OSHA Inspection: RAILWAY AND INDUSTRIAL SERVICES

Issued

Jan 31, 2012

Abate by

Aug 7, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1000(e): To achieve compliance with paragraphs (a) through (d) of this section, administrative or engineering controls must first be determined and implemented whenever feasible. When such controls are not feasible to achieve full compliance, protective equipment or any other protective measures shall be used to keep the exposure of employees to air contaminants within the limits prescribed in this section. Any equipment and/or technical measures used for this purpose must be approved for each particular use by a competent industrial hygienist or other technically qualified person. Whenever respirators are used, their use shall comply with 1910.134.[71 FR 16673, April 3, 2006]    Engineering and work practice controls (including administrative controls) were not implemented to reduce and maintain employee exposure to iron oxide in accordance with the schedule in Table 1 of this paragraph:    a. On or about November 9, 2011, in the truck shop, general methods of control applicable in these circumstances include, but are not limited to the following:    1. Engineering controls such as additional  local ventilation.    2. Administrative controls such as limiting employees exposure to below that of the permissible exposure limit.    Abatement:    Step 1: Effective respirator protection shall be provided and used by the exposed employees as an interim protective measure until engineering and/or administrative controls can be implemented, or whenever such controls fail to reduce employee exposure to within permissible exposure limits.    Date by Which Abatement is Due:  Corrected During Inspection    Step 2:  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 the hazardous substances referred in this citation.  The plan shall include, at minimum, target dates for the following actions which must be consistent with 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; and    (4) Testing and acceptance or modification/redesign of controls.    Note: All proposed measures shall be approved for each particular use by a competent industrial hygienist or other qualified person. Ninety (90) day progress reports are required during the abatement period.    Date by Which Abatement is Due (60 days):                      04/24/2012                                            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.      Date by Which Abatement is Due (90 days):

Issued

Jan 31, 2012

Abate by

Aug 7, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1026(f)(1)(i):  The employer did not use engineering and work practice controls to reduce and maintain employee exposure to chromium (VI) to or below the PEL unless the employer can demonstrate that such controls are not feasible:    a. On or about November 9, 2011, in the truck shop, general methods of control applicable in these circumstances include, but are not limited to the following:    1. Engineering controls such as additional local ventilation.    Abatement:    Step 1: Effective respirator protection shall be provided and used by the exposed employees as an interim protective measure until engineering and/or administrative controls can be implemented, or whenever such controls fail to reduce employee exposure to within permissible exposure limits.    Date by Which Abatement is Due:  Corrected During Inspection    Step 2:  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 the hazardous substances referred in this citation.  The plan shall include, at minimum, target dates for the following actions which must be consistent with 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; and    (4) Testing and acceptance or modification/redesign of controls.    Note: All proposed measures shall be approved for each particular use by a competent industrial hygienist or other qualified person. Ninety (90) day progress reports are required during the abatement period.    Date by Which Abatement is Due (60 days):                                   04/24/2012    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.      Date by Which Abatement is Due (90 days):

Issued

Jan 24, 2012

Penalty

Initial $2,700 · Current $1,200 Reduced

General-duty citation text

29 CFR 1910.95(g)(6):     "Annual audiogram." At least annually after obtaining the baseline audiogram, the employer shall obtain a new audiogram for each employee exposed at or above an 8-hour time-weighted average of 85 decibels.    On or about November 9, 2011, in the work area, the employees were exposed to noise from 89 to 90 decibels as a time weighted average and were not provided audiograms in 2009, 2010 and 2011.

Issued

Jan 24, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.95(k)(2):     The training program shall be repeated annually for each employee included in the hearing conservation program. Information provided in the training program shall be updated to be consistent with changes in protective equipment and work processes.    a. On or about November 9, 2011, in the work area, employees were exposed to noise from 89 to 90 decibels as a time weighted average and were not provided annual training on the hearing conservation program for 2009, 2010 and 2011.

