OSHA Inspection: SULLIVAN PRECISION METAL FINISHING

Issued

Jan 17, 2013

Abate by

Jul 1, 2013

Penalty

Initial $1,785 · Current $893 Reduced

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. Where high noise levels existed near the passivation line where parts were blown off with hand held air lines, and in paint booths, and where elevated noise levels existed in other areas, such as during abrasive blasting; noise monitoring was not conducted to determine required use of hearing protection and to establish a hearing conservation program, including annual hearing tests and training.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $2,380 · Current $1,190 Reduced

General-duty citation text

29 CFR 1910.94(a)(5)(ii)(a):     Abrasive-blasting respirators were not worn when working inside of a blasting cleaning room:    a. A half mask, negative pressure, cartridge respirator (with an amine cartridge not applicable to abrasive blasting) was worn during abrasive blasting; an abrasive blasting respirator was not used at all times when abrasive blasting.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

May 10, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.244(b):     Abrasive blast cleaning nozzle(s) were not equipped with an operating valve which had to be held open manually:    a. The abrasive blasting hand control, used in the blasting trailer, was not provided with a valve which had to be held open manually.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $2,975 · Current $1,488 Reduced

General-duty citation text

29 CFR 1910.106(d)(3)(ii):     Storage cabinet(s) for flammable and combustible liquids were not designed or constructed to meet minimal fire resistance as required:    a. The flammable safety cabinet used to store 55 gal. drums of toluene was not fitted with covers on the vent openings; therefore not "made tight" according to the standard.    b. Two flammable safety cabinets used to store 55 gal. drums of MEK were not fitted with covers on the vent openings;    c. The flammable safety cabinet in the magnetic particle room, used to store a flammable liquid, was not fitted with a cover on the vent opening.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.106(e)(2)(iv)(a):     Flammable liquids were not kept in covered containers when not in use:    a. A bung opening in one of two 55 gal. drums of tolune, stored in a flammable safety cabinet, near the sanding room, was left open (for draining the pump hose);    b. An open container of flammable liquid (thinner or MEK) on a table between spray booths #2 and #3 was used to clean parts;    c. A part protruded from a safety can with a flammable liquid (thinner or MEK) on a table between spray booths #1 and #2, allowing an opening of the lid.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.106(e)(6)(i):     Adequate precautions were not taken to prevent the ignition of flammable vapors:    a. The ground clamp/wire to one of two 55 gal. drums of toluene stored in a flammable safety cabinet, near the sanding room, was not attached to the drum.    b. A flammable liquid drum in the spray paint mix room was improperly grounded to a water pipe.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.106(e)(6)(ii):     Class I liquids were  dispensed into containers without the nozzle and container electrically interconnected:    a. Instances existed where bonding, from 55 gal. drums of flammable liquid to the container being transered to, was not made.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.157(c)(1):     Portable fire extinguishers were not mounted, located and identified so that they were readily accessible without subjecting the employees to injuries:    a. Outside the sanding & scuffing room, a portable fire extinguisher was blocked by drums setting on a pallet.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.157(e)(2):     Portable fire extinguishers were not visually inspected at least monthly:    a. A monthly check of portable fire extinguishers was not yet implemented.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.157(g)(1):     An educational program was not provided for all employees to familiarize them with the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting:    a. A training program was not yet established and implemented for intial and annual training on portable fire extinguisher use for incipient stage fires (note: hands on training is required).    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Jun 19, 2013

Penalty

Initial $2,975 · Current $1,488 Reduced

General-duty citation text

29 CFR 1910.120(q)(1):     The employer did not develop and implement an emergency response plan (according to the hazardous waste operations and emergency response standard) to handle anticipated emergencies prior to commencement of emergency response operations:    a. Where flammable liquids, chemicals with corrosive properties, some with extremely corrosive hazards, and chemical products with compatibility hazards, including hydrofluoric acid, other mineral acids, glacial acetic acid, and oxidizers, were stored in bulk (55 gal. drums stored in three separate storage areas, including the waste water treatement area), a chemical emergency action plan ("Haz Mat") to control the potential release of chemicals and subsequent response if a release did occur, was not established and implemented.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Jun 19, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.120(q)(6)(iii):     Employees who participated as hazardous materials technicians, or were expected to participate as hazardous materials technicians, had not received at least 24 hours of training equal to the first responder operations level, and in addition have competency in the areas outlined in 29 CFR 1910.120(q)(6)(iii)(A) through (q)(6)(iii)(I) and/or the employer did not so certify:    a. Where flammable liquids, chemicals with corrosive properties, some with extremely corrosive hazards, and chemical products with compatibility hazards, including hydrofluoric acid, other mineral acids, glacial acetic acid, and oxidizers, were stored in bulk (55 gal. drums stored in three separate storage areas, including the waste water treatement area), employees (as applicable) did not receive the required training.     Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.124(h)(4):     Employees working with chromic acid were not provided with periodic examinations of their exposed body parts, especially their nostrils:    a. Employees exposed to chromic acid when working on the tank lines, were not provided a periodic examination.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

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:    a. Where dip tanks have previously been entered, which may be permit required confined spaces, and where other permit required confined spaces were present, such as in the wastewater treatment room, a confined space program was not developed, implemented, and written (note: the standard must be complied with, but only those sections that would be applicable).    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Jul 1, 2013

Penalty

Initial $0 · Current $0

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:    a. During spraying of paints containing hexavalent chromium, employees were exposed to levels of 0.37 and 0.0636 milligrams per cubic meter exceeding the permissible exposure limit of 0.005 by 74 and 12 times respectively.  A respriatory protection program was not established and the 0.37 level exceeded the maximum use concentration (see related citation; 1910.134(d)(3)(i)(B)).    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

