OSHA Inspection: AFFORDABLE ENGINEERING SERVICES

Issued

Oct 3, 2012

Abate by

Oct 30, 2012

Penalty

Initial $7,000 · Current $3,500 Reduced

Hazardous substances 0360

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment to each employee that were free from recognized hazards that caused or were likely to cause death or serious physical harm to employees in that the employer failed to put into place Safety and Health programs, policies, and procedures to protect employees from the hazards of Beryllium.       Located in Bldg. 94, Hangar, Mezzanine, and Administration Offices, the employer failed to put into place Safety and Health programs, policies, and procedures to protect employees from the hazards of beryllium, which is likely to cause death and/or serious physical harm to employees.          AMONG OTHER METHODS, FEASIBLE AND ACCEPTABLE METHODS TO CORRECT THE HAZARD WOULD BE TO FOLLOW THE PROVISIONS OF:          ANSI standard is A37.29-1970 and DHHS (NIOSH Be Alert) Publication Number 2011 107 dated Feb. 2011 having feasible abatement methods for reducing this hazard include but are not limited to:     1. Institute a written effective Beryllium Dust and Exposure Control Program that details procedures for controlling beryllium dust contamination. The written program must indicate effective engineering controls, work practices, training, and housekeeping procedures.      2. Periodically evaluate the written program's effectiveness, including frequent and regular inspections by competent designated persons, HVAC balancing of the North Administration Offices, as well as institute changes when the written program is deemed ineffective.     3. Discontinue sanding and grinding in the open bays and conduct sanding and grinding operations in fully enclosed exhaust booths and isolation rooms that effectively capture all dusts generated by the operations.      4. Institute routine maintenance of ventilation engineering controls (vacuum tools, exhaust booths, etc.) to capture beryllium dusts generated during sanding and grinding operations.      5. Discontinue work practices of dry sweeping or other procedures that recirculate dusts into the air.      6. Institute effective use of vacuuming of work surfaces where dusts may have accumulated.      7. Require use of respirators and skin protective PPE to prevent exposure to beryllium dusts during work operations and clean up.      8. Require use of gloves while working in the zone of danger including desks and computer stations.      9. Evaluate and clean up dust accumulation throughout the building as well as the general HVAC system in the North Administration Office side of Bldg. 94.      10. Require employees to wash hands and faces before breaks and shower at the end of the work shift leaving at work site soiled work clothing or uniforms for laundering.           Pursuant to 29 CFR 1903, the employer must submit documents describing the steps it is taking to ensure compliance, including a description of how this program will protect its employees from the hazards associated with beryllium dusts.

Issued

Oct 3, 2012

Abate by

Oct 30, 2012

Penalty

Initial $7,000 · Current $3,500 Reduced

Hazardous substances 03601591C141

General-duty citation text

29 CFR 1910.141(g)(2):  Employees were permitted to consume food or beverage in area(s) exposed to toxic materials:     a) At Bldg. 94, Contractor break room, refrigerator door handle - On or about 4/10/12, employees were permitted to consume food or beverages in areas exposed to cadmium.    b) At Bldg. 94, Contractor break room, top of refrigerator - On or about 4/10/12, employees were permitted to consume food or beverages in areas exposed to lead and cadmium.    c) At Bldg. 94, Mezzanine, Fencing adjacent to employee desk - On or about 4/10/12, employees were permitted to consume food or beverages in areas exposed to lead and cadmium.	    d) At Bldg. 94, Mezzanine, Steel beam above break room area, adjacent to table - On or about 4/10/12, employees were permitted to consume food or beverages in areas exposed to lead, cadmium, and beryllium.    e) At Bldg. 94, Mezzanine, Break room, Top of locker - On or about 4/10/12, employees were permitted to consume food or beverages in areas exposed to lead and cadmium.    f) At Bldg. 94, Mezzanine, Break room, Steel beam above lockers - On or about 4/10/12 and at times prior thereto, employees were permitted to consume food or beverages in areas exposed to lead, cadmium, and beryllium.    g) At Bldg. 94, Mezzanine, Break room, Refrigerator - On or about 4/10/12, employees were permitted to consume food or beverages in areas exposed to lead and cadmium.      Pursuant to 29 CFR 1903, the employer must submit documents describing the steps it is taking to ensure compliance, including a description of how this program will protect its employees from the hazards associated with ingesting toxic materials.

