OSHA Inspection: RONALD L JONES FUNERAL CHAPELS

Issued

Jan 31, 2013

Abate by

May 1, 2013

Penalty

Initial $2,000 · Current $1,400 Reduced

General-duty citation text

29 CFR 1910.1048(c)(2)  Employees were exposed to an airborne concentration of formaldehyde which exceeded two parts per million as a 15-minute short term exposure limit (STEL):  For the embalmer who was exposed to formaldehyde at an exposure level of 5.5 ppm for a short term exposure limit (STEL) who was sampled for 15 minutes on 12/07/2012.  The employee was embalming an adult autopsy client.

Issued

Jan 31, 2013

Abate by

Jun 13, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1048(f)(1)  Engineering controls and work practices were not instituted to reduce and maintain employee exposures to formaldehyde at or below the TWA and the STEL:  For the embalmer who was exposed to formaldehyde at an exposure level of 5.5 ppm for a short term exposure limit (STEL) who was sampled for 15 minutes on 12/07/2012.  The employee was embalming an adult autopsy client.  This exposure was approximately 2.75 times the Short Term Exposure Limit (STEL) of 2 ppm.     The short term exposure limit (STEL) was in excess of the OSHA Short Term Exposure LImit of 2 ppm and work practices and engineering controls had not been implemented to reduce the exposure below the STEL, including, but not necessarily limited to:                a) Local exhaust ventilation (LEV) for the embalming table.   DHHS (NIOSH) Publication No. 98-149, Controlling Formaldehyde Exposures During Embalming, October 1998, describes a LEV system which consists of a pair of 6-ft long slot hoods placed on each side of the embalming table  These slot hoods capture formaldehyde by means of an exhaust fan placed outside the embalming room.  The exhaust fan maintains an optimum airflow of 700 cubic feet per minute.  For a slot width of 1 inch, the slot velocity is 720 feet per minute.  Embalming equipment manufacturers and distributors can provide LEV systems for existing tables, or a sheet metal contractor can custom build the LEV system.      General room (dilution) ventilation is another way to exhaust formaldehyde from the embalming room.  Depending on how well the air in a room is mixed, 4 to 13 times more exhaust air is needed to achieve the same control as from the LEV system.  Make-up air costs for heating or cooling are considerably less for the LEV system than for dilution ventilation.  Therefore, NIOSH recommends that the primary control be the LEV system.    b)  Substitution of Postene gel    STEPS WILL BE AS FOLLOWS:    STEP 1:  EFFECTIVE RESPIRATORY PROTECTION SHALL BE PROVIDED AND USED BY EXPOSED EMPLOYEE(S) AS AN INTERIM PROTECTIVE MEASURE UNTIL FEASIBLE ENGINEERING CONTROLS CAN BE IMPLEMENTED, OR WHENEVER SUCH CONTROLS FAIL TO REDUCE EMPLOYEE EXPOSURE TO WITHIN PERMISSIBLE EXPOSURE LIMITS.    STEP 2:  SUBMIT TO THE AREA DIRECTOR A WRITTEN DETAILED PLAN OF ABATEMENT OUTLINING A SCHEDULE FOR THE IMPLEMENTATION OF ENGINEERING MEASURES TO CONTROL EMPLOYEE EXPOSURE TO HAZARDOUS SUBSTANCES AS REFERENCED IN THIS CITATION.  THIS PLAN SHALL INCLUDE, AT A MINIMUM, TARGET DATES FOR THE FOLLOWING ACTIONS WHICH MUST BE CONSISTENT WITH THE ABATEMENT DATES REQUIRED BY THIS CITATION:           (1)  EVALUATION OF ENGINEERING CONTROL OPTIONS:         (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.    NOTE:  ALL PROPOSED CONTROL MEASURES SHALL BE APRROVED FOR EACH PARTICULAR USE BY A COMPETENT INDUSTRIAL HYGIENIST OR OTHER TECHNICALLY QUALIFIED PERSON.  THIRTY (30) DAY PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD.    STEP 3:  ABATEMENT SHALL HAVE BEEN COMPLETED BY THE IMPLEMENTATION OF FEASIBLE ENGINEERING CONTROLS UPON VERIFICATION OF THEIR EFFECTIVENESS IN ACHIEVING COMPLIANCE.

