OSHA Inspection: S.H. LIVINGSTON & ASSOCIATES

Issued

Dec 11, 2012

Abate by

Jan 8, 2013

Penalty

Initial $1,600 · Current $800 Reduced

Hazardous substances 8111

General-duty citation text

29 CFR 1910.95(c)(1):     The employer did not administer a continuing, effective hearing conservation program as described in 29 CFR 1910.9(c) through (o) whenever employee noise exposures equal or exceed an 8-hour time-weighted average sound level of 85 decibels measured on the A scale, or equivalently a dose of fifty percent:    a) Finishing/Cleaning Area- The employer failed to implement a hearing conservation program for an employee grinding bronze parts that was exposed to an 8-hour time weighted average of 92.3 dBA, which exceeded the action limit of 85 dBA.  Results were from a 411 minute sampling period conducted on July 11, 2012.                               ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED

Issued

Dec 11, 2012

Abate by

Mar 14, 2013

Penalty

Initial $1,600 · Current $800 Reduced

Hazardous substances 1591

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) Finishing/Cleaning Area- An employee grinding on bronze ice machine housings was exposed to airborne lead at an 8-hour time weighted average (TWA) of 0.10 milligrams per cubic meter (mg/m3), which is 2.0 times the permissible exposure limit (PEL) of 0.050 mg/m3.  The exposure level was derived from a sample collected over a 405 minute sampling period on July 11, 2012.  Zero exposure assumed for the minutes not sampled.

Issued

Dec 11, 2012

Abate by

Mar 14, 2013

Penalty

Initial $0 · Current $0

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 the employer did not implement engineering and work practice controls (including administrative controls) to reduce and maintain employee exposure to lead below the permissible exposure limit:    a) Finishing/Cleaning Area- An employee grinding on bronze ice machine housings was exposed to airborne lead at an 8-hour time weighted average (TWA) of 0.10 milligrams per cubic meter (mg/m3), which is 2.0 times the permissible exposure limit (PEL) of 0.050 mg/m3.  The exposure level was derived from a sample collected over a 405 minute sampling period on July 11, 2012.  Zero exposure assumed for the minutes not sampled.     General methods of controls applicable in these circumstances include, but are not limited to:    Prevent dust generation at the point of operation by some type of local exhaust ventilation.    However, other methods of abatement may be equally, or more appropriate. Ultimate responsibility for determining the most appropriate abatement method rests with the employer, given its superior knowledge of the specific conditions at its worksite.                     ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED

Issued

Dec 11, 2012

Abate by

Jan 8, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(c)(1): A written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented for required respirator use:    a) Finishing/Cleaning Area- The employer had not established or implemented a respiratory protection program for an employee exposed to lead above the permissible exposure limit while grinding on bronze ice machine housings. The employee was wearing a N95 dust mask type respirator instead of a P100 high efficiency respirator. There was no written program, medical evaluations, fit-testing, or training.                      ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED

Issued

Dec 11, 2012

Abate by

Jan 8, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(m)(2)(i): Warning signs bearing the legend: WARNING, LEAD WORK AREA, POISON, NO SMOKING OR EATING, were not posted in each work area where the permissible exposure limit (PEL) was exceeded:    a) Finishing/Cleaning Area- There were no lead warning signs posted to properly notify employees so that they could take the necessary protective measures before entering the grinding area where an employee was exposed to lead above the permissible exposure limit for lead.                      ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED

Issued

Dec 11, 2012

Abate by

Jan 8, 2013

Penalty

Initial $1,600 · Current $800 Reduced

General-duty citation text

29 CFR 1910.1025(g)(1): Appropriate protective work clothing and equipment was not provided when employee(s) were exposed to lead above the permissible exposure limit (PEL), without regard to the use of respirators, or where the possibility of skin or eye irritation exists:    a) Finishing/Cleaning Area- An employee exposed to lead in excess of the permissible exposure limit while grinding bronze parts was not provided with adequate personal protective equipment to include coveralls or similar full-body clothing.                        ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED

Issued

Dec 11, 2012

Abate by

Mar 14, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(i)(2)(ii): Change rooms were not equipped with separate storage facilities for protective work clothing and equipment and for street clothes to prevent cross contamination from lead:    a) Change Area- Employees were exposed to hazards of lead when the employer failed to provide separate storage areas for street clothes and work clothes to prevent cross contamination in the change area.                     ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED

Issued

Dec 11, 2012

Abate by

Mar 14, 2013

Penalty

Initial $0 · Current $0

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) Change Area- An employee exposed to lead above the permissible exposure limit (PEL) was not required to shower at the end of the shift.                     ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED

Issued

Dec 11, 2012

Abate by

Mar 14, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(i)(3)(ii): Shower facilities, in accordance with 29 CFR 1910.141(d)(3), were not provided for employee(s) exposed to lead in excess of the permissible exposure limit (PEL), without regard to the use of respirators:    a) Change Area- The employer failed to provide showers exposing an employee to the hazards from lead when he was not able to shower at the end of the shift.                      ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED

Issued

Dec 11, 2012

Abate by

Jan 8, 2013

Penalty

Initial $1,200 · Current $600 Reduced

General-duty citation text

29 CFR 1910.1025(h)(1): All surfaces were not maintained as free as practicable of accumulations of lead:    a) Break Area- The employer failed to ensure that surfaces in the break area were maintained free of the accumulation of lead.  A wipe sample from the lunch table revealed that there was 12.18 micrograms of lead present.    b) Break Area- The employer failed to ensure that surfaces in the break area were maintained free of the accumulation of lead.  A wipe sample from the water fountain revealed that there was 18.40 micrograms of lead present.                     ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED

Issued

Dec 11, 2012

Abate by

Jan 8, 2013

Penalty

Initial $1,600 · Current $800 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) Finishing/Cleaning Area- The employer did not institute a medical surveillance program for an employee grinding bronze parts who was exposed to airborne concentrations of lead above the action level of 0.03 milligrams per cubic meter for 30 or more days per year. The employee was exposed to lead at an 8-hour time weighted average (TWA) of 0.10 milligrams per cubic meter (mg/m3), which is 3.3 times the action level. The exposure level was derived from a sample collected over a 405 minute sampling period on July 11, 2012. Zero exposure was assumed for the minutes not sampled.                     ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED

Issued

Dec 11, 2012

Abate by

Jan 8, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

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 in accordance with the implementation schedule in paragraph (e)(1):    a) The employer did not develop and implement a lead compliance program to reduce exposure to lead in the grinding area where an employee was exposed to lead in excess of the permissible exposure limit.                      ABATEMENT DOCUMENTATION AND CERTIFICATION REQUIRED