Issued

Jan 24, 2012

Abate by

May 7, 2012

Penalty

Initial $2,700 · Current $1,300 Reduced

General-duty citation text

29 CFR 1910.132(c):     Design. All personal protective equipment shall be of safe design and construction for the work to be performed.    a. On or about November 3, 2011, the employer installed a cable with harnesses in the box car area, but did not ensure that it met the minimum requirements of a fall protection system.  Employees were thereby exposed to the hazards associated with falls.

Issued

Jan 24, 2012

Penalty

Initial $4,500 · Current $2,250 Reduced

General-duty citation text

29 CFR 1910.134(f)(2):     The employer shall ensure that an employee using a tight-fitting facepiece respirator is fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.    a. On or about November 9, 2011, in the work area, employees over exposed to iron oxide and chromium VI (see citation 1, item 4a and 5a) were not fit tested annually.

Issued

Jan 24, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(k):     Training and information. This paragraph requires the employer to provide effective training to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary. This paragraph also requires the employer to provide the basic information on respirators in Appendix D of this section to employees who wear respirators when not required by this section or by the employer to do so.    a. On or about November 9, 2011, in the truck shop, the employees were not retrained annually on the half mask  respirators required to be worn for welding in the area.

Issued

Jan 24, 2012

Abate by

May 31, 2012

Penalty

Initial $4,500 · Current $2,250 Reduced

General-duty citation text

29 CFR 1910.1000(a)(2):     Other substances -- 8-hour Time Weighted Averages. An employee's exposure to any substance in Table Z-1, the exposure limit of which is not preceded by a "C", shall not exceed the 8-hour Time Weighted Average given for that substance any 8-hour work shift of a 40-hour work week.    a. On or about November 9, 2011, in the truck shop, an employee was exposed to iron oxide at an eight hour time weighted average of 14.0 milligrams per meter cubed (mg/m3), approximately 1.4 times the OSHA permissible exposure limit of 10 mg/m3.  This limit is established to prevent employees from suffering from adverse health effects such as lung changes (siderosis).    b. On or about November 9, 2011, in the truck shop, an employee was exposed to iron oxide at an eight hour time weighted average of 14.06 milligrams per meter cubed (mg/m3), approximately 1.4 times the OSHA permissible exposure limit of 10 mg/m3.  This limit is established to prevent employees from suffering from adverse health effects such as lung changes (siderosis).

Issued

Jan 24, 2012

Abate by

May 31, 2012

Penalty

Initial $4,500 · Current $2,250 Reduced

General-duty citation text

29 CFR 1910.1026(c):     Permissible exposure limit (PEL). The employer shall ensure that no employee is exposed to an airborne concentration of chromium (VI) in excess of 5 micrograms per cubic meter of air (5 g/m), calculated as an 8-hour time-weighted average (TWA).    a. On or about November 10, 2011, in the truck shop, an employee was exposed to chromium VI at an eight hour time weighted average of 0.0067 milligrams per meter cubed (mg/m3), approximately 1.35 times the OSHA permissible exposure limit of 0.005 mg/m3.  This limit is established to prevent employees from suffering from adverse health effects such as nasal septum ulceration and perforation, dermatitis, asthma and lung cancer.      b. On or about November 10, 2011, in the truck shop, an employee was exposed to chromium VI at an eight hour time weighted average of 0.012 milligrams per meter cubed (mg/m3), approximately 2.4 times the OSHA permissible exposure limit of 0.005 mg/m3.  This limit is established to prevent employees from suffering from adverse health effects such as lung cancerh as nasal septum ulceration and perforation, dermatitis, asthma and lung cancer.

Issued

Jan 24, 2012

Penalty

Initial $4,500 · Current $2,250 Reduced

General-duty citation text

29 CFR 1910.1026(d)(2)(i):     The employer shall perform initial monitoring to determine the 8-hour TWA exposure for each employee on the basis of a sufficient number of personal breathing zone air samples to accurately characterize full shift exposure on each shift, for each job classification, in each work area. Where an employer does representative sampling instead of sampling all employees in order to meet this requirement, the employer shall sample the employee(s) expected to have the highest chromium (VI) exposures.    a. On or about November 10, 2011, in the truck shop, the welders weld on stainless steel parts. The employee did not perform air monitoring.  The employees were exposed to chromium VI at a time weighted average (TWA) of 0.0067 mg/m3 and 0.012 mg/m3, approximately 1.35 and 2.4 times the OSHA established TWA of 0.005 mg/m3, during the day shift. The limit was established to prevent nasal septum ulceration and perforation, dermatitis, asthma and lung cancer.

