OSHA Inspection: ALL SPUN METAL PRODUCTS, L.L.C.

Issued

Apr 11, 2013

Abate by

Oct 1, 2013

Penalty

Initial $2,400 · Current $1,440 Reduced

Hazardous substances 0730

General-duty citation text

29 CFR 1910.1000(a)(2):     Employee(s) were exposed to an airborne concentration of copper listed in Table Z-1 in excess of the 8-hour time weighted average concentration of 1 mg/m3:    a) On November 1, 2012, an employee performing annealing and spinning of copper Timpani kettles was exposed to an 8-hour time weighted average of 2.24 mg/m3 of copper, approximately 2.2 times the OSHA permissible exposure limit of 1.0 mg/m3.  The limit is established to prevent irritation of eyes, nose, and pharynx, nasal septum perforation, metallic taste, dermatitis, lung, liver, and kidney damage, and anemia.  The exposure level was established from two samples collected over a period of 262 minutes.  Zero exposure was assumed for the unsampled time of 218 minutes.

Issued

Apr 11, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 0730

General-duty citation text

29 CFR 1910.1000(e):   Feasible administrative or engineering controls were not determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):  a) Effective administrative or engineering controls were not determined and implemented by All Spun Metal Products LLC in the furnace room and spinning areas of the shop to reduce employee exposure to airborne copper below the OSHA permissible exposure limit (PEL) of 1.0 mg/m3, as an 8-hour time-weighted average (TWA).  An employee annealing Timpani kettles in the furnace room and spinning the kettles to completion in the shop was exposed to airborne copper in excess of the PEL.  See instance description in item 1a of this citation.  Methods of controls 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 the existing controls (non-powered canopy hood over annealing furnace, roof mounted exhaust fan in furnace room, pedestal floor fans, and open windows and door), provide recommendations to improve the existing controls to reduce employee exposures, economically prioritize recommendations, and prepare design documentation for the successful installation of recommended equipment or modifications.  2) Perform annealing in a controlled atmosphere furnace that would inhibit oxidation on the kettle surfaces. These are typically reducing environments that shield surfaces from oxidation. Carbon monoxide and hydrogen are typical reducing gasses that would comprise the controlled atmosphere in the furnace. In addition, the annealing may be performed under a vacuum (i.e., no oxygen).  Note: Modification of the existing furnace for controlled environment annealing is unlikely. Purchasing a new or used controlled environment annealing furnace or outsourcing kettle annealing may be feasible alternative(s).   3) Eliminate the use of compressed air for cleaning.  Substitute vacuuming for sweeping and brushing whenever possible. Vacuums should have HEPA filtration of discharge. This should include vacuuming for housekeeping and vacuuming for process cleaning.  4) Provide local exhaust ventilation during any disturbance of loose copper oxide scale.  For example, if kettle scale is brushed or vacuumed it should be performed on a downdraft table with total hood flow rate capacity sized by Q=150-250 cubic feet per minute per square foot of table area.  If the copper oxide scale is disturbed with a hand-held rotating wheel tool then a more robust response would be required such as placing the kettle in an enclosing hood, or ventilated cabinet with total flow rate capacity sized by Q=250 cubic feet per minute per square foot of open face area.  5) Eliminate the work practice of slapping the cleaning abrasive pads on the kettle by the spinner operator(s).  The pads should be discarded when they load up rather than cleaned and reused. In addition, the employer should use pads impregnated with a lubricant which would retain the oxide dust while cleaning the spinning drum bowl.  6) Perform a single housekeeping event to remove accumulated copper oxide dust from all horizontal surfaces in the facility and supplement with periodic and/or end of shift cleaning.    ABATEMENT NOTE:  STEP 1:  Effective respiratory protection shall be used by the affected employee(s) as an interim measure.  The use of respiratory protection must include the implementation of a respiratory protection program which meets the requirements of 29 CFR 1910.134.  Abatement Date:  May 2, 2013  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 copper 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/administrative controls; (2) Selection of optimum control methods and completion of design; (3) Procurement, installation and operation of selected control measures; and (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.  45 day (calendar days) progress reports are required during the abatement period.  Abatement Date:  June 14, 2013  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.  Abatement Date:  October 1, 2013

Issued

Apr 11, 2013

Abate by

May 7, 2013

Penalty

Initial $2,000 · Current $1,200 Reduced

Hazardous substances 0730

General-duty citation text

29 CFR 1910.1200(g)(1):   The employer did not have a material safety data sheet for each hazardous chemical in use:  a) All Spun Metal Products, LLC did not maintain copies of material safety data sheets for each hazardous chemical used in the workplace, including copper and Mobil Mobilube HD Plus Gear Oil 80W-90 (contains olefin sulfide).

Issued

Apr 11, 2013

Abate by

May 7, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 0730

General-duty citation text

29 CFR 1910.1200(h)(1):     Employees were not provided effective information and training as specified in 29 CFR 1910.1200(h)(1) and (2) on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard that the employees had not been previously trained about was introduced into their work area:    a) All Spun Metal Products, LLC did not provide information and training to employees exposed to hazardous chemical used in the workplace, including copper and Mobil Mobilube HD Plus Gear Oil 80W-90 (contains olefin sulfide).

Issued

Apr 11, 2013

Abate by

May 7, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 0730

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:  a) On November 1, 2011, an employee who voluntarily wore a Moldex 2310 N99 particulate respirator while performing annealing and spinning tasks was not provided with the basic advisory information on respirators, as presented in Appendix D of 29 CFR 1910.134.

Issued

Apr 11, 2013

Abate by

May 7, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(e)(1)(i):     The written hazard communication program did not include a list of the hazardous chemicals known to be present, using an identity that was referenced on the appropriate material safety data sheet:    a) All Spun Metal Products, LLC did not ensure that the written hazard communication program included a list of the hazardous chemicals, including copper and Mobil Mobilube HD Plus Gear Oil 80W-90, known to present in the workplace.