OSHA Inspection: MICRON METAL FINISHING

Issued

Apr 23, 2013

Abate by

Jun 10, 2013

Penalty

Initial $4,200 · Current $2,100 Reduced

Hazardous substances 8110

General-duty citation text

29 CFR 1910.95(c)(1):  The employer shall administer a continuing, effective hearing conservation program, as described in paragraphs (c) through (o) of this section, whenever employee noise exposures equal or exceed an 8-hour time-weighted average sound level (TWA) of 85 decibels measured on the A scale (slow response) or, equivalently, a dose of fifty percent. For purposes of the hearing conservation program, employee noise exposures shall be computed in accordance with appendix A and Table G-16a, and without regard to any attenuation provided by the use of personal protective equipment.    a.  In the facility, an employee working in a powder coating booth was exposed to continuous noise levels at 154.8% of the permissible daily dose level, when measured with an 80 dBA threshold, or an average equivalent sound level of the approximately 93.1 dBA for the 459 minute sampling time on November 30, 2012.  Exposure calculation included a zero increment for the 21 minutes not sampled.      b.  In the facility, an employee working in a powder coating booth was exposed to continuous noise levels at 125.1% of the permissible daily dose level, when measured with an 80 dBA threshold, or an average equivalent sound level of the approximately 91.6 dBA for the 450 minute sampling time on November 30, 2012.  Exposure calculation included a zero increment for the 30 minutes not sampled.      c.  In the facility, an employee working in a powder coating booth was exposed to continuous noise levels at 125.1% of the permissible daily dose level, when measured with an 80 dBA threshold, or an average equivalent sound level of the approximately 91.6 dBA for the 468 minute sampling time on November 30, 2012.  Exposure calculation included a zero increment for the 12 minutes not sampled.

Issued

Apr 23, 2013

Abate by

Jun 10, 2013

Penalty

Initial $4,200 · Current $2,100 Reduced

General-duty citation text

29 CFR 1910.107(i)(5):  Spray gun ground. The handle of the spraying gun shall be electrically connected to ground by a metallic connection and to be so constructed that the operator in normal operating position is in intimate electrical contact with the grounded handle.    a.  On or about November 16, 2012, employees were required to work in the powder coating booth performing electrostatic hand spraying operations.  The employer failed to ensure that the spray gun was electrically connected to ground at all times to ensure that employees were not exposed to shock hazards.

Issued

Apr 23, 2013

Abate by

Apr 23, 2013

Penalty

Initial $0 · Current $2,450

General-duty citation text

29 CFR 1910.132(d)(2):  The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.    a.  On or about November 16, 2012, employees in the facility were required to wear personal protective equipment while performing job tasks.  The employer failed to develop a written certification which identified the person who certified the completion of the evaluation, the date(s) of the assessment and a complete hazard assessment.

Issued

Apr 23, 2013

Abate by

Apr 23, 2013

Penalty

Initial $0 · Current $0

Hazardous substances T405

General-duty citation text

29 CFR 1910.138(a): General requirements. Employers shall select and require employees to use appropriate hand protection when employees' hands are exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; thermal burns; and harmful temperature extremes.    a.  On or about November 16, 2012, in the powder coating booth, employees were required to work with hazardous chemicals, including but not limited to 1,3,5-triglycidyl isocyanurate.  The employer failed to provide an appropriate glove which provided some protection from skin contact while allowing for a continuous ground to be maintained when operating the electrostatic hand spraying equipment.

Issued

Apr 23, 2013

Abate by

Apr 23, 2013

Penalty

Initial $2,100 · Current $0 Reduced

General-duty citation text

29 CFR 1910.151(c): Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.    a.  On or about November 16, 2013 in the facility, employees were exposed to corrosive chemicals including, but not limited to phosphoric acid and were not provided with a safety shower or eye wash in the event of an exposure.

Issued

Apr 23, 2013

Abate by

Sep 4, 2013

Penalty

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

Hazardous substances 9135

General-duty citation text

29 CFR 1910.1000(a)(2): Employee(s) were exposed to an airborne concentration of particulates, not otherwise classified, listed in table Z-1-A (Transitional Limits column) in excess of 15 milligram per meter cubed as an 8 hour time weighted average concentration:    a.  On or about November 29, 2012, in the powder coating area, an employee was exposed to particulates, not otherwise classified, at an eight hour time weighted average of 75.3 milligrams per meter cubed.  This limit was established to prevent employees form suffering from adverse health effects such as cumulative lung damage.      b.  On or about November 29, 2012, in the powder coating area, an employee was exposed to particulates, not otherwise classified, at an eight hour time weighted average of 37.5 milligrams per meter cubed.  This limit was established to prevent employees form suffering from adverse health effects such as cumulative lung damage.

