OSHA Inspection: MEDPRO IMAGING PROBE LABS LLC

Issued

2013-02-26 00:00:00

Abate by

2013-05-30 00:00:00

Penalty

Initial $1360.00 · Current $1360.00

Hazardous substances 1538

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to an isophorone inhalation hazard:    (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to an isophorone inhalation hazard.  One employee used Markem-imaje V Thinner (containing isophorone) when silk screening ultrasound probes.  On 1/10/13 one employee silk screening ultrasound probes was exposed to isophorone at a concentration greater than the ACGIH Ceiling Limit of 5 ppm.  The employee was exposed to isophorone at a concentration of 40.1 ppm.  This is 8.0 times the Ceiling Limit.  Air monitoring was conducted for 55 minutes.  This condition exposed the employee to a respiratory hazard.    Abatement Note:  Abatement of this item will normally be multi-step as follows:    1. Effective respiratory protection 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 exposure limits.    STEP 1 ABATEMENT DATE (15 DAYS):     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 exposures to the hazardous substance referenced in this citation.  The plan shall include, at a minimum, target dates for the following actions which should be consistent with the dates required by this citation:  a. Evaluation of the extent and location of the hazard source;  b. Evaluation of control measure options;  c. Selection of optimum control measures;  d. Determination of control measure design;  e. Ordering and delivery of equipment;  f. Installation of control measures;  g. Training of employees in proper operation and maintenance of newly implemented control measures; and  h. Assurance of the effective performance of control measures.    All proposed control measures shall be evaluated for each particular use by a competent Industrial Hygienist or other technically qualified person.  Thirty day progress reports are required during the abatement period.  The progress report must identify the action taken to achieve abatement and the date the action was taken.    STEP 2 ABATEMENT DATE (30 DAYS):     3. Abatement will be completed by the implementation of feasible engineering and/or administrative controls and upon verification of their effectiveness in achieving compliance.    STEP 3 ABATEMENT DATE (90 DAYS):

Issued

2013-02-26 00:00:00

Abate by

2013-03-16 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.134(c)(1): The employer did not establish and maintain a written respiratory protection program, as specified in subparagraphs (c)(1)(i) through (ix), in that employees were required to wear respirators during work operations:    (a)  MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/10/13, MedPro Imaging Probe Labs LLC did not establish and maintain a written respiratory protection program, as specified in subparagraphs (c)(1)(i) through (ix), in that employees were required to wear respirators during work operations.  One employee used Markem-imaje V Thinner (containing isophorone) when silk screening ultrasound probes.  This employee also used Sherwin Williams Polane Reducer K84 (containing toluene, n-butyl acetate, and isopropyl acetate) and PPG Industries DCX61 High Solids Hardener (containing hexamethylene diisocyanate and isophorone diisocyanate) to recoat ultrasound probes.  The reactants were mixed to form polyurethane and then poured onto the ultrasound probes.  On 1/10/13 one employee silk screening ultrasound probes was exposed to isophorone at a concentration greater than the ACGIH Ceiling Limit of 5 ppm.  The employee was exposed to isophorone at a concentration of 40.1 ppm.  This is 8.0 times the Ceiling Limit.  Air monitoring was conducted for 55 minutes.  The employer did not establish and maintain a written respiratory protection program.  This condition exposed the employee to a respiratory hazard.

Issued

2013-02-26 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer did not identify and evaluate the respiratory hazard in the workplace:    (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not identify and evaluate the respiratory hazard in the workplace.  One employee used Markem-imaje V Thinner (containing isophorone) when silk screening ultrasound probes.  The employer did not evaluate employee exposure to isophorone.  This condition exposed the employee to a respiratory hazard.    (b) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not identify and evaluate the respiratory hazard in the workplace.  One employee used Sherwin Williams Polane Reducer K84 (containing toluene, n-butyl acetate, and isopropyl acetate) and PPG Industries DCX61 High Solids Hardener (containing hexamethylene diisocyanate and isophorone diisocyanate) to recoat ultrasound probes.  The reactants were mixed to form polyurethane and then poured onto the ultrasound probes.  The employer did not evaluate employee exposure to the isocyanates.  This condition potentially exposed the employee to a respiratory hazard.    (c) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not identify and evaluate the respiratory hazard in the workplace.  One employee used Sherwin Williams Polane Reducer K84 (containing toluene, n-butyl acetate, and isopropyl acetate) and PPG Industries DCX61 High Solids Hardener (containing hexamethylene diisocyanate and isophorone diisocyanate) to recoat ultrasound probes.  The employer did not evaluate employee exposure to n-butyl acetate.  This condition potentially exposed the employee to a respiratory hazard.

