OSHA Inspection: THE ALLOY ENGINEERING COMPANY

Issued

Oct 24, 2012

Abate by

Nov 23, 2012

Penalty

Initial $4,900 · Current $2,940 Reduced

Hazardous substances 0689

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:    On or about August 30, 2012, a respirator program was not instituted for at least three employees performing welding operations who were exposed to levels of Hexavalent Chromium above the Permissible Exposure Level (PEL) of 5 micrograms per cubic meter based on an 8 hour time weighted average.  The employees exposures were 7 micrograms per cubic meter, which is 1.4 times the PEL; 7 micrograms per cubic meter, which is 1.4 times the PEL; and 13 micrograms per cubic meter, which is 2.6 times the PEL.

Issued

Oct 24, 2012

Abate by

Nov 23, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 0689

General-duty citation text

29 CFR 1910.134(e)(1):     The employer did not provide a medical evaluation to determine the employees' ability to use a respirator, before the employee was fit tested or required to use the respirator in the workplace:    a) On or about August 30, 2012, for at least three employees performing welding operations, who were exposed to levels of Hexavalent Chromium above the Permissible Exposure Level (PEL) of 5 micrograms per cubic meter based on an 8 hour time weighted average, were required to be in a respirator program and were not given medical evaluations.  The employees exposures were 7 micrograms per cubic meter, which is 1.4 times the PEL; 7 micrograms per cubic meter, which is 1.4 times the PEL; and 13 micrograms per cubic meter, which is 2.6 times the PEL.     b) On or about August 6, 2012, employees who were provided half mask respirators with cartridges to wear voluntarily were not provided with medical evaluations.

Issued

Oct 24, 2012

Abate by

Nov 23, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 0689

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) is used, and at least annually thereafter    On or about August 30, 2012, fit testing was not provided for at least three employees performing welding operations who were exposed to levels of Hexavalent Chromium above the Permissible Exposure Level (PEL) of 5 micrograms per cubic meter based on an 8 hour time weighted average.  The employees exposures were 7 micrograms per cubic meter, which is 1.4 times the PEL; 7 micrograms per cubic meter, which is 1.4 times the PEL; and 13 micrograms per cubic meter, which is 2.6 times the PEL.

Issued

Oct 24, 2012

Abate by

Nov 23, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 0689

General-duty citation text

29 CFR 1910.134(k)(3):     Training was not provided prior to requiring employees to use a respirator in the workplace:    On or about August 30, 2012, training required by the Respiratory Protection standard was not instituted for at least three employees performing welding operations who were exposed to levels of Hexavalent Chromium above the Permissible Exposure Level (PEL) of 5 micrograms per cubic meter based on an 8 hour time weighted average.  The employees exposures were 7 micrograms per cubic meter, which is 1.4 times the PEL; 7 micrograms per cubic meter, which is 1.4 times the PEL; and 13 micrograms per cubic meter, which is 2.6 times the PEL.

Issued

Oct 24, 2012

Abate by

Dec 17, 2012

Penalty

Initial $4,900 · Current $2,940 Reduced

General-duty citation text

29 CFR 1910.146(c)(4):     When the employer decided that its employees would enter permit spaces, the employer did not develop and implement a written permit space entry program that complied with 29 CFR 1910.146:    On or about August 6, 2012, the employer did not develop and implement a permit required space program for employees who enter into washer retorts.

Issued

Oct 24, 2012

Abate by

Nov 23, 2012

Penalty

Initial $4,900 · Current $2,940 Reduced

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(c):     Employees were exposed to an airborne concentration of chromium (VI) which exceeded 5 micrograms per cubic meter of air, as an 8-hour time-weighted average:    On or about August 30, 2012, at least three employees performing welding operations were exposed to levels of Hexavalent Chromium above the Permissible Exposure Level (PEL) of 5 micrograms per cubic meter based on an 8 hour time weighted average.  The employees exposures were 7 micrograms per cubic meter, which is 1.4 times the PEL; 7 micrograms per cubic meter, which is 1.4 times the PEL; and 13 micrograms per cubic meter, which is 2.6 times the PEL.        Engineering controls usually effective in these circumstances include but are not limited to the following:     1.	Local exhaust ventilation   2.	Gun mounted fume extractor  3.	Vacuum nozzle at the arc      Abatement Steps     STEP 1:  Effective respirators shall be provided and used by all employee(s) as an interim measure.  Abatement must be completed by ***5 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 as referenced in this citation.  This plan shall include, at a minimum, target dates for the following actions which must 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 method(s).     d)  Determination of control measure design.     e)  Ordering and delivery of equipment and material(s).     f)  Installation of control measures.     g)  Training of employees in proper operation and maintenance of newly-implemented control measures.     h)  Assurance of effective performance of control measures.     All proposed control measures shall be evaluated for each particular use by a technically qualified person.  Abatement must be completed by ***30 days***.     STEP 3:  Correction should have been completed by the implementation of feasible engineering and/or administrative controls and their effectiveness in achieving compliance.  Abatement must be completed by ***60 days***.

