OSHA Inspection: THE MOHAWK COMPANY

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $4,900 · Current $2,450 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 combustible metal dust deflagration, explosion, or other fire hazards while working at or near dust collectors and associated upstream equipment which were not adequately designed to prevent or minimize employee exposure in the event of a deflagration or other uncontrolled fire event:      (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that employees were protected from dust deflagration, explosion, or other fire hazards.  The employees were exposed to hazards from a dust collector, located inside the building and connected to the Goff abrasive blast units, which lacked means of (1) explosion protection, (2) deflagration isolation to upstream process equipment, and (3) fire protection.      (b)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that employees were protected from dust deflagration, explosion, or other fire hazards.  The employees were exposed to hazards from a dust collector, located outdoors and connected to the Wheelabrator abrasive blast units, which lacked means of (1) explosion protection, and (2) deflagration isolation to upstream process equipment.      (c)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that employees were protected from dust deflagration, explosion, or other fire hazards.  The employees were exposed to hazards from a dust collector, located outdoors and connected to four abrasive blast units, which lacked means of (1) explosion protection, and (2) deflagration isolation to upstream process equipment.         Among other methods, a feasible method to correct this hazard would be to comply with National Fire Protection Association (NFPA) Standards 484 "Standard for Combustible Metals, 2006 Ed." - Sections 12.2.1.4, 12.2.10.1, 12.2.10.7, 12.2.10.8, 13.3, NFPA 654 "Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2006 Ed." - Sections 7.1.2, 7.1.4, 7.1.5, 7.13.1.1.1, 7.13.1.3.1,  7.13.1.5, and/or to comply with FM Global Property Loss Prevention Data Sheet 7-73 "Dust Collectors and Collection Systems, 2010" - Section 2.1.1.1, 2.1.2.2, 2.1.4.2 and 7-76 "Prevention and Mitigation of Combustible Dust Explosions and Fire, 2009" - Sections 2.4.1.1.

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $3,500 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.22(a)(2):  The floor of every workroom was not maintained in a clean and, so far as possible, a dry condition:    (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that that the floors in the abrasive blast room were kept clean of accumulated dust from the Goff abrasive blast dust collector.  A sample of the metal dust was determined to be an explosive dust.  Employees were at risk of serious injury from a dust explosion.

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $3,500 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.107(i)(6):  All electrically conductive objects in the spraying area were not adequately grounded.    (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that the powder coating operator was electrically grounded while working in the spray booth.  Employees wore electrically insulating gloves while spraying powder coatings which prevented the employees from coming in contact with the grounded spray gun handles and the employees did not use grounding devices, such as but not limited to, grounding straps and static dissipative footwear to ensure they were electrically grounded to the spray booth.

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $3,500 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.134(c)(1):  In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer did not establish and implement a written respiratory protection program with worksite specific procedures which includes provisions (i) through (ix) of this subparagraph, as applicable:    (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not develop and implement a written respiratory protection program to address the selection, maintenance, storage, and use of respirators.  Employees working inside the powder coating booth were required to wear 3M N95 filtering face piece respirators (dust masks).

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(e)(1):  The employer did not provide a medical evaluation to determine the employees ability to use a respirator, before the employee was fit tested or required to use the respirator in the workplace:    (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that employees who were required to wear filtering face piece respirators were medically evaluated prior to wearing the respirators.  Employees working in the powder coating booth were required to wear 3M N95 filtering face piece respirators (dust masks)  without the benefit of a medical evaluation.

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(f)(2):  The employer did not ensure that an employee using a tight-fitting facepeice respirator was fit tested prior to initial use of the respirator and at least annually thereafter.    (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that employees who were required to wear filtering face piece respirators were fit tested prior to initial use.  Employees working in the powder coating booth were required to wear 3M N95 filtering face piece respirators (dust masks) without being fit tested.

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(g)(1)(i)(A):  The employer permitted respirators with tight-fitting face pieces to be worn by employees who have facial hair that comes between the sealing surface of the face piece and the face or that interferes with valve function:      (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that an employee required to wear a tight-fitting respirator was clean shaven.  An employee with several days growth beard which interfered with the face-to-respirator seal was required to wear a filtering face piece respirator while applying powder coatings.

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(k)(3):  The employer did not ensure that each employee received the respirator training required in 1910.134(k)(1)(i)-(vii) prior to requiring employees to use a respirator in the workplace:      (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that employees who were required to wear respirators received appropriate respiratory protection training before using the 3M respirators.  Employees working in the powder coating booth were required to wear 3M N95 filtering face piece respirators (dust masks) and were not aware of the limitations of the respirators, were not aware that facial hair interfered with the face-to-respirator seal, and were not aware that they must be medically cleared before using the respirator.