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. During spraying of paints containing hexavalent chromium, where employees were exposed to levels of 0.37 and 0.0636 milligrams per cubic meter exceeding the permissible exposure limit of 0.005 by 74 and 12 times respectively, a regulated area was not established.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1026(i)(5):     The employer did not ensure that employees did not eat, drink, smoke, chew tobacco or gum, or apply cosmetics in regulated areas:    a. During spraying of paints containing hexavalent chromium, where employees were exposed to levels of 0.37 and 0.0636 milligrams per cubic meter exceeding the permissible exposure limit of 0.005 by 74 and 12 times respectively, employees were not prohibited from drinks in the spray booth preparation area.      Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1026(k)(1)(i):     The employer did not make medical surveillance for chromium (VI) exposures available at no cost to the employees, and/or at a reasonable time and place:    a. During spraying of paints containing hexavalent chromium, where employees were exposed to levels of 0.37 and 0.0636 milligrams per cubic meter exceeding the permissible exposure limit of 0.005 by 74 and 12 times respectively, a medical surveillance program was not established for employees.      Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1026(l)(2)(i):     The employer did not ensure that each employee could demonstate knowledge of at least he contents of this seciton and the purpose and a description of the medical surveillance program required by paragraph (k) of this section:    a. During spraying of paints containing hexavalent chromium, where employees were exposed to levels of 0.37 and 0.0636 milligrams per cubic meter exceeding the permissible exposure limit of 0.005 by 74 and 12 times respectively, information and training on hexavalent chromium was not provided (note: this is in addition to the training required byh the chemical hazard communication standard (1910.1200)).    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1052(d)(1)(i):     Where methylene chloride was present in the workplace, the employer did not determine each employee's exposure:    a. In the large paint booth spray room, employees used a methylene chloride containing product to strip paint; exposure monitioring was not conducted in order to determine the need for compliance with the standard, 1910.1052.  (Note: this product was said to have been incorrectly received and used.  The product use has been discontinued.)

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h):     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 was introduced in their area:    a. Not all employees were trained on chemical hazard communication, including the specific health and physical hazards of the chemicals used and their exposure, what controls were to be used to reduce exposure, that all containers were to be kept labeled, incompatibility of container storage, and review of applicable material safety data sheets and providing an index so that data sheets could be readily retrieved.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $1,785 · Current $893 Reduced

General-duty citation text

29 CFR 1910.132(d)(2):     The employer did not verify, through a written certification, that the required workplace hazard assessment had been performed:    a. Where corrosives, flammable solvents, and other chemical products were used a personal protective equipment hazard assessment, according to the requirements of the standard, was not certified.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.132(f)(4):     The employer did not verify, that each affected employee received and understood the required training through a written certification, that included the name of each employee, the date of training, and the subject of the training:     a. Where corrosives, flammable solvents, and other chemical products were used personal protective equipment training was not certified.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.151(c):     Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:    a. Where corrosives, and other chemical products were used, such as on the 32 ft. tank line, an eye wash was missing a handle.    b. Where corrosives were used, not all eye washes were checked at least monthly.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $2,975 · Current $1,488 Reduced

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:    a. Where solvent based paints were used during spray painting, abrasive blasting was conducted, including direct exposure to the employee and within enclosed cabinets, and supplied air, half mask, negative pressure cartridge, and single use, disposable respirators were provided, a current and applicable respiratory protection program was not developed and implemented and in writing.  Defeciencies in the use of respriators at the worksite included:     i. Incorrect fit testing (at least one employee was not fit tested with the correct respirator);     ii. Incomplete respirator fit test/training documentation;     iii. Medical evaluation not provided before the use of negative pressure respirators;     iv. No maintenance of supplied air respirator filtration;     v. No carbon monoxide alarm for supplied air respirator air supply;     vi. No competent person assigned to oversee and evaluate respiratory protection;     vii. Incorrect cartridge used for abrasive blasting (although negative pressure respirators can only be used in a very limited manner for work involving abrasive blasting (see 1910.94(a)(5))     viii. Incorrect use of a single use, disposable respirator with exposure to CEE-BEE A-202 epoxy stripper.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(d)(3)(i)(B):     The employer did not select a respirator for employee use that miantained the employee's expousre to the hazardous substnace, when measured outside the rspirator, at or below the MUC (maximum use concentration):    a. During spraying of paints containing hexavalent chromium, employees were exposed to levels of 0.37 and 0.0636 milligrams per cubic meter exceeding the permissible exposure limit of 0.005 by 74 and 12 times respectively.  Half mask, cartridge respirators, which have a maximum use concentration of 0.05 milligrams per cubic meter, were used during spraying.      Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $1,785 · Current $893 Reduced

General-duty citation text

29 CFR 1910.178(q)(1):     Any power-operated industrial truck not in safe operating condition was not taken out of service, and/or repairs were not made by authorized personnel:    a. Both propane tank straps were in disrepair (not attached) on the Komatsu G30S forklift.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Jan 17, 2013

Abate by

Apr 18, 2013

Penalty

Initial $1,785 · Current $893 Reduced

General-duty citation text

29 CFR 1910.304(g)(5):     The path to ground from circuits, equipment, and enclosures was not permanent, continuous, and effective:    a. Power cords were missing ground pins, such as, but not limited to, a fluorescent light on the 32 foot tank line where the ground pin was broken and a cooling fan, also on the 32 foot tank line.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).