Issued

Oct 24, 2012

Abate by

Nov 23, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(e)(1):     The employer did not establish a regulated area wherever an employee's exposure to airborne concentrations of chromium (VI) is, or could reasonably be expected to be, in excess of the PEL:    On or about August 30, 2012, regulated areas were not established for at least three employees performing welding operations who were exposed to levels of Hexavalent Chromium above the Permissible Exposure Level (PEL) of 5 micrograms per cubic meter based on an 8 hour time weighted average.  The employees exposures were 7 micrograms per cubic meter, which is 1.4 times the PEL; 7 micrograms per cubic meter, which is 1.4 times the PEL; and 13 micrograms per cubic meter, which is 2.6 times the PEL.

Issued

Oct 24, 2012

Abate by

Nov 23, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(f)(1)(i):     Feasible engineering controls and work practices were not instituted to reduce and maintain employee exposures to chromium (VI) at or below the permissible exposure limit:    On or about August 30, 2012, feasible engineering and work practice controls were not used for at least three employees performing welding operations who were exposed to levels of Hexavalent Chromium above the Permissible Exposure Level (PEL) of 5 micrograms per cubic meter based on an 8 hour time weighted average.  The employees exposures were 7 micrograms per cubic meter, which is 1.4 times the PEL; 7 micrograms per cubic meter, which is 1.4 times the PEL; and 13 micrograms per cubic meter, which is 2.6 times the PEL.

Issued

Oct 24, 2012

Abate by

Jan 31, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(k)(1)(i)(A):     The employer did not make medical surveillance available for all employees who were or could be occupationally exposed to chromium (VI) at or above the action level for 30 or more days a year:    On or about August 30, 2012, a medical surveillance program was not made available for at least three employees performing welding operations for 30 days or more a year and who were exposed to levels of Hexavalent Chromium above the Permissible Exposure Level (PEL) of 5 micrograms per cubic meter, based on an 8 hour time weighted average.  The employees exposures were 7 micrograms per cubic meter, which is 1.4 times the PEL; 7 micrograms per cubic meter, which is 1.4 times the PEL; and 13 micrograms per cubic meter, which is 2.6 times the PEL.

Issued

Oct 24, 2012

Abate by

Nov 23, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(l)(2)(i):     The employer did not ensure that employees could demonstrate knowledge of the contents of this section and the purpose of medical surveillance; and in addition the employer did not make a copy of this section available without cost to all affected employees:    On or about August 30, 2012, the employer did not provide information and training on the Hexavalent Chromium Standard and the medical surveillance program to employees exposed to Hexavalent Chromium, including but not limited to three employees performing welding operations for 30 days or more a year and who were exposed to levels of Hexavalent Chromium above the Permissible Exposure Level (PEL) of 5 micrograms per cubic meter, based on an 8 hour time weighted average.  The employees exposures were 7 micrograms per cubic meter, which is 1.4 times the PEL; 7 micrograms per cubic meter, which is 1.4 times the PEL; and 13 micrograms per cubic meter, which is 2.6 times the PEL.

Issued

Oct 24, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1904.7(b)(1)(iv):     29 CFR 1904.7(b)(5): An injury or illness involving medical treatment, was not properly classified on the OSHA 300 Log by placing a check mark in the space for other recordable cases:    On or about August 6, 2012, the "other recordable case" dated April 24, 2012 and listed as case number 0212 on the employer's OSHA 300 Log for 2012; did not have a check mark in column J.

Issued

Oct 24, 2012

Abate by

Nov 23, 2012

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(k)(6):     The employer did not provide the basic advisory information on respirators, as presented in Appendix D of 29 CFR 1910.134, in written or oral format to employees who wear respirators when such use was not required by the employer:    On or about August 6, 2012, employees who were provided with filtering face piece (dust mask style) respirators to wear voluntarily were not trained on the information in Appendix D of 29 CFR 1910.134.