Issued

2013-02-26 00:00:00

Abate by

2013-04-01 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee was fit tested, or required to use the respirator in the workplace:    (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/10/13, MedPro Imaging Probe Labs LLC did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee was fit tested, or required to use the respirator in the workplace.  One employee used Markem-imaje V Thinner (containing isophorone) when silk screening ultrasound probes.  This employee also used Sherwin Williams Polane Reducer K84 (containing toluene, n-butyl acetate, and isopropyl acetate) and PPG Industries DCX61 High Solids Hardener (containing hexamethylene diisocyanate and isophorone diisocyanate) to recoat ultrasound probes.  The reactants were mixed to form polyurethane and then poured onto the ultrasound probes.  On 1/10/13 one employee silk screening ultrasound probes was exposed to isophorone at a concentration greater than the ACGIH Ceiling Limit of 5 ppm.  The employee was exposed to isophorone at a concentration of 40.1 ppm.  This is 8.0 times the Ceiling Limit.  Air monitoring was conducted for 55 minutes.  The employee was required to wear a North 5400 tight fitting air purifying full facepiece respirator with OV/P100 cartridges and previously had worn a Sperian 100300 tight fitting air purifying half mask respirator with OV cartridges.  The employer did not provide a medical evaluation.  This condition exposed the employee to a respiratory hazard.

Issued

2013-02-26 00:00:00

Abate by

2013-04-01 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.134(f)(2): The employer did not ensure that employees using a tight-fitting facepiece respirator were fit tested prior to initial use of the respirator, whenever a different respirator facepiece was used, and at least annually thereafter:    (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On 1/10/13, MedPro Imaging Probe Labs LLC did not ensure that employees using a tight-fitting facepiece respirator were fit tested prior to initial use of the respirator, whenever a different respirator facepiece was used, and at least annually thereafter.  One employee used Markem-imaje V Thinner (containing isophorone) when silk screening ultrasound probes.  On 1/10/13 one employee silk screening ultrasound probes was exposed to isophorone at a concentration greater than the ACGIH Ceiling Limit of 5 ppm.  The employee was exposed to isophorone at a concentration of 40.1 ppm.  This is 8.0 times the Ceiling Limit.  Air monitoring was conducted for 55 minutes.  The employee was required to wear a North 5400 tight fitting air purifying full facepiece respirator with OV/P100 cartridges and previously had worn a Sperian 100300 tight fitting air purifying half mask respirator with OV cartridges.  The employer did not ensure that the employee was fit tested with either respirator.  This condition exposed the employee to a respiratory hazard.

Issued

2013-02-26 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.134(h)(2)(i): The employer did not ensure that all respirators were stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and that all respirators were packed or stored to prevent deformation of the facepiece and exhalation valve:    (a)  MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not ensure that all respirators were stored to protect them from contamination and that all respirators were packed or stored to prevent deformation of the facepiece and exhalation valve.  One employee used a Sperian model 100300 tight fitting air purifying half mask respirator with OV cartridges when using chemicals in the recoating room.  The respirator was stored in the open, hanging from a wall hook, adjacent to the cabinet where chemicals were stored.  The employer did not ensure that the respirator was stored where it would not be contaminated or damaged.  This condition exposed the employee to a respiratory hazard.

Issued

2013-02-26 00:00:00

Abate by

2013-04-01 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.134(k)(1): The employer did not provide effective, comprehensive, understandable, annual respirator training to employees who are required to use respirators:    (a)  MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/10/13, MedPro Imaging Probe Labs LLC did not provide effective, comprehensive, understandable, annual respirator training to employees who are required to use respirators.  One employee used Markem-imaje V Thinner (containing isophorone) when silk screening probes.  This employee also used Sherwin Williams Polane Reducer K84 (containing toluene, n-butyl acetate, and isopropyl acetate) and PPG Industries DCX61 High Solids Hardener (containing hexamethylene diisocyanate and isophorone diisocyanate) to recoat ultrasound probes.  The reactants were mixed to form polyurethane and then poured onto the ultrasound probes.  On 1/10/13 one employee silk screening ultrasound probes was exposed to isophorone at a concentration greater than the ACGIH Ceiling Limit of 5 ppm.  The employee was exposed to isophorone at a concentration of 40.1 ppm.  This is 8.0 times the Ceiling Limit.  Air monitoring was conducted for 55 minutes.  The employee was required to wear a North 5400 tight fitting air purifying full facepiece respirator with OV/P100 cartridges and previously had worn a Sperian 100300 tight fitting air purifying half mask respirator with OV cartridges.  The employer did not provide comprehensive annual respirator training.  This condition exposed the employee to a respiratory hazard.

