OSHA Inspection: FRANKLIN NON-FERROUS FOUNDRY, INC.

Issued

Jul 17, 2012

Abate by

Aug 29, 2012

Penalty

Initial $4,400 · Current $4,400

Hazardous substances 0731

General-duty citation text

29 CFR 1910.1000(a)(2): Employee(s) were exposed to an airborne concentration of copper fume (a substance in Table Z-1) in excess of the 8 hour Time Weighted Average concentration of 0.1 milligrams per cubic meter (100 micrograms per cubic meter):            a.      Franklin Nonferrous Foundry - On 2/7/12, an employee was exposed to airborne copper fume at a concentration of 219 micrograms per cubic meter averaged over an eight-hour period, during pouring activities, approximately 2.19 times the permissible exposure limit (PEL) of 100 micrograms per cubic meter.   Overexposure to copper fume can cause acute lung damage/edema and metal fume fever.

Issued

Jul 17, 2012

Abate by

Aug 29, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 0731

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.      Franklin Nonferrous Foundry - As of  02/07/12, effective engineering controls were not implemented and/or maintained to prevent employee exposures above the applicable permissible exposure limit (PEL) of 100 micrograms per cubic meter. On 02/07/12 an employee was exposed to airborne copper fume at a concentration of 219 micrograms per cubic meter averaged over an eight-hour period, during pouring activities, approximately 2.19 times the permissible exposure limit (PEL).  Overexposure to copper fume can cause acute lung damage/edema and metal fume fever.  Administrative or engineering controls were not adequate to reduce the employee exposure to copper fume below the permissible exposure limit.

Issued

Jul 17, 2012

Abate by

Jul 19, 2012

Penalty

Initial $60,500 · Current $60,500

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(c)(1): The employer does not ensure that employees are not exposed to lead at concentrations greater than fifty micrograms per cubic meter of air averaged over an eight-hour period.  Two instances of this violation were observed most recently on February 7, 2012 when employees were working with metal alloys containing up to 1.7% lead:          a.      Franklin Nonferrous Foundry - On 2/7/12, an employee was exposed to airborne lead at a concentration of 84.8 micrograms per cubic meter averaged over an eight-hour period, during pouring activities and finishing activities, approximately 1.7 times the permissible exposure limit (PEL) of 50 micrograms per cubic meter.   Overexposure to lead can cause permanent kidney, blood, and reproductive damage.         b.      Franklin Nonferrous Foundry - On 2/7/12, an employee was exposed to airborne lead at a concentration of 66.4 micrograms per cubic meter averaged over an eight-hour period, during melting, wheel-a-brator, and foreman activities, approximately 1.3 times the permissible exposure limit (PEL) of 50 micrograms per cubic meter.  Overexposure to lead can cause permanent kidney, blood, and reproductive damage.     Prior violations include:    (1) a violation of this Occupational Safety and Health Standard which was contained in OSHA Inspection Number 302543269, Citation No, 1, item Number 2a issued on October 29, 2001 with respect to a workplace located at 293 Sanborn St. Franklin, NH.    (2) a violation of this Occupational Safety and Health Standard which was contained in OSHA Inspection Number 304559057, Citation No, 3, item Number 1a issued on July 2, 2003 with respect to a workplace located at 293 Sanborn St. Franklin, NH.    (3) a violation of this Occupational Safety and Health Standard which was contained in OSHA Inspection Number 306520052, Citation No, 2, item Number 4 issued on March 14, 2006 with respect to a workplace located at 293 Sanborn St. Franklin, NH    To abate this violation, the employer must ensure that its employees are not exposed to lead at concentrations greater than fifty micrograms per cubic meter of air averaged over an eight-hour period.  Pursuant to 29 C.F.R. 1903.19, the employer must submit documents describing the steps it is taking to ensure compliance immediately upon receipt of the citation, including an explanation of how these steps protect its employees from overexposures to lead.

Issued

Jul 17, 2012

Abate by

Jul 19, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(1)(i):  The employer does not implement engineering and work practice controls (including administrative controls) for any employees exposed to lead above the permissible exposure limit for more than 30 days per year so as to reduce and maintain employee exposure to lead in accordance with the schedule in Table I of this paragraph.  The most recent violation occurred on February 7, 2012 where engineering controls were in disrepair and/or were not being used:    a.         Franklin Nonferrous Foundry -  As of 02/07/12, the employer had failed to use and/or maintain the effectiveness of the ventilation systems to reduce the employee exposures to lead to 75 micrograms/cubic meter or below as given in Table 1 for small nonferrous foundries. Deficiencies were noted, such as but not limited to:      1.         The duct from the traveling hood was ripped and not repaired.     2.         The fresh air in-take system was not working.    3.         The ventilation for the furnace was not being used.    4.         Some molds on the pouring line were placed beyond the effective range of the slot hood ventilation.      On 2/7/12, an employee was exposed to airborne lead at a concentration of 84.8 micrograms per cubic meter averaged over an eight-hour period, during pouring activities and finishing activities, approximately 1.7 times the permissible exposure limit (PEL) of 50 micrograms per cubic meter.   Overexposure to lead can cause permanent kidney, blood, and reproductive damage.     Prior violations include:    (1) a violation of this Occupational Safety and Health Standard which was contained in OSHA Inspection Number 300448487, Citation No, 1, item Number 4b issued on May 5, 1999 with respect to a workplace located at 293 Sanborn St. Franklin, NH.    (2) a violation of this Occupational Safety and Health Standard which was contained in OSHA Inspection Number 302543269, Citation No, 1, item Number 2b issued on October 29, 2001 with respect to a workplace located at 293 Sanborn St. Franklin, NH.    (3) a violation of this Occupational Safety and Health Standard which was contained in OSHA Inspection Number 304559057, Citation No, 3, item Number 1b issued on July 2, 2003 with respect to a workplace located at 293 Sanborn St. Franklin, NH.    (4) a violation of this Occupational Safety and Health Standard which was contained in OSHA Inspection Number 306952052, Citation No, 2, item Number 6b issued on March 14, 2006 with respect to a workplace located at 293 Sanborn St. Franklin, NH.    To abate this violation, the employer must ensure that it implements engineering and work practice controls (including administrative controls), for any employees exposed to lead above the permissible exposure limit for more than 30 days per year so as to reduce and maintain employee exposure to lead in accordance with the schedule in Table I of this paragraph.  Pursuant to 29 C.F.R. 1903.19, the employer must submit documents describing the steps it is taking to ensure compliance immediately  upon receipt of the citation, including an explanation of how engineering and work practice controls (including administrative controls) are implemented to protect its employees from overexposures to lead.