Issued

Oct 3, 2012

Abate by

Oct 30, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 1591C141

General-duty citation text

29 CFR 1910.141(g)(4): Food or beverages were stored in area(s) exposed to toxic material(s):    a) At Bldg. 94, Contractor break room, refrigerator door handle - On or about 4/10/12, food and beverages were stored in areas exposed to cadmium.    b) At Bldg. 94, Contractor break room, top of refrigerator - On or about 4/10/12, food and beverages were stored in areas exposed to lead and cadmium.    c) At Bldg. 94, Mezzanine, Fencing adjacent to employee desk - On or about 4/10/12, employees were permitted to consume food or beverages in areas exposed to lead and cadmium.	    d) At Bldg. 94, Mezzanine, Steel beam above break room area, adjacent to table - On or about 4/10/12, employees were permitted to consume food or beverages in areas exposed to lead, cadmium, and beryllium.    e) At Bldg. 94, Mezzanine, Break room, Top of locker - On or about 4/10/12, employees were permitted to consume food or beverages in areas exposed to lead and cadmium.    f) At Bldg. 94, Mezzanine, Break room, Steel beam above lockers - On or about 4/10/12 and at times prior thereto, employees were permitted to consume food or beverages in areas exposed to lead, cadmium, and beryllium.    g) At Bldg. 94, Mezzanine, Break room, Refrigerator - On or about 4/10/12, employees were permitted to consume food or beverages in areas exposed to lead and cadmium    h) At Bldg. 94, Disassembly tent area - On or about 7/23/12, food and beverages were stored in areas exposed to heavy metals in the open bay of the hangar.    i) At Bldg. 94, computer station near superhornets, refrigerator - On or about 7/23/12, beverages were stored in areas exposed to heavy metals in the open bay of the hangar.    Pursuant to 29 CFR 1903, the employer must submit documents describing the steps it is taking to ensure compliance, including a description of how this program will protect its employees from the hazards associated with ingesting toxic materials.

Issued

Oct 3, 2012

Abate by

Oct 30, 2012

Penalty

Initial $7,000 · Current $3,500 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(h)(1): All surfaces shall be maintained as free as practicable of accumulations of lead:    a) At Bldg. 94, Hangar, Near column F-19, Top of electrical panel adjacent to 5-3-LP-1-02 - On or about 4/10/12, lead dusts were allowed to accumulate.      b) At Bldg. 94, Administration side, F/A-18 conference room, Return air vent - On or about 4/10/12, lead dusts were allowed to accumulate.      c) At Bldg. 94, Administration side, Supervisor's office, return air vent above kitchenette - On or about 4/10/12, lead dusts were allowed to accumulate.      d) At Bldg. 94, Mezzanine, Fencing adjacent to employee desk - On or about 4/10/12, lead dusts were allowed to accumulate.      e) At Bldg. 94, Mezzanine, Eyewash - On or about 4/10/12, lead dusts were allowed to accumulate.      f) At Bldg. 94, Mezzanine, Steel beam above break room area, adjacent to table - On or about 4/10/12, lead dusts were allowed to accumulate.      g) At Bldg. 94, Mezzanine, Break room, Top of locker - On or about 4/10/12, lead dusts were allowed to accumulate.      h) At Bldg. 94, Mezzanine, Break room, Steel beam above lockers - On or about 4/10/12, lead dusts were allowed to accumulate.      i) At Bldg. 94, Mezzanine, Top of red tool box - On or about 4/10/12, lead dusts were allowed to accumulate.      j) At Bldg. 94, Mezzanine, Break room, Refrigerator - On or about 4/10/12, lead dusts were allowed to accumulate.      k) At Bldg. 94, Mezzanine, Fencing above the Bonding shop - On or about 4/10/12, lead dusts were allowed to accumulate.      l) At Bldg. 94, First floor, Adjacent to stairs, Left of electrical panel L4.5 - On or about 4/10/12, lead dusts were allowed to accumulate.      m) At Bldg. 94, Contractor break room, top of refrigerator - On or about 4/10/12, lead dusts were allowed to accumulate.      n) At Bldg. 94, E-37 floor below emergency shower - On or about 4/10/12, lead dusts were allowed to accumulate.     o) At Bldg. 94, Middle quad desk, MSDS binder - On or about 4/10/12, lead dusts were allowed to accumulate.      p) At Bldg. 94, Middle quad desk, Employee clock out computer keyboard - On or about 4/10/12, lead dusts were allowed to accumulate.        Pursuant to 29 CFR 1903, the employer must submit documents describing the steps it is taking to ensure compliance, including a description of how this program will protect its employees from the hazards associated with lead.

