74 minutes not sampled.
b.   Employee deflashing parts on Line 2 on or about 7/15/93, was
exposed to
isocyanates in the form of 2,6-Diisopropylphenyl isocyanate
(DIPPI) at a time
weighted average (TWA) of 0.013 ppm, approximately 2.6 times
the limit
recommended by NIOSH and the chemical manufacturer which was
established to prevent the development of chemical asthma; the
exposure level
was derived from two samples collected over 413 minutes on one
shift.  Zero
exposure was assumed for the 67 minutes not sampled.
c.   Employee working as lead person in Jounce Department on or
about 7/15/93,
was exposed to isocyanates in the form of 2,6-Diisopropylphenyl
isocyanate
(DIPPI) at a time weighted average (TWA) of .008 ppm,
approximately 1.6
times the limit recommended by the NIOSH and the chemical
manufacturer
which was established to prevent the development of chemical
asthma; the
exposure level was derived from two samples collected over 413
minutes on
one shift.  Zero exposure was assumed for the 67 minutes not
sampled.
d.   Employee working as a batchmaker in Jounce Department on or
about
7/15/93, was exposed to isocyanates in the form of
2,6-Diisopropylphenyl
isocyanate (DIPPI) and 1,5-Naphthalene Diisocyanate (NDI) at a
time
weighted average (TWA) of .012 ppm, approximately 2.4 times the
limit
recommended by NIOSH and the chemical manufacturer which was
established to prevent the development of chemical asthma; the
exposure level
was derived from two samples collected over 358 minutes on one
shift.  Zero
exposure was assumed for the 122 minutes not sampled.
ABATEMENT NOTE:  Among other methods, feasible and acceptable abatement
methods
to correct this hazard include:
1.   Reduction of airborne exposure levels to the NIOSH recommended level
of .005 parts
per million (ppm) 8-hour time weighted average (TWA).
2.   Substitution of raw materials that are free of or contain less of
the DIPPI impurity.
3.   Improved local exhaust ventilation at the demolding stations.
4.   Rapid cooling of the parts as they come out of the molds.
5.   Fully automated demolding on all lines (such as on line 4).
6.   Full enclosure of the demolding and cooling of parts before accessed
by employees.
Abatement Schedule
Step 1 - Effective respiratory protection shall be provided to 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
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 abatement dates required by this citation:
(1)  Evaluation of engineering/administrative 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 controls.
All proposed control measures shall be approved for each
particular use by a
competent industrial hygienist or other technically qualified person.
90-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 upon verification of their effectiveness
in achieving
compliance.

Issued

Nov 30, 1993

Abate by

Jan 1, 1995

Penalty

Initial $1,625 · Current $100 Reduced

Issued

Nov 30, 1993

Abate by

Jan 1, 1995

Issued

Nov 30, 1993

Abate by

Dec 18, 1993

Penalty

Initial $1,625 · Current $1,700

Issued

Nov 30, 1993

Abate by

Dec 3, 1993

Penalty

Initial $1,625 · Current $1,700

Issued

Nov 30, 1993

Abate by

Jan 1, 1995

Issued

Nov 30, 1993

Abate by

Jan 1, 1995

Issued

Nov 30, 1993

Abate by

Jan 1, 1995

Issued

Nov 30, 1993

Abate by

Jan 1, 1995