Issued

Jul 17, 2012

Abate by

Jul 19, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(4)(i): The employer does not take measurements every three months of the ventilation systems used to control exposure to lead so as to demonstrate the effectiveness of the system in controlling exposures. The most recent violation of this was observed on February 7, 2012. During the inspection, the employer stated he had not taken ventilation system measurements for years.           a.      Franklin Nonferrous Foundry -  As of 02/07/12, the employer had not taken quarterly ventilation measurements as required. There were several problems with the ventilation system that would have reduced its efficiency and contributed to employee exposures. OSHA personal sampling on 02/07/12 showed that two workers were exposed to lead above the permissible exposure limit (PEL) of 50 micrograms per cubic meter.     Prior violation includes:     (1) a violation of this Occupational Safety and Health Standard which was contained in OSHA Inspection Number 306952052, Citation No, 2, item Number 6b issued on March 14, 2006 with respect to a workplace located at 293 Sanborn St. Franklin, NH.    To abate this violation, the employer must ensure that it takes measurements every three months of the ventilation systems used to control exposure to lead so as to demonstrate the effectiveness of the system in controlling exposures.  Pursuant to 29 C.F.R. 1903.19, the employer must submit documents describing the steps it is taking to ensure compliance immediately upon receipt of the citation, including an explanation of how ventilation measurements will be taken to ensure that ventilation system(s) are operating properly to ensure its employees are not overexposed to lead.

Issued

Jul 17, 2012

Abate by

Jul 19, 2012

Penalty

Initial $60,500 · Current $60,500

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(d)(7): The employer does not conduct additional lead exposure monitoring of its employees 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.  Two instances of this violation were observed on February 7, 2012 where additional monitoring was not conducted:     a.      Franklin Nonferrous Foundry - As of 02/07/12, The employer had not conducted additional monitoring after there was significant change to the operation of the ventilation system.  The rip in the duct for the traveling hood, the failure of the make-up air system, and the frequent non-use of the ring ventilation all contributed to a change in control, which would have resulted in additional exposure to lead. These conditions were allowed to continue for over a year.    b.      Franklin Nonferrous Foundry - As of 02/07/12, the employer had not conducted additional exposure monitoring when higher lead alloys were used, such as but not limited to C83450 (1.66-1.78% lead) and/or 245 (1.29-1.53% lead). These alloys contained between 24 and 71 times the amount of lead as that in the alloys which were sampled by the employer. On 02/07/12, OSHA exposure sampling determined that the permissible exposure limit (PEL) of 50 micrograms per cubic meter was exceeded when C83450 was used. Overexposure to lead can cause permanent kidney, blood, and reproductive damage.    Prior violation includes:    (1) a violation of this Occupational Safety and Health Standard which was contained in OSHA Inspection Number 302543269, Citation No, 3, item Number 3 issued on October 29, 2001 with respect to a workplace located at 293 Sanborn St. Franklin, NH.    To abate this violation, the employer must ensure that it performs additional exposure monitoring whenever there is 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.  Pursuant to 29 C.F.R. 1903.19, the employer must submit documents describing the steps it is taking to ensure compliance immediately upon receipt of the citation, including an explanation of how these steps protect its employees from overexposures to lead.

Issued

Jul 17, 2012

Penalty

Initial $60,500 · Current $60,500

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(f)(1)(ii): The Employer does not provide respirators to employees for protection against lead when engineering and/or work-practice controls are not sufficient to reduce employee exposures to or below the permissible exposure limit.  The most recent violation occurred on February 7, 2012 when an employee performing melting, wheel-a-brator, and foreman activities was not provided with a respirator:          a.      Franklin Nonferrous Foundry - On 2/7/12, a respirator was not provided to an employee who was exposed to airborne lead at a concentration of 66.4 micrograms per cubic meter averaged over an eight-hour period, during melting, wheel-a-brator, and foreman activities, approximately 1.3 times the permissible exposure limit (PEL) of 50 micrograms per cubic meter.  Overexposure to lead can cause permanent kidney, blood, and reproductive damage.     To abate this violation, the employer must ensure that its employees are provided with and use respiratory protection to reduce employee exposures to or below the permissible exposure limit of 50 micrograms per cubic meter averaged over an eight-hour period.  Pursuant to 29 C.F.R. 1903.19, the employer must submit documents describing the steps it is taking to ensure compliance immediately upon receipt of the citation, including an explanation of which employees are wearing respiratory protection in order to avoid overexposures to lead when engineering and/or work-practice controls are not sufficient to reduce employee exposures to or below the permissible exposure limit.