Issued

Oct 3, 2012

Abate by

Oct 30, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(h)(2)(ii): Shoveling, sweeping or brushing methods were used to remove lead accumulations where vacuuming or other equally effective methods were available and feasible:    At Bldg. 94 - On or about 7/23/12, and at times prior thereto, dry sweeping and use of compressed air was performed throughout the hangar including the open bays of the center barrel area, disassembly area, Wing shop, Quickie shop, and mezzanine.

Issued

Oct 3, 2012

Abate by

Oct 30, 2012

Penalty

Initial $7,000 · Current $3,500 Reduced

Hazardous substances C141

General-duty citation text

29 CFR 1910.1027(k)(1):  Surfaces were not maintained as free as practicable of accumulations of cadmium:     a) At Bldg. 94, Hangar, Near column F-19, Top of electrical panel adjacent to 5-3-LP-1-02 - On or about 4/10/12, cadmium dusts were allowed to accumulate.      b) At Bldg. 94, Administration side, F/A-18 conference room, Return air vent - On or about 4/10/12, cadmium dusts were allowed to accumulate.     c) At Bldg. 94, Administration side, Supervisor's office, return air vent above kitchenette - On or about 4/10/12, cadmium dusts were allowed to accumulate.    d) At Bldg. 94, Administration side, Men's restroom, Return air vent - On or about 4/10/12, cadmium dusts were allowed to accumulate.      e) At Bldg. 94, Administration side, Women's restroom, Return air vent - On or about 4/10/12, cadmium dusts were allowed to accumulate.      f) At Bldg. 94, Mezzanine, Fencing adjacent to employee desk - On or about 4/10/12, cadmium dusts were allowed to accumulate.      g) At Bldg. 94, Mezzanine, Eyewash - On or about 4/10/12, cadmium dusts were allowed to accumulate.      h) At Bldg. 94, Mezzanine, Steel beam above break room area, adjacent to table - On or about 4/10/12, cadmium dusts were allowed to accumulate.      i) At Bldg. 94, Mezzanine, Break room, Top of locker - On or about 4/10/12, cadmium dusts were allowed to accumulate.      j) At Bldg. 94, Mezzanine, Break room, Steel beam above lockers - On or about 4/10/12, cadmium dusts were allowed to accumulate.      k) At Bldg. 94, Mezzanine, Top of red tool box - On or about 4/10/12, cadmium dusts were allowed to accumulate.      l) At Bldg. 94, Mezzanine, Break room, Refrigerator - On or about 4/10/12, cadmium dusts were allowed to accumulate.      m) At Bldg. 94, Mezzanine, Fencing above the Bonding shop - On or about 4/10/12, cadmium dusts were allowed to accumulate.      n) At Bldg. 94, First floor, Adjacent to stairs, Left of electrical panel L4.5 - On or about 4/10/12, cadmium dusts were allowed to accumulate.      o) At Bldg. 94, Contractor break room, refrigerator door handle - On or about 4/10/12, cadmium dusts were allowed to accumulate.      p) At Bldg. 94, Contractor break room, top of refrigerator - On or about 4/10/12, cadmium dusts were allowed to accumulate.      q) At Bldg. 94, E-37 floor below emergency shower - On or about 4/10/12, cadmium dusts were allowed to accumulate.      r) At Bldg. 94, Middle quad desk, MSDS binder - On or about 4/10/12, cadmium dusts were allowed to accumulate.     s) At Bldg. 94, Middle quad desk, Employee Clockout, computer keyboard- On or about 4/10/12, cadmium dusts were allowed to accumulate.     Pursuant to 29 CFR 1903, the employer must submit documents describing the steps it is taking to ensure compliance, including a description of how this program will protect its employees from the hazards associated with cadmium dusts.

Issued

Oct 3, 2012

Abate by

Oct 30, 2012

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR 1910.1027(k)(5): Shoveling, dry or wet sweeping and brushing were used where vacuuming or other methods that minimize the likelihood of cadmium becoming airborne had not been tried and/or had been found effective:    At Bldg. 94 - On or about 7/23/12, and at times prior thereto, dry sweeping and use of compressed air was performed throughout the hangar including the open bays of the center barrel area, disassembly area, Wing shop, Quickie shop, and mezzanine.