Issued

Jan 24, 2012

Abate by

Mar 7, 2012

Penalty

Initial $4,500 · Current $2,250 Reduced

General-duty citation text

29 CFR 1910.1026(e)(1): The employer did not establish a regulated area whenever an employee's exposure to airborne concentration to chromium (VI) is, or can reasonably be expected to be, in excess of the PEL.    a. On or about Novemebr 10, 2011, in the truck shop, employees exposures exceeded the chromium VI permissible exposure limit (PEL) by 1.35 and 2.4 times.  The employer did not establish a regualted area to control or post signs to alert employees.

Issued

Jan 24, 2012

Abate by

Mar 7, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1026(h)(1): Where a hazard is present or is likely to be present from skin or eye contact with chromium (VI), the employer did not provide appropriate personal protective clothing and equipment at no cost to employees, and did not ensure that employees used such clothing and equipment.      a. On or about Novemebr 10, 2011, in the truck shop,  employees were exposed to chromium VI at 1.35 and 2.4 times the PEL and were not provided protective clothing and equipment that was laundered and maitained by the employer.

Issued

Jan 24, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1026(i)(2): The employer did not assure that change rooms are equipped with separate storage facilities for protective clothing and equipment and for street clothes, and that these facilities prevent cross contamination.     a. On or about November 10, 2011, at the site, the employer did not ensure that the employees overexposed to chromium VI were provided two lockers and a separate area from other employees to prevent cross contamination.

Issued

Jan 24, 2012

Abate by

Feb 7, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1026(i)(3)(ii):  The employer did not ensure that employees who have skin contamination with chromium VI wash their hands and faces at the end of the work shift and prior to eating , drinking, smoking, chewing tobacco or gum, applying cosmetics, or using the toilet.     a. On or about November 10, 2011, at the site, employees over exposed to 1.35 to 2.4 times the PEL for chromium VI were not required to wash their hands and face before eating, drinking, smoking, chewing gum or tobacco or using the toilet.

Issued

Jan 24, 2012

Abate by

Mar 7, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1026(i)(4)(ii): The employer did not ensure that eemployees do not enter eating and drinking areas with protective work clothing or equipment unless surface chromium VI has been removed from the clothing and equipment by methods that do not disperse chromium VI into the air onto the employee's body.     a. On or about November 10, 2011, at the site, the employees over exposed 1.34 and 2.4 times the permissible exposure limit were not requried to remove or vacuum their contaminated clothing before entering the lunchroom.

Issued

Jan 24, 2012

Abate by

Mar 7, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1026(k)(1)(i)[A]:  The employer did not make medical surveillance available at no cost to the employee, and at a reasonable time and place. for all employees:    Who are or may be occupationally exposed to chromium (VI) at or above the action level for 30 or more days a year.     a.  On or about December 10, 2011, at the facility, the employer did not have a medical surveillance program for  employees exposed or potentially exposed to chromium VI above the action level 30 or more days a year.

Issued

Jan 24, 2012

Abate by

Mar 7, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1026(l)(2)(i):  The employer did not ensure that each employee can demonstrate knowledge of at least the following:  A. The contents of this section.  B. The purpose and description of the medical surveillance program required by this paragraph (k) of this section.     On or about November 10, 2011, at the site, employees were overexposed to chromium VI 1.34 and 2.4 times the PEL. The employer did not train the employees on the chromium VI standard, the medical surveillance paragraph and availability of the standard.

Issued

Jan 24, 2012

Abate by

Mar 7, 2012

Penalty

Initial $4,500 · Current $2,250 Reduced

General-duty citation text

29 CFR 1910.1200(h)(1):     Employers shall 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. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety datasheets.    a. On or about November 9, 2011, in the work area, the employees were not trained or in the case of employees that were rehired they were not retrained,  in the hazards associated with chemicals such as, but not limited to, iron oxide, manganese and other potential welding fume metals.