OSHA Inspection: REYNOLDS POLYMER TECHNOLOGY, INC

Issued

Aug 2, 2012

Abate by

Sep 1, 2012

Penalty

Initial $3,443 · Current $2,250 Reduced

General-duty citation text

29 CFR 1910.138(b) The employer did not base the selection of the appropriate hand protection on an evaluation of the performance characteristics of the hand protection relative to the task(s) to be performed, conditions present, duration of use, and the hazards and potential hazards identified:    (a) Reynolds Polymer Technology, Inc. at 607 Hollingsworth St. in Grand Junction, CO: The employer did not base the selection of the appropraite hand proteciton on an evaluation of the performance characteristics of the hand protection relative to the tasks(s) to be performed, conditions present, duration of use, and the hazards and potential hazards identified.  Employees in the Casting and Tool Prep area use Marigold Blue Nitrile G25B gloves for tasks involving contact with methyl methacrylate in excess of 30 minutes.  The breakthrough time (permeation performance) for this glove with this chemical is between 10 and 30 minutes.  This condition exposes employees to a skin sensitization hazard.    Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Aug 2, 2012

Penalty

Initial $2,066 · Current $1,350 Reduced

General-duty citation text

29 CFR 1910.151(c): Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:    (a) Reynolds Polymer Technology Inc. at 607 Hollingsworth St in Grand Junction, CO: On and before March 6, 2012 the facilities for quick drenching or flushing of the eyes and body were not provided in the autoclave mechanical room where employees dispense corrosive boiler treatment chemicals.  This condition exposed employees using corrosive chemicals to an eye hazard.    Abatement Note:  Abatement certification is not required for this item.

Issued

Aug 2, 2012

Abate by

May 20, 2013

Penalty

Initial $5,670 · Current $3,800 Reduced

General-duty citation text

29 CFR 1910.1000(a)(2) An employee's exposure to any substance in Table Z-1 shall not exceed the 8-hour Time Weighted Average given for that substance for any 8-hour work shift of a 40-hour work week:    (a) Reynolds Polymer Technology Inc. at 607 Hollingsworth St in Grand Junction, CO:  On April 24, 2012, the employer did not ensure that employees who were working in the Casting Room were protected from over-exposure to methyl methacrylate.  Employee A was exposed to a Time Weighted Average (8-hour TWA) of 148 parts per million (ppm), approximately 1.5 times the permissilbe exposure limite of 100 ppm.  This level of exposure is associated with asthma, and eye, skin, and respiratory tract irritatioin.    Abatement Note: Methyl methacrylate is a skin sensitizer. It is not classified as a carcinogen at this time.    Abatement Note:  Abatement certification and documentation are required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Aug 2, 2012

Abate by

May 20, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1000(e) Feasible administrative and engineering controls were not determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):     (a) Reynolds Polymer Technology Inc. at 607 Hollingsworth St in Grand Junction, CO:  On April 24, 2012 the employer did not implement administrative or engineering controls to achieve compliance with paragraph (a) of this section in that the employer relied on respiratory protection when employees were exposed to methyl methacrylate in excess of the OSHA Permissible Exposure Limit (PEL).   This condition exposed employees to a respiratory hazard.    Abatement Note: Feasible engineering controls include increased general exhaust ventilation in the work areas where monomer is used and installation of local exhaust ventilation.    STEP 1: Effective respiratory protection shall be provided and used by exposed employees as an interim protective measure until feasible engineering controls and/or administrative controls can be implemented or whenever such controls fail to reduce employee exposure to within exposure limits.    STEP 1 Abatement Date (15 Days):     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 exposures to silica.  The plan shall include, at a minimum, target dates for the following actions which should be consistent with the dates required by this citation:    (a) Evaluation of the extent and location of the hazard source  (b) Evaluation of control measure options  (c) Selection of optimum control measures  (d) Determination of control measure design  (e) Ordering and delivery of equipment  (f) Installation of control measures  (g) Training of employees in proper operation and maintenance of newly implemented control measures  (h) Assurance of the effective performance of control measures    All proposed control measures shall be evaluated for each particular use by a competent Industrial Hygienist or other technically qualified person.  Thirty (30) day progress reports are required during the abatement period.  The progress report must identify the action taken to achieve abatement and the date the action was taken.    STEP 2 Abatement Date (60 Days):     STEP 3: Abatement will be completed by the implementation of feasible engineering and/or administrative controls and upon verification of their effectiveness in achieving compliance.    STEP 3 Abatement Date: (90 Days):     Abatement Note: Abatement certification and documentation are required for this item (see enclosed "Sample Abatement Certification Letter").

