OSHA Inspection: NEO-BRAKE SYSTEMS, INC.

Issued

May 21, 2012

Penalty

Initial $1,530 · Current $0 Reduced

General-duty citation text

29 CFR 1910.124(g)(2):     Employees who  worked with liquids that could burn, irritate, or otherwise harm their skin were not provided with an emergency shower and eye-wash station close to the dipping and coating operation:    (a)  No emergency shower and eye-wash station was located in the vicinity of paint dip tanks, such as in the dip tank for the Small Shoe Line, where workers were potentially exposed to contacting skin or eyes with #76 Water-Base Black paint, which could cause irritation effects.

Issued

May 21, 2012

Penalty

Initial $2,040 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.133(a)(3):     The employer shall ensure that each affected employee who wears prescription lenses while engaged in operations that involve eye hazards wears eye protection that incorporates the prescription in its design, or wears eye protection that can be worn over the prescription lenses without disturbing the proper position of the prescription lenses or the protective lenses.    (a) Safety eyewear was not worn by worker(s) exposed to flying particles formed from brake liner stripping operations.

Issued

May 21, 2012

Penalty

Initial $2,550 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.147(c)(4)(ii):     Procedures did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, 29 CFR 1910.147(c)(4)(ii)(A), (c)(4)(ii)(B), (c)(4)(ii)(C) and (c)(4)(ii)(D):    (a) For example, the Punch Deliner featured multiple hazardous energy sources (electrical and pneumatic), but the generic procedures for applying and removing lockout devices, which had been developed for the Deliner, did not list specific procedural steps for shutting down, isolating, blocking and securing the machine to control hazardous energy as required by 29 CFR 1910.147(c)(4)(ii)(B).  Also this energy control procedure did not list specific procedural steps for the placement, removal lockout devices or tagout devices, as required by 29 CFR 1910.147(c)(4)(ii)(C).  In addition, this energy control procedure did not specify how to test a machine or equipment to verify effectiveness of lockout devices, tagout devices, and other energy control measures, as required by 29 CFR 1910.147(c)(4)(ii)(D).

Issued

May 21, 2012

Abate by

Jun 12, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(d):     The established procedure for the application of energy control (the lockout or tagout procedures) did not cover the actions listed in and was not done in sequence as required by 29 CFR 1910.147(d)(1)-(6):    (a) Periodically machine operator(s) performed set up of machines, such as the  Punch Deliner in the Big Shoe line area, involving tool changes, without first performing lockout/tagout of the equipment.  This condition potentially exposed hands of worker(s) to crushing injuries.    (b) According to the employer's written lockout procedures for equipment, such as the Deliner, the step in which energy isolation was verified (as detailed in the 3rd and 4th bullet points of the procedure) was incorrectly sequenced in that it was done prior to lockout or tagout device application.

Issued

May 21, 2012

Abate by

Aug 30, 2012

Penalty

Initial $1,530 · Current $0 Reduced

Hazardous substances 9135

General-duty citation text

29 CFR 1910.1000(a)(2):     Employee(s) were exposed to an airborne concentration of Particulates Not Otherwise Regulated (Total Dust) listed in Table Z-1 in excess of the 8 hour Time Weighted Average concentration of 15 milligrams per cubic meter:    (a)  On March 20, 2012 in the Small Brake Shoe Disassembly Area, a laborer who performed truck brake disassembly (a task involving operation of the Shear Deliner, manually knocking off remaining rivets by means of hammer and chisel, and blaster loading/unloading) was exposed to an 8-Hour Time Weighted Average of 29.17 milligrams Total Dust per cubic meter of air, approximately 1.94 times the Permissible Exposure Limit of 15 milligrams per cubic meter.      The 8-Hour Time Weighted Average exposure level was derived from air sampling conducted over a 464 minute period; exposure calculations included zero increment for the 16 minutes not sampled.