Issued

Apr 23, 2013

Abate by

Sep 4, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 9135

General-duty citation text

29 CFR 1910.1000(e): Feasible administrative or engineering controls were not determined and implemented to reduce employee exposure below the permissible exposure limit:  a. On or about November 29, 2012, in the facility, an employee performing electrostatic spray powder coating was exposed to airborne total dust at an 8 hour time weighted average of 75.3 milligrams per cubic meter (mg/m3), approximately 5 times the permissible exposure limit of 15 mg/m3 (8 hour TWA).  Feasible administrative or engineering controls were not determined and implemented to reduce employee exposure to below the permissible exposure limits.   b. On or about November 29, 2012, in the facility, an employee performing electrostatic spray powder coating was exposed to airborne total dust at an 8 hour time weighted average of 37.5 milligrams per cubic meter (mg/m3), approximately 2.5 times the permissible exposure limit of 15 mg/m3 (8 hour TWA).  Feasible administrative or engineering controls were not determined and implemented to reduce employee exposure to below the permissible exposure limits.    General methods of control that may be applicable to the process include, but are not limited to, the following: 1.   Employees should be positioned as far away from each other as possible in the booth during spraying.  Avoid having both employees facing each other during spraying as to avoid creating or adding to exposure. 2.  Ensure good maintenance controls of the powder spraying system to ensure efficiency of process by ensuring proper grounding of entire system including, but not limited to the parts being powder painted.  Proper grounding of parts shall increase the powder paint adherence and reduce overspray.   3.  Clothing, equipment and surfaces should be cleaned in such a manner as to avoid creating exposure from dust clouds. 4.  Develop and implement an employee job rotation schedule to reduce exposure levels by reducing exposure times to powders and dust.    Abatement normally will be multi-step as follows:  STEP 1:  Effective respiratory protection in accordance with 29 CFR 1910.134 shall be provided and used by exposed employees as an interim protective measure until feasible engineering and/or administrative controls can be implemented, or whenever such controls fail to reduce employee exposure to within permissible exposure limits  Abatement Period:  1 day  STEP 2:  Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposure to total dust.  The plan shall include, at minimum, target dates for the following actions which must be consistent with abatement dates required by this citations (abatement time  30 days).   (1) Evaluation of engineering/administrative 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 measure shall be approved 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.   Abatement period:  60 days  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 time: 90 days.

Issued

Apr 23, 2013

Abate by

Apr 23, 2013

Penalty

Initial $4,200 · Current $0 Reduced

Hazardous substances 9135

General-duty citation text

29 CFR 1910.134(c)(1): In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer shall establish and implement a written respiratory protection program with worksite-specific procedures. The program shall be updated as necessary to reflect those changes in workplace conditions that affect respirator use. The employer shall include in the program the following provisions of this section, as applicable:    a.  On or about November 29, 2012, in the facility, the employer did not have a written respiratory protection program in place when an employee was exposed to particulates not otherwise classified while operating electrostatic hand spraying equipment.  The employee was exposed to particulates not otherwise classified at an eight hour time weighted average of 75.3 milligrams per meter cubed, approximately 5 times the permissible exposure limit.  This limit was established to prevent employees form suffering from adverse health effects such as cumulative lung damage.      b.  On or about November 29, 2012, in the facility, the employer did not have a written respiratory protection program in place when an employee was exposed to particulates not otherwise classified while operating electrostatic hand spraying equipment.  The employee was exposed to particulates not otherwise classified at an eight hour time weighted average of 37.5 milligrams per meter cubed, approximately 2.5 times the permissible exposure limit.  This limit was established to prevent employees form suffering from adverse health effects such as cumulative lung damage.

Issued

Apr 23, 2013

Abate by

May 26, 2013

Penalty

Initial $4,200 · Current $2,100 Reduced

General-duty citation text

29 CFR 1910.1200(h)(1):  Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets.    a.  On or about November 16, 2012, in the facility, employees were required to work with hazardous chemicals including, but not limited to 1,3,5-triglycidyl isocyanurate and phosphoric acid.  The employer failed to provide employees with the required training to ensure they understood the hazards associated with the use of chemicals, proper labeling and location of materail safety data sheets.

Issued

Apr 23, 2013

Abate by

Jun 10, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(c)(1):  The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces. NOTE: Proper application of the decision flow chart in Appendix A to section 1910.146 would facilitate compliance with this requirement.    a.  On or about November 16, 2013, in the facility, the employer had not evaluated to determine if any spaces in the facility are permit required confined spaces.