OSHA Inspection: RAPP BROS PALLET SERVICES

Issued

Jan 11, 2013

Abate by

Apr 16, 2013

Penalty

Initial $4,900 · Current $2,450 Reduced

Hazardous substances 81108111

General-duty citation text

29 CFR 1910.95(b)(1):     When employees were subjected to sound exceeding those listed in Table G-16, feasible administrative or engineering controls were not utilized:    a) Wood Cutting Area: An employee, Chop Saw Operator, cutting 2x4s with a chop saw was exposed to continuous noise at 413.0% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 100.2 dBA.  This exposure was observed over a 428 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 52 minutes not sampled.  The employer did not utilize feasible administrative or engineering controls for employees exposed above the eight-hour TWA of 100% of the PEL or 90 dBA, on or about October 2, 2012.    b) Pallet Building Area: An employee, Pallet Builder, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 256.8% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 96.7 dBA.  These exposures were observed over a 444 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled.  The employer did not utilize feasible administrative or engineering controls for employees exposed above the eight-hour TWA of 100% of the PEL or 90 dBA, on or about October 2, 2012.    c) Pallet Building Area: Two employees, Pallet Builders, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 213.7% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 95.4 dBA respectively.  These exposures were observed over a 465 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled.  The employer did not utilize feasible administrative or engineering controls for employees exposed above the eight-hour TWA of 100% of the PEL or 90 dBA, on or about October 2, 2012.    d) Pallet Repairing Area: An employee, Pallet Repairer, repairing broken pallets with a hammer, crowbar and a Tech PCN 670S-2 nail gun was exposed to continuous noise at 189.1% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 94.5 dBA.  This exposure was observed over a 455 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 25 minutes not sampled.  The employer did not utilize feasible administrative or engineering controls for employees exposed above the eight-hour TWA of 100% of the PEL or 90 dBA, on or about October 2, 2012.    Feasible abatement methods include but are not limited to:  1) Covering the surface of the metal tables in the pallet repair/build area with sound deadening material and if necessary, cover with a wood overlay.   2) Adding damping material to the saw blade to reduce vibration on the 22 cut saw.  3) Implement employee rotation of saw operators or limit use of the saw to a 4 hour period.  4) Replace or redesign saw so that the blade does not continuously run, requiring activation of a switch during cutting and such that the blade shuts off between cuts.     ABATEMENT STEPS ARE AS FOLLOW:    STEP 1 - As an interim protective measure and when administrative or engineering controls fail to reduce sound levels within the levels of table G-16, effective hearing protection shall be provided and used by all exposed employees.  In addition, an effective hearing conservation program in accordance with 29 CFR 1910.95(c) through (n) shall be maintained.    STEP 2 - A written detailed plan of abatement shall be submitted to the Area Director outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposures to noise 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:    1.  Evaluation of engineering control options;    2.  Selection of optimum control method and completion of design;    3.  Procurement, installation and operation of selected control measures;    4.  Testing and acceptance or modification/redesign of controls.    All proposed control measures shall be evaluated for each particular use by a competent industrial hygienist or other technically qualified person.  Ninety (90) day progress reports are required during the abatement period.    STEP 3 - Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.

Issued

Jan 11, 2013

Abate by

Feb 15, 2013

Penalty

Initial $4,900 · Current $2,450 Reduced

Hazardous substances 81108111

General-duty citation text

29 CFR 1910.95(g)(1):     The employer did not establish and maintain an audiometric testing program as provided by 29 CFR 1910.95(g) by making audiometric testing available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 decibels:    a) Wood Cutting Area: An employee, Chop Saw Operator, cutting 2x4s with a chop saw was exposed to continuous noise at 417.6% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 100.3 dBA.  This exposure was observed over a 428 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 52 minutes not sampled.  The employer did not establish and maintain an audiometric testing program for employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    b) Pallet Building Area: An employee, Pallet Builder, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 256.8% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 96.7 dBA.  These exposures were observed over a 444 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled.  The employer did not establish and maintain an audiometric testing program for employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    c) Pallet Building Area: Two employees, Pallet Builders, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 213.7% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 95.4 dBA respectively.  These exposures were observed over a 465 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled.  The employer did not establish and maintain an audiometric testing program for employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    d) Pallet Repairing Area: An employee, Pallet Repairer, repairing broken pallets with a hammer, crowbar and a Tech PCN 670S-2 nail gun was exposed to continuous noise at 189.1% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 94.5 dBA.  This exposure was observed over a 455 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 25 minutes not sampled. The employer did not establish and maintain an audiometric testing program for employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    Abatement certification required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Jan 11, 2013