Issued

2013-02-26 00:00:00

Abate by

2013-03-31 00:00:00

Penalty

Initial $1360.00 · Current $680.00 Reduced

General-duty citation text

29 CFR 1910.133(a)(1): The employer did not ensure that each affected employee use appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation:     (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not ensure that each affected employee use appropriate eye or face protection when exposed to eye or face hazards from liquid chemicals.  One employee recoated ultrasound probes with polyurethane.  The employee used Sherwin Williams Polane Reducer K84 (containing toluene, n-butyl acetate, and isopropyl acetate) and PPG Industries DCX61 High Solids Hardener (containing hexamethylene diisocyanate and isophorone diisocyanate) to form the polyurethane.  The isocyanates are corrosive liquids.  The employee did not use protective eyewear while mixing or pouring the chemicals.  The employer did not ensure that protective equipment was used.  This condition exposed the employee to a chemical hazard.    (b) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not ensure that each affected employee use appropriate eye or face protection when exposed to eye or face hazards from flying particles or molten metal.  Three employees repaired ultrasound probes.  The employees did not use protective eyewear while soldering or repairing the ultrasound probes.  The employer did not ensure that protective eyewear was used.  This condition exposed the employees to a flying object hazard.    (c) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not ensure that each affected employee use appropriate eye or face protection when exposed to eye or face hazards from liquid chemicals.  One employee silk screened ultrasound probes.  The employee used Markem-imaje 300 Cleaner (containing acetone, 2-propanol, and ethyl acetate), Markem-imaje V Thinner (containing isophorone), and 2-propanol when silk screening or cleaning.  The employee did not use protective eyewear while using the chemicals.  The employer did not ensure that protective eyewear was used.  This condition exposed the employee to a chemical hazard.

Issued

2013-02-26 00:00:00

Abate by

2013-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.138(a):  The employer did not select and require employee(s) to use appropriate hand protection when employees' hands were 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) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not select and require employees to use appropriate hand protection when employees' hands were exposed to hazards such as those from skin absorption of harmful substances.  One employee recoated ultrasound probes with polyurethane.  The employee used Sherwin Williams Polane Reducer K84 (containing toluene, n-butyl acetate, and isopropyl acetate) and PPG Industries DCX61 High Solids Hardener (containing hexamethylene diisocyanate and isophorone diisocyanate) to form the polyurethane.  The isocyanates are corrosive liquids.  The employee did not use protective gloves while mixing or pouring the chemicals.  The employer did not ensure that appropriate gloves were used.  This condition exposed the employee to a chemical hazard.    (b) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not select and require employees to use appropriate hand protection when employees' hands were exposed to hazards such as those from skin absorption of harmful substances.  One employee silk screened ultrasound probes.  The employee used Markem-imaje 300 Cleaner (containing acetone, 2-propanol, and ethyl acetate), Markem-imaje V Thinner (containing isophorone), and 2-propanol when silk screening or cleaning.  The employee did not use protective gloves while using the chemicals.  The employer did not ensure that appropriate gloves were used.  This condition exposed the employee to a chemical hazard.

Issued

2013-02-26 00:00:00

Abate by

2013-03-31 00:00:00

Penalty

Initial $1360.00 · Current $680.00 Reduced

General-duty citation text

29 CFR 1910.1200(e)(1): Employer had not developed or implemented a written hazard communication program which at least describes how the criteria in 29 CFR 1910.1200(f), (g) and (h) will be met:    (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC had not developed or implemented a written hazard communication program which at least describes how the criteria in 29 CFR 1910.1200(f), (g) and (h) will be met.  Hazardous chemicals located in the workplace included, but are not limited to the following:    1.  Kester Rosin Core solder (containing 37% lead);  2.  2-propanol;  3.  Sherwin Williams Polane Reducer K84 (containing toluene, n-butyl acetate, and isopropyl acetate);  4.  PPG Industries DCX61 High Solids Hardener (containing hexamethylene diisocyanate and isophorone diisocyanate);  5.  Markem-imaje 300 Cleaner (containing acetone, 2-propanol, and ethyl acetate); and   6.  Markem-imaje V Thinner (containing isophorone).