Issued

Jan 31, 2013

Abate by

May 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1048(g)(2)(i)  The employer did not implement a respiratory protection program in accordance with 29 CFR 1910.134(b) through (d) (except (d)(1)(iii), (d)(3)(iii)(B)(1), and (d)(2)) and (f) through (m), which covers each employee required by 29 CFR 1910.1048 to use a respirator:  For the embalmer who was exposed to formaldehyde at an exposure level of 5.5 ppm for a short term exposure limit (STEL) who was sampled for 15 minutes on 12/07/2012.  The employee was embalming an adult autopsy client.  The embalmer wore an AO Safety 1/2 face negative pressure respirator with formaldehyde cartridges.  The employer had not implemented a respiratory protection program, including but not limited to a written program, medical surveillance, fit-testing and training.

Issued

Jan 31, 2013

Abate by

May 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1048(g)(2)(ii)(A)  When air-purifying chemical-cartridge respirators were used, the employer did not replace the cartridge after three hours of use or at the end of the workshift, whichever occurs first:  For the embalmer who wore an AO Safety 1/2 face negative pressure respirator with AO Safety formaldehyde cartridges on 12/5/12 and 12/7/12.   The employer did not ensure that these cartridges were replaced after three hours of use or at the end of the workshift, whichever occurred first.

Issued

Jan 31, 2013

Abate by

May 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1048(g)(3)(ii)  The employer substituted an air-purifying, half mask respirator for an air-purifying, full facepiece respirator equipped with a cartridge approved for protection against formaldehyde and did not provide the affected employees with effective gas-proof goggles:  For the embalmer who wore an AO Safety 1/2 face negative pressure respirator with AO Safety formaldehyde cartridges on 12/5/12 and 12/7/12, without effective gas-proof goggles.

Issued

Jan 31, 2013

Abate by

May 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1048(l)(1)(i)  The employer did not a institute medical surveillance programs for all employees exposed to formaldehyde at concentrations at or exceeding the action level or exceeding the STEL:  For the embalmer who was sampled for 15 minutes on 12/07/12 and was exposed to formaldehyde at an exposure level of 5.5 ppm for a short term exposure limit (STEL), which is approximately 2.75 times the 15-minute STEL.  The employee was embalming an adult autopsy client.

Issued

Jan 31, 2013

Abate by

May 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1048(o)(1)  The employer did not establish and maintain an accurate record of all measurements taken to monitor employee exposure to formaldehyde  The employer did not ensure that an accurate record of sampling measurements taken to monitor employee exposure to formaldehyde during embalming procedures was maintained.

Issued

Jan 31, 2013

Abate by

May 1, 2013

Penalty

Initial $1,200 · Current $840 Reduced

General-duty citation text

29 CFR 1910.1048(h)  The employer did not comply with the provisions of 29 CFR 1910.132 and/or 29 CFR 1910.133:    The employer did not have a written personal protective equipment hazard assessment and enforce the use of personal protective equipment, including but not limited to the following:   a. Use of chemical safety goggles  b. Changing gloves according to manufacturer's recommendations for permeation protection to formaldehyde

Issued

Jan 31, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1048(i)(3)  When there was a possibility that an employee's eyes could be splashed with solutions containing 0.1 percent or greater formaldehyde, the employer did not provide acceptable eyewash facilities within the immediate work area for emergency use:  At the time of the inspection, for the embalmer(s) who used chemicals containing formaldehyde, including but not limited to NeoBlitz (22% formaldehyde), and S.T. 39 (30% formaldehyde), a functional eyewash was not available for immediate emergency use.

Issued

Jan 31, 2013

Abate by

May 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1048(m)(5) The employer did not develop, implement, and maintain at the workplace, a written hazard communication program for formaldehyde exposures in the workplace:  For employees who used chemicals including but not limited to NEOBLITZ (22% formaldehyde), S.T. 39(30% formaldehyde), and Postene gel (18% formaldehyde), a hazard communication program including but not limited to a written program and training had not been implemented.

Issued

Jan 31, 2013

Abate by

May 1, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1030(c)(1)(i) The employer having employee(s) with occupational exposure did not establish a written Exposure Control Plan designed to eliminate or minimize employee exposure:  For embalmers who had occupational exposure to blood borne pathogens, the employer had not implemented a written exposure control plan.