OSHA Inspection: HOWELL MACHINE, INC.

Issued

Mar 12, 2012

Abate by

Feb 7, 2014

Penalty

Initial $4,200 · Current $1,512 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(d)(7): Additional exposure monitoring was not conducted when there was a change in production, process, control or personnel, or any other reason to suspect a change that may have resulted in new or additional exposure to lead:    (a)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, employees doing work were not monitored for airborne exposures to lead when the wash process was changed from the beginning to the end of the process.    (b)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, employees doing work were not monitored for airborne exposures to lead when the bullet polishing operation (Hammond Roto-Finish equipment) was added to the area.     Note: Abatement certification IS required for this item.

Issued

Mar 12, 2012

Abate by

Feb 7, 2014

Penalty

Initial $4,200 · Current $1,512 Reduced

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.1025(e)(3)(i): The employer did not establish and implement a written compliance program to reduce exposures to or below the permissible exposure limit, solely by means of engineering and work practice controls:    (a)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily on case processing machines and auto sorting machinery was exposed to lead above the Permissible Exposure Limit.      (b)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily with the bullet polishing machine; and the waste treatment flock(s) was exposed to lead above the Permissible Exposure Limit.        (c)   Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily performing hand (manual) inspection and sorting of shell casings was exposed to lead above the Permissible Exposure Limit.      Note: Abatement certification IS required for this item.

Issued

Mar 12, 2012

Abate by

Feb 7, 2014

Penalty

Initial $4,200 · Current $1,512 Reduced

General-duty citation text

29 CFR 1910.1025(j)(1)(i):  A medical surveillance program was not instituted for all employee(s) who were, or could be exposed to lead above the action level for more that thirty days per year:    (a)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, where employees were exposed to airborne lead concentrations in excess of the OSHA Permissible Exposure Limit (PEL) while performing work including, but not limited to, the manual sorting of spent shell casings.    (b)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, where employees were exposed to airborne lead concentrations in excess of the OSHA Permissible Exposure Limit (PEL) while performing work including, but not limited to, operation of the bullet polisher and tending the waste treatment flock.    Note: Abatement certification IS NOT required for this item.

Issued

Mar 12, 2012

Abate by

Feb 7, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(j)(2)(i)(A):  The employer did not make available biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels at least every 6 months to each affected employee:    (a)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, where employees were exposed to airborne lead concentrations in excess of the OSHA Permissible Exposure Limit (PEL) while performing work including, but not limited to, the manual sorting of spent shell casings.    (b)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, where employees were exposed to airborne lead concentrations in excess of the OSHA Permissible Exposure Limit (PEL) while performing work including, but not limited to, operation of the bullet polisher and tending the waste treatment flock.    Note: Abatement certification IS NOT required for this item.

Issued

Mar 12, 2012

Abate by

Feb 7, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(j)(3)(i)(B):   Medical examinations and consultations for lead were not performed prior to assignment for each employee being assigned for the first time to an area in which airborne concentrations of lead are at or above the action level:    (a)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, where employees were exposed to airborne lead concentrations in excess of the OSHA Permissible Exposure Limit (PEL) while performing work including, but not limited to, the manual sorting of spent shell casings.    (b)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, where employees were exposed to airborne lead concentrations in excess of the OSHA Permissible Exposure Limit (PEL) while performing work including, but not limited to, operation of the bullet polisher and tending the waste treatment flock.    Note: Abatement certification ISNOT required for this item.

Issued

Mar 12, 2012

Abate by

Feb 7, 2014

Penalty

Initial $8,400 · Current $3,037 Reduced

General-duty citation text

29 CFR 1910.1025(c)(1):   Employee(s) were exposed to lead at concentrations greater than fifty micrograms per cubic meter of air averaged over an eight-hour period:    (a)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily on case processing machines and auto sorting machinery was exposed to an 8-hour, time-weighted average of 112.1 ug/M3 of inorganic lead particulate.      (b)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily performing hand (manual) inspection and sorting of shell casings was exposed to an 8-hour, time-weighted average of 72.6 ug/M3 of inorganic lead particulate.    (c)   Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily with the bullet polishing machine; and the waste treatment flock(s) was exposed to an 8-hour, time-weighted average of 139.2 ug/M3 of inorganic lead particulate.    Note 1:  Howell Machine, Inc. was previously cited SERIOUS for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 313352254, citation number 2, item number 1a, and was affirmed as abated on October 14, 2010, with respect to a workplace located at 815 D. Street, Lewiston, Idaho 83501.      Note 2: Abatement certification and supporting documentation ARE required for this item.