Issued

Aug 2, 2012

Abate by

Sep 1, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(d)(1)(iii) The employer did not identify and evaluate the respiratory hazard(s) in the workplace:     (a) Reynolds Polymer Technology Inc. at 607 Hollingsworth St in Grand Junction, CO: On and before March 5, 2012 the employer did not evaluate the respiratory hazards in the workplace in that the employer did not evaluate emlployees' exposure to methyl methacrylate in the Bonding Room and did not repeat air monitoring for full-shift duration in the Casting and Tool Prep rooms following the previous OSHA inspection.  This condition exposed employees to a respiratory hazard.    Abatement Note: This evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.    Abatement Note: Abatement certification is required for this item (see enclosed "Sample Abatement Certification Letter").

Issued

Aug 2, 2012

Abate by

Sep 1, 2012

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 facepiece respirator was fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) was used, and at least annually thereafter:    (a) Reynolds Polymer Technology Inc. at 607 Hollingsworth St in Grand Junction, CO: The employer did not ensure that employees were fit tested at least annually when using tight-fitting facepiece respirators.  Employees working in Casting and Tool Prep were required to use tight fitting respirators and were not fit tested annually.  Improper respirator fit exposes employees to respiratory hazards.    Abatement Note: The employer shall establish a record of the qualitative and quantitative fit tests administered to an employee including:  The name or identification of the employee tested;  Type of fit test performed;  Specific make, model, style, and size of respirator tested;  Date of test; and  The pass/fail results for QLFTs or the fit factor and strip chart recording or other recording of the test results for QNFTs.    Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Aug 2, 2012

Abate by

Sep 1, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(g)(1)(i)(A) The employer shall not permit respirators with tight-fitting facepieces to be worn by employees who have facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function:    (a) Reynolds Polymer Technology Inc. at 607 Hollingsworth St in Grand Junction, CO: The employer permitted respirators with tight-fitting facepieces to be worn by employees who had facial hair that came between the sealing surface of the facepiece and the face. Employees in Tool Prep and Casting were allowed to wear tight-fitting respirators when they had facial hair.  Use of improperly sealed respirators exposes employees to respiratory hazards.    Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Aug 2, 2012

Abate by

Sep 1, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.95(i)(3): Employees were not given the opportunity to select their hearing protectors from a variety of suitable hearing protectors provided by the employer:    (a)  Reynolds Polymer Technology Inc. at 607 Hollingsworth St in Grand Junction, CO: On and before March 5, 2012 employees were not given the opportunity to select their hearing protectors from a variety of suitable hearing protectors in that only one type of ear plug was made available.  Employees are less likely to use hearing protection, or may not wear it properly, if the protector is not comfortable.    Abatement Note: Employers shall make hearing protectors available to all employees exposed to an 8-hour time-weighted average of 85 decibels or greater at no cost to the employees. Hearing protectors shall be replaced as necessary.    Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Aug 2, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1030(d)(4)(iii)(A)(1)(iv) Contaminated sharps shall be discarded immediately or as soon as feasible in containers that are labeled or color-coded in accordance with paragraph (g)(1)(i) of this standard:    (a) Reynolds Polymer Technology Inc. at 607 Hollingsworth St in Grand Junction, CO: The employer did not ensure that contaminated sharps were discarded immediately in standard sharps containers.  Employees routinely use razor blades for work tasks and the employer did not install a sharps container to dispose of blades contaminated with blood. This condition exposed employees to sharps injuries.    Abatement Note:  Abatement certification is not required for this item.