Abate by

Feb 15, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 81108111

General-duty citation text

29 CFR 1910.95(i)(2)(i):     The employer did not ensure that hearing protectors are worn by an employee who is required by 29 CFR 1910.95(b)(1) to wear personal protective equipment:    a) Pallet Building Area: An employee, Pallet Builder, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 256.8% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 96.7 dBA.  These exposures were observed over a 444 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled.  The employer did not require the employee to wear hearing protection when the employee was exposed to 100% of the PEL or an eight-hour TWA of 90 dBA, on or about October 2, 2012.    b) Pallet Building Area: Two employees, Pallet Builders, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 213.7% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 95.4 dBA respectively.  These exposures were observed over a 465 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled. The employer did not require the employee to wear hearing protection when the employee was exposed to 100% of the PEL or an eight-hour TWA of 90 dBA, on or about October 2, 2012.    c) Pallet Repairing Area: An employee, Pallet Repairer, repairing broken pallets with a hammer, crowbar and a Tech PCN 670S-2 nail gun was exposed to continuous noise at 207.6% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 95.2 dBA.  This exposure was observed over a 455 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 25 minutes not sampled. The employer did not require the employee to wear hearing protection when the employee was exposed to 100% of the PEL or an eight-hour TWA of 90 dBA, on or about October 2, 2012.    Abatement certification required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Jan 11, 2013

Abate by

Feb 15, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 81108111

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) Wood Cutting Area: An employee, Chop Saw Operator, cutting 2x4s with a Chop saw was exposed to continuous noise at 417.6% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 100.3 dBA.  This exposure was observed over a 428 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 52 minutes not sampled.  The employer did not provide multiple types of hearing protection for employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    b) Pallet Building Area: An employee, Pallet Builder, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 256.8% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 96.7 dBA.  These exposures were observed over a 444 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled.  The employer did not provide multiple types of hearing protection for employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    c) Pallet Building Area: Two employees, Pallet Builders, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 213.7% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 95.4 dBA respectively.  These exposures were observed over a 465 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled. The employer did not provide multiple types of hearing protection for employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    d) Pallet Repairing Area: An employee, Pallet Repairer, repairing broken pallets with a hammer, crowbar and a Tech PCN 670S-2 nail gun was exposed to continuous noise at 207.6% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 95.2 dBA.  This exposure was observed over a 455 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 25 minutes not sampled.  The employer did not provide multiple types of hearing protection for employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    Abatement certification required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Jan 11, 2013

Abate by

Feb 15, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 81108111

General-duty citation text

29 CFR 1910.95(k)(1):    The employer did not train each employee who is exposed to noise at or above an 8-hour time-weighted average of 85 decibels in accordance with the requirements of 29 CFR 1910.95(k):    a) Wood Cutting Area: An employee, Chop Saw Operator, cutting 2x4s with a chop saw was exposed to continuous noise at 417.6% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 100.3 dBA.  This exposure was observed over a 428 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 52 minutes not sampled.  The employer did not provide hearing conservation training to employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    b) Pallet Building Area: An employee, Pallet Builder, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 256.8% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 96.7 dBA.  These exposures were observed over a 444 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled.  The employer did not provide hearing conservation training to employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    c) Pallet Building Area: Two employees, Pallet Builders, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 213.7% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 95.4 dBA respectively.  These exposures were observed over a 465 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled.  The employer did not provide hearing conservation training to employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    d) Pallet Repairing Area: An employee, Pallet Repairer, repairing broken pallets with a hammer, crowbar and a Tech PCN 670S-2 nail gun was exposed to continuous noise at 207.6% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 95.2 dBA.  This exposure was observed over a 455 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 25 minutes not sampled.  The employer did not provide hearing conservation training to employees exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    Abatement certification required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Jan 11, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 81108111

General-duty citation text

29 CFR 1910.95(d)(1):     When information indicated that any employee's exposure equaled or exceed the 8-hour time-weighted average of 85 decibels, the employer did not develop and implement a monitoring program:    a) Wood Cutting Area: An employee, Chop Saw Operator, cutting 2x4s with a chop saw was exposed to continuous noise at 417.6% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 100.3 dBA.  This exposure was observed over a 428 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 52 minutes not sampled.  The employer did not develop and implement a monitoring program for employees that have a potential to be exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    b) Pallet Building Area: An employee, Pallet Builder, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 256.8% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 96.7 dBA.  These exposures were observed over a 444 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled. The employer did not develop and implement a monitoring program for employees that have a potential to be exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    c) Pallet Building Area: Two employees, Pallet Builders, using Tech PCN 670S-2 nail guns to build wooden pallets were exposed to continuous noise at 213.7% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 95.4 dBA respectively.  These exposures were observed over a 465 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 36 minutes and 15 minutes not sampled.  The employer did not develop and implement a monitoring program for employees that have a potential to be exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    d) Pallet Repairing Area: An employee, Pallet Repairer, repairing broken pallets with a hammer, crowbar and a Tech PCN 670S-2 nail gun was exposed to continuous noise at 207.6% of the permissible exposure limit (PEL) of 90 dBA or an eight-hour time-weighted average (TWA) of 95.2 dBA.  This exposure was observed over a 455 minute sampling period on October 2, 2012.  Zero exposure was assumed for the 25 minutes not sampled.  The employer did not develop and implement a monitoring program for employees that have a potential to be exposed to 50% of the PEL or an eight-hour TWA of 85 dBA, on or about October 2, 2012.    No abatement certification or documentation required.