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1000(a)(2):  An employee's exposure to any substance in Table Z-1 exceeded the 8-hour Time Weighted Average given for that substance in an 8-hour work shift of a 40-hour work week:    (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about September 28, 2011, the employer did not ensure that employees manually applying powder coatings were protected from exposure to particulates not otherwise regulated (PNOR), total dust, in excess of the permissible exposure limit.  An employee was exposed to total dust at an 8-hour time weighted average of 49.24 mg/m3 which exceeded the OSHA Permissible Exposure Limit of 15.0 mg/m3 by 328%.    (b)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about September 28, 2011, the employer did not ensure that employees manually applying powder coatings were protected from exposure to particulates not otherwise regulated (PNOR), total dust, in excess of the permissible exposure limit.  An employee was exposed to total dust at an 8-hour time weighted average of 28.83 mg/m3 which exceeded the OSHA Permissible Exposure Limit of 15.0 mg/m3 by 192%.

Issued

Dec 8, 2011

Abate by

Mar 7, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1000(e):  Feasible administrative or engineering controls were not determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):    (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about September 28, 2011, the employer did not ensure that employees working in the powder coating booth were protected from exposure to particulates not otherwise regulated (PNOR), total dust, in excess of the permissible exposure limit.  An employee was exposed to total dust at an 8-hour time weighted average of 49.24 mg/m3 which exceeded the OSHA Permissible Exposure Limit of 15.0 mg/m3 by 328%.    (b)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about September 28, 2011, the employer did not ensure that employees working in the powder coating booth were protected from exposure to particulates not otherwise regulated (PNOR), total dust, in excess of the permissible exposure limit.  An employee was exposed to total dust at an 8-hour time weighted average of 28.83 mg/m3 which exceeded the OSHA Permissible Exposure Limit of 15.0 mg/m3 by 192%.    Step 1:  Effective respiratory protection shall be provided 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.  When personal exposure concentrations exceed the maximum allowable concentration for the respirator used, the employer shall ensure employees are protected with a respirator appropriate for the exposure concentration.    Step 2:  Within 60 days submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of engineering and /or administrative measures to control employee exposure to hazardous substances as referenced in the 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 controls options;  	2.  Selection of optimum control methods and completion of design  	3.  Procurement, installation, and operation of selected control measures; and  	4.  Testing and acceptance or modification/redesign of controls    Step 3:  Within 90 days abatement shall have been completed by the implementation of feasible engineering and / or administrative controls upon verification of their effectiveness in achieving compliance.  Feasible engineering controls include but are not limited to:  1. Improve the mechanical ventilation system in the coating booths so that the dust levels in the enclosure are maintained below exposure limits.    2.  Utilize spray guns which increase powder coating transfer of the powder coatings to the part and which reduce airborne concentrations of the coatings.  3.  Modify the coating application process such that the employees do not stand close to the part being coated and therefore the airborne dust is not in the employees breathing zone.  4.   Modify the coating application process such that employees stand upstream of the dust collection system so that the air currents in the booth draw the airborne dust away from the employees breathing zone.  5.  Automate the powder coating application process.     Date by which step 1 must be abated:  Date by which step 2 must be abated:  Date by which step 3 must be abated:    Ultimate responsibility for determining the most appropriate method rests with the employer, given his superior knowledge of the specific conditions at the workplace.

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $3,500 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.145(c)(2)(i):  Caution signs were not used only to warn against potential hazards or to caution against unsafe practices.    (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that signs warning of combustible dust hazards were posted at areas were an explosive atmosphere may occur.  Under normal operations, the powder coating booth and abrasive blaster dust collectors could contain an explosive atmosphere due to the presence of combustible dust.

Issued

Dec 8, 2011

Penalty

Initial $3,500 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.307(c):  Equipment, wiring methods, and installations of equipment in hazardous (classified) locations were not intrinsically safe, or approved for the hazardous (classified) location, or safe for the hazardous (classified) location:    (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that the wiring and electrical boxes mounted inside the powder coating booth were approved for use in the hazardous location.  NEMA Type I electrical equipment was installed in the powder coating booth.  Under normal operations, the interior of the booth is a Class II, division 1 environment due to the presence of airborne concentrations of a Class II dust.  NEMA Type I equipment is not approved for a Class II (dust) hazardous environment.

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $3,500 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met:    (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not develop and implement a written hazard communication program to address the hazards in the work area.  Employees were exposed to combustible dust, respiratory, dermal contact, ocular, and ingestion hazards.

Issued

Dec 8, 2011

Abate by

Dec 30, 2011

Penalty

Initial $3,500 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.1200(h)(1):  The employer did not provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area.    (a)	The Mohawk Company, 1700 Elida Road, Lima, Ohio:  On or about June 13, 2011, the employer did not ensure that employees were trained in the hazards present in the work areas.  Employees were exposed to combustible dust, respiratory, dermal contact, ocular, and ingestion hazards.  Employees were not aware of the PPE requirements, first aid measures, and potential safety and health effects of exposure to these hazards.