Issued

2013-02-26 00:00:00

Abate by

2013-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.1200(f)(5)(i): The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the identity of the hazardous chemical(s) contained therein:    (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the identity of the hazardous chemical(s) contained therein.  One employee used Markem-imaje 300 Cleaner (containing acetone, 2-propanol, and ethyl acetate), Markem-imaje V Thinner (containing isophorone), and 2-propanol during silk screening of probes.  The above chemicals were placed in unlabeled secondary containers.  The employer did not ensure that secondary containers of chemicals were labeled with the identity of the contents.  This condition exposed employees to a chemical hazard.

Issued

2013-02-26 00:00:00

Abate by

2013-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.1200(g)(8): The employer did not ensure that Material Safety Data Sheets were readily accessible to the employees in their work area during each work shift:    (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not ensure that Material Safety Data Sheets were readily accessible to the employees in their work area during each work shift.  The employer did not ensure that Material Safety Data Sheets were located at the workplace.  Hazardous chemicals located in the workplace included, but are not limited to the following:    1.  Kester Rosin Core solder (containing 37% lead);   2.  2-propanol;   3.  Sherwin Williams Polane Reducer K84 (containing toluene, n-butyl acetate, and isopropyl acetate);   4.  PPG Industries DCX61 High Solids Hardener (containing hexamethylene diisocyanate and isophorone diisocyanate);  5.  Markem-imaje 300 Cleaner (containing acetone, 2-propanol, and ethyl acetate); and  6.  Markem-imaje V Thinner (containing isophorone).

Issued

2013-02-26 00:00:00

Abate by

2013-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

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) on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard was introduced into their work area:    (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not ensure that employees were provided effective information and training as specified in 29 CFR 1910.1200(h) on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard was introduced into their work area.  Hazardous chemicals located in the workplace included, but are not limited to the following:    1.  Kester Rosin Core solder (containing 37% lead);  2.  2-propanol;  3.  Sherwin Williams Polane Reducer K84 (containing toluene, n-butyl acetate, and isopropyl acetate);  4.  PPG Industries DCX61 High Solids Hardener (containing hexamethylene diisocyanate and isophorone diisocyanate);  5.  Markem-imaje 300 Cleaner (containing acetone, 2-propanol, and ethyl acetate); and   6.  Markem-imaje V Thinner (containing isophorone).

Issued

2013-02-26 00:00:00

Abate by

2013-04-16 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.132(d)(2): The employer did not verify that the required workplace hazard assessment had been performed through a written certification which included the requirements as outlined in 29 CFR 1910.132(d):    (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not verify that the required workplace hazard assessment had been performed through a written certification which included the requirements as outlined in 29 CFR 1910.132(d).  Employees conducted operations which included exposure to toxic chemicals.  Hazardous operations included, but are not limited to the following:    1.  Exposure to lead fume when soldering;  2.  Exposure to Sherwin Williams Polane Reducer K84 (containing toluene, n-butyl acetate, and isopropyl acetate) and PPG Industries DCX61 High Solids Hardener (containing hexamethylene diisocyanate and isophorone diisocyanate) when coating ultrasound probes with polyurethane; and  3.  Exposure to Markem-imaje 300 Cleaner (containing acetone, 2-propanol, and ethyl acetate), Markem-imaje V Thinner (containing isophorone), and 2-propanol when silk screening ultrasound probes.

Issued

2013-02-26 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.1025(d)(2): An initial determination was not made to determine if any employee may be exposed to lead at or above the action level:    (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not make an initial determination to determine if any employee may be exposed to lead at or above the action level.  Employees used Kester Rosin Core solder (containing 37% lead) when making repairs to ultrasound probes.  The employer did not perform air monitoring to determine employee exposure to lead fume.  This condition potentially exposed employees to a lead hazard.

Issued

2013-02-26 00:00:00

Abate by

2013-03-31 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.1025(l)(1)(i): Employee(s) working in an area where there is potential exposure to airborne lead at any level were not informed of the content of Appendices A and B of this regulation:    (a) MedPro Imaging Probe Labs LLC, at 1821 Left Hand Circle #B, Longmont, CO: On and preceding 1/2/13, MedPro Imaging Probe Labs LLC did not ensure that employees working in an area where there is potential exposure to airborne lead at any level were informed of the content of Appendices A and B of this regulation.  Employees used Kester Rosin Core solder (containing 37% lead) when making repairs to ultrasound probes.  The employer did not ensure that employees were informed of the content of Appendices A and B of the lead standard.  This condition potentially exposed employees to a lead hazard.