Issued

May 21, 2012

Abate by

Nov 17, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 9135

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) In the Small Shoe Line area, where workers performed brake disassembly, existing engineering and administrative controls were not adequate to maintain the exposure of the worker(s) to Particulates Not Otherwise Regulated (Total Dust), to less than the Permissible Exposure Limit of 15 milligrams per cubic meter.  Conditions that appeared to contribute to the overall exposure included the following: (1)  Visible dust in the area of the worker's breathing zone was generated during operation of the Shear Deliner; (2) Visible dust in the area of the worker's breathing zone was generated during manual rivet removal, performed by means of hammer and chisel; (3) Some leakage was noted from #3 Blaster which was periodically loaded/unloaded and operated by these workers.    Feasible means of abatement could include, but need not be limited to the following: (1) Provide industrial ventilation controls to reduce concentrations of dust emissions in the breathing zones of workers performing these operations; (2) Investigate feasiblility of replacing existing older brake disassembly equipment with newer automated brake disassembly equipment allowing the worker to be positioned more remotely from the point of operation and having capablility of automatic rivet removal, thus eliminating the step of manual rivet removal; (3) Inspect the #3 Blaster for leaks, repair as needed, verify proper functioning of blaster ventilation.

Issued

May 21, 2012

Abate by

Jun 12, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 9135

General-duty citation text

29 CFR 1910.134(a)(2):     The employer did not establish and maintain a respiratory protection program which included the requirements outlined in 29 CFR 1910.134(c):  (a) In the Small Shoe area where brake disassembly was performed, laborer(s) performing brake disassembly had exposure to Particulates Not Otherwise Regulated (Total Dust) in excess of the Permissible Exposure Limit of 15 milligrams per cubic meter, but no written respiratory protection program had been established to assure that these workers have adequate protection from respiratory hazards until effective engineering and/or administrative controls could be implemented.  In particular, the following respiratory protection provisions appeared to be deficient:   (1) No medical evaluations had been provided;  (2) No fit tests had been provided;  (3) Inadequate training on proper use of the respirator.

Issued

May 21, 2012

Abate by

Jul 3, 2012

Penalty

Initial $1,530 · Current $800 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 written hazard communication program did not adequately describe the numerical labeling system (which featured numerical ratings to denote hazards involving Health, Flammability, and Reactivity) that was used on some of the chemical containers in shop.  For example, this type of labeling system was used on the drum containing #76 Waterbase Black paint in the vicinity of the Small Shoe Line.

Issued

May 21, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(f)(5):     The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged, or marked with the identity and appropriate hazard warnings regarding the chemicals contained therein:    (a) In the Small Shoe Line area, the dip tank which contained black paint was not labeled with its identity and appropriate hazard warning.

Issued

May 21, 2012

Abate by

Jul 3, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h)(1):     Employees were not provided effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard that the employees had not been previously trained about was introduced into their work area:    (a) Workers were not provided adequate training on the health hazards of chemicals such as, but not limited to, the #76 Waterbase Black paint which could cause irritation and cracking of skin, irritation to eyes; potential inhalation effects could include dizziness and light headedness.  Workers were not adequately trained regarding the numerical labeling system, which was used to label some of the chemical containers, such as the dip tank located in the Small Shoe Line area.  Training did not adequately explain the location of material safety data sheets and access to those.  Training did not provide an adequate explanation of the information available in material safety data sheets.

Issued

May 21, 2012

Abate by

Jun 12, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(c)(2)(i):     Respirator users were not provided with the information contained in Appendix D to 29 CFR 1910.134 when the employer determined that any voluntary respirator use was permissible:    (a) Disposable filtering facepiece dust masks were voluntarily used in various areas of the shop, such as in the Small Shoe Line area, but workers were not informed of the contents of Appendix D of the Respiratory Protection standard.

Issued

May 21, 2012

Abate by

Jul 2, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(6)(ii):     The employer did not certify that periodic inspections of the energy control procedures had been performed:    (a) Periodic inspections of energy control procedures for various equipment in the shop, such as but not limited to wheelabrators and deliners, were not documented and cerrtified as required by this standard.

Issued

May 21, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.303(g)(1)(i)(A):     For electric equipment operating at 600 volts, nominal, or less to ground, and likely to require examination, adjustment, servicing, or maintenance while energized, the depth of the working space in the direction of access to live parts (as measured from the live parts where they were exposed or from the enclosure front or opening whwere they were enclosed) was less than indicated in Table S-1 of Subpart S of Part 1910:    (a) Parts were stacked on pallets in front of an energized breaker panel mounted on the west wall of the shop.