Issued

Mar 12, 2012

Abate by

Feb 7, 2014

Penalty

Initial $8,400 · Current $3,037 Reduced

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.1025(e)(1)(i):  For any employees exposed to lead above the permissible exposure limit for more than 30 days per year where engineering and work practice controls (including administrative controls) were feasible but did not reduce the employees' exposure to or below the permissible exposure limit the employer did not use engineering and/or work practice controls to reduce exposures to the lowest feasible level:    (a)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily on case processing machines and auto sorting machinery was exposed to an 8-hour, time-weighted average of 112.1 ug/M3 of inorganic lead particulate.      (b)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily with the bullet polishing machine; and the waste treatment flock(s) was exposed to an 8-hour, time-weighted average of 72.6 ug/M3 of inorganic lead particulate.    (c)   Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily performing hand (manual) inspection and sorting of shell casings was exposed to an 8-hour, time-weighted average of 139.2 ug/M3 of inorganic lead particulate.    NOTE:  Howell Machine, Inc. was previously cited SERIOUS for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 313352254, citation number 2, item number 1b, and was affirmed as abated on October 14, 2010, with respect to a workplace located at 815 D. Street, Lewiston, Idaho 83501.     Note: Abatement certification and supporting documentation ARE required for this item.

Issued

Mar 12, 2012

Abate by

Feb 7, 2014

Penalty

Initial $8,400 · Current $3,037 Reduced

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.1025(f)(2)(i):   The employer must implement a respiratory protection program in accordance with  1910.134(b) through (d) (except (d)(1)(iii)), and (f) through (m), which covers each employee required by this section to use a respirator.    (a)   Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, where employees were exposed to inorganic lead in excess of the Permissible Exposure Limit and fit testing was not provided for all employees.     (b)   Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, where employees were exposed to inorganic lead in excess of the Permissible Exposure Limit and use of respirators and limitations with facial hair were not fully understood by all employees.     (c)   Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, where employees were exposed to inorganic lead in excess of the Permissible Exposure Limit and program evaluations were not conducted by the employer to evaluate the effectiveness of the program implementation.     NOTE:  Howell Machine, Inc. was previously cited SERIOUS for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 313352254, citation number 2, item number 3a, and was affirmed as abated on October 14, 2010, with respect to a workplace located at 815 D. Street, Lewiston, Idaho 83501.    Note: Abatement certification and supporting documentation ARE required for this item.

Issued

Mar 12, 2012

Abate by

Feb 7, 2014

Penalty

Initial $8,400 · Current $3,037 Reduced

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.1025(g)(1):  Where employees were exposed to lead above the PEL, the employer did not provide, at no cost to the employee and assure that the employee used, appropriate protective work clothing and equipment:    (a)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily on case processing machines and auto sorting machinery was exposed to inorganic lead particulate in excess of the PEL and was not provided protective clothing like coveralls, boot covers, and head covering.    (b)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily with the bullet polishing machine; and the waste treatment flock(s) was exposed to inorganic lead particulate in excess of the PEL and was not provided protective clothing like coveralls, boot covers, and head covering.    (c)   Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily performing hand (manual) inspection and sorting of shell casings exposed to inorganic lead particulate in excess of the PEL and was not provided protective clothing like coveralls, boot covers, and head covering.    NOTE:  Howell Machine, Inc. was previously cited SERIOUS for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 313352254, citation number 2, item number 3b, and was affirmed as abated on October 14, 2010, with respect to a workplace located at 815 D. Street, Lewiston, Idaho 83501.     Note: Abatement certification and supporting documentation ARE required for this item.

Issued

Mar 12, 2012

Abate by

Feb 7, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.1025(i)(2)(i):   Clean change rooms were not provided for employees exposed to lead in excess of the permissible exposure limit (PEL), without regard to the use of respirators:    (a)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily on case processing machines and auto sorting machinery was exposed to inorganic lead particulate in excess of the PEL.      (b)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily with the bullet polishing machine; and the waste treatment flock(s) was exposed to inorganic lead particulate in excess of the PEL.    (c)   Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily performing hand (manual) inspection and sorting of shell casings was exposed to inorganic lead particulate in excess of the PEL.    NOTE:  Howell Machine, Inc. was previously cited SERIOUS for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 313352254, citation number 2, item number 3c, and was affirmed as abated on October 14, 2010, with respect to a workplace located at 815 D. Street, Lewiston, Idaho 83501.     Note: Abatement certification and supporting documentation ARE required for this item.

Issued

Mar 12, 2012

Abate by

Feb 7, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.1025(i)(3)(i):   Employee(s) exposed to lead in excess of the permissible exposure limit (PEL), without regard to the use of respirators, were not required to shower at the end of the work shift:    (a)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily on case processing machines and auto sorting machinery was exposed to inorganic lead particulate in excess of the PEL.      (b)  Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily with the bullet polishing machine; and the waste treatment flock(s) exposed to inorganic lead particulate in excess of the PEL.    (c)   Case Processing Operations in Building 815A, on or about September 29, 2011, and at times prior thereto, the employee doing work primarily performing hand (manual) inspection and sorting of shell casings was exposed to inorganic lead particulate in excess of the PEL.    NOTE:  Howell Machine, Inc. was previously cited SERIOUS for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 313352254, citation number 2, item number 3d, and was affirmed as abated on October 14, 2010, with respect to a workplace located at 815 D. Street, Lewiston, Idaho 83501.     Note: Abatement certification and supporting documentation ARE required for this item.