OSHA Inspection: NOVA_CHROME, INC

Issued

Oct 31, 2012

Abate by

Dec 14, 2012

Penalty

Initial $2,800 · Current $1,400 Reduced

Hazardous substances 0689

General-duty citation text

29 CFR 1910.134(d)(1)(ii):     The employer did not select and use a NIOSH-certified respirator in compliance with the conditions of its certification:    (a) On or about September 6, 2012, employees of Nova-Chrome Inc. were observed wearing their 3M 8511 N95 dustmasks improperly.  Employees only utilized the upper strap to secure the respirator to their face, which did not allow for a proper seal around the nose and mouth.  An employee wearing the dust mask in this manner was exposed to hexavalent chromium at a level of 6.5 micrograms per cubic meter of air (mcg/m3), which is 1.3 times the permissible exposure limit of 5 mcg/m3.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Oct 31, 2012

Abate by

Mar 14, 2013

Penalty

Initial $2,800 · Current $1,400 Reduced

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(c):     The employer did not ensure that no employee was exposed to an airborne concentration of chromium (VI) in excess of 5 micrograms per cubic meter of air (mcg/m3), calculated as an 8-hour time-weighted average (TWA).    a) Nova-Chrome Inc., Franklin Park, IL- An employee performing chrome electroplating was exposed to airborne levels of hexavalent chromium at an 8-hour TWA level of 6.5 mcg/m3, which is approximately 1.3 times the OSHA 8-hour TWA Permissible Exposure Limit of 5 mcg/m3.  This limit is established to prevent irritation of the respiratory system, skin, and eye injuries, as well as lung cancer, asthma, and nasal septum perforation and ulceration.  The exposure level was derived from a sample taken over a 382 minute period during one shift on September 6, 2012.  Zero exposure was assumed for the unsampled period of 98 minutes.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Oct 31, 2012

Abate by

Mar 14, 2013

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:    (a) Nova-Chrome Inc., Franklin Park, IL- Effective engineering controls and work practices were not instituted and maintained by the employer for the chrome electroplating operation to reduce employee exposure to levels of airborne hexavalent chromium below the OSHA Permissible Exposure Limit (PEL) of 5 mcg/m3 as an 8-hour time-weighted average.  An employee performing chrome plating on September 6, 2012 was exposed to airborne concentrations of hexavalent chromium in excess of the OSHA PEL.    See instance description in item 2a of this citation.    Methods of engineering controls and work practices under these circumstances include, but are not limited to:    1) Seek the expertise of a competent individual such as an engineer or certified industrial hygienist to assess existing controls and work practices (including the manual spray rinse operations), provide recommendations to improve existing controls and work practices, and prepare design documentation for the successful installation of recommended equipment or modifications.    2) Use an enclosure with mechanical ventilation for the manual spraying operations to capture mists generated.    ABATEMENT NOTE:    STEP 1: Effective respiratory protection shall be used by the affected employees as an interim measure.  Ensure employees are retrained on the proper use of the respiratory equipment being used.      Abatement date: 12/14/2012    Step 2:  A written, detailed plan of abatement shall be submitted to the Area Director outlining a schedule for the implementation of engineering controls and work practice measures to control employee exposures to hexavalent chromium as referenced in the citation.  This plan shall include, at a minimum, target dates for the following action, which must be consistent with the dates required by this citation:    (1) Evaluation of engineering controls and work practices.  (2) Selection of the optimum combination of engineering controls and work practices.  (3) Installation and operation of the optimum engineering conrtols and work practices.  (4) Testing and acceptance, or modification/ redesign of the engineering controls and work practices.      Abatement Date: 1/30/2013    STEP 3:  Abatement shall have been completed by the implementation of feasible engineering/administrative controls and/or work practice changes upon verification of their effectiveness in achieving compliance.    Abatement date: 3/14/2013     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Oct 31, 2012

Abate by

Nov 23, 2012

Penalty

Initial $2,800 · Current $1,400 Reduced

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(d)(3):     The employer used the performance-oriented option; however, the employer did not determine the 8-hour time-weighted average exposure for each employee on the basis of any combination of air monitoring data, historical monitoring data, or objective data sufficient to accurately characterize employee exposure to chromium (VI):    (a) Nova-Chrome Inc. performed initial monitoring for hexavalent chromium in 2005.  Results of this monitoring indicated employee exposures of 5.95 and 5.84 mcg/m3, which were above the OSHA PEL of 5 mcg/m3.  Subsequent to initial monitoring, the employer installed local exhaust ventilation but did not sample to determine employee exposure after the change in the work environment.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Oct 31, 2012

Abate by

Nov 23, 2012

Penalty

Initial $2,800 · Current $1,400 Reduced

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) was, or could reasonably be expected to be, in excess of the permissible exposure limit:    (a) On or about September 6, 2012, employee(s) of Nova-Chrome Inc. were exposed televels of hexavalent chromium that exceeded the OSHA PEL of 5 micrograms per cubic meter od air.  Nova-Chrome Inc. did not establish a regulated area around the chrome plating tanks where employees could be exposed to airborne concentrations in excess of the PEL.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Oct 31, 2012

Abate by

Nov 23, 2012

Penalty

Initial $2,800 · Current $1,400 Reduced

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:    (a) Nova-Chrome Inc., Franklin Park, IL- Nova-Chrome Inc. did not make medical surveillance for chromium (VI) available to employees.  On September 6, 2012, an employee was exposed to an airborne level of hexavalent chromium at an 8-hour time-weighted average of 6.5 mcg/m3, which is approximately 1.3 times the OSHA 8-hour time-weighted average Permissible Exposure Limit of 5 mcg/m3.  Employees perform chrome plating operations for 8 hours per day 5 days per week.  It can be reasonably expected that employees may be exposed to hexavalent chromium over the action level for 30 or more days a year.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Oct 31, 2012

Abate by

Nov 23, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1200(f)(5)(i):     The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the identity of the hazardous chemical(s) contained therein:    (a) On or about September 2, 2012, Nova-Chrome Inc. did not label their chrome plating tanks to inform the employees that the tanks contained hexavalent chromium.    In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Oct 31, 2012

Abate by

Nov 23, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1200(f)(5)(ii):     The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the appropriate hazard warnings:    (a) On or about September 6, 2012, Nova-Chrome Inc. did not label their chrome plating tanks with the health hazards of hexavalent chromium.    In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).