OSHA Inspection: KEYSTONE FOUNDRY DIVISION OF UNITED BRASS WORKS

Issued

May 13, 2013

Abate by

Nov 15, 2013

Penalty

Initial $5,000 · Current $5,000

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(c)(1): Employee(s) were exposed to lead at concentrations greater than fifty micrograms per cubic meter of air averaged over an eight-hour period:    a) Keystone Foundry Division of United Brass Works, Inc.- On or about March 14, 2013, a pourer was exposed to lead at a time weighted average (TWA) of  220  micrograms per cubic meter of air (ug/m3).  The exposure level was derived from one sample collected over 472 minutes and assumed zero exposure for the remaining work shift.

Issued

May 13, 2013

Abate by

Nov 15, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(1)(i): For any employees exposed to lead above the permissible exposure limit for more than 30 days per year where engineering and work practice controls (including administrative controls) were feasible but did not reduce the employees' exposure to or below the permissible exposure limit the employer did not use engineering and/or work practice controls to reduce esposures to the lowest feasible level:   a) Keystone Foundry Division of United Brass Works, Inc.- On or about March 14, 2013, a pourer was exposed to lead at a time weighted average (TWA) of  220  micrograms per cubic meter of air (ug/m3).  The exposure level was derived from one sample collected over 472 minutes and assumed zero exposure for the remaining work shift.

Issued

May 13, 2013

Abate by

Jun 15, 2013

Penalty

Initial $5,000 · Current $5,000

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(d)(6)(ii): Where the initial determination or subsequent monitoring revealed employee exposure to lead to be at or above the action level but below the permissible exposure limit; monitoring was discontinued without two consecutive measurements taken at least 7 days apart below the action level:    a) Keystone Foundry Division of United Brass Works, Inc.- The company discontinued sampling of the grinder when sampling results indicated employee exposure to lead above the action level.  Monitoring records provided by the company, on or about January 10, 2013,  indicated the grinder was exposed to 47.9 ug/m3 as an 8 hour Time-Weighted Average (TWA) on May 19, 2009.  The company had not conducted additonal monitoring.

Issued

May 13, 2013

Abate by

Jun 15, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(d)(6)(iii): Where the initial monitoring revealed that employee exposure to lead was above the permissible exposure limit, ; monitoring was not repeated at least quarterly and continued at the required frequency until at least two consecutive measurements taken at least 7 days apart were below the PEL and at or above the action level:   (a) Keystone Foundry Division of United Brass Works, Inc.- Lead exposure monitoring was not repeated quarterly for a Pourer exposed to lead levels exceeding the PEL.  On May 19, 2009, the Pourer was exposed to 146.7 ug/m3 of lead as a 8-hour TWA.  Lead monitoring was not repeated until February 12, 2010.  On February 12, 2010, the Pourer was exposed to 15 ug/m3 of lead as a 8-hour TWA.  Lead monitoring was not repeated until November 22, 2010.  Monitoring had not been conducted at the required frequency until at least two consecutive measurements, taken at least seven (7) days apart, were below the PEL.   (b) Keystone Foundry Division of United Brass Works, Inc.- Lead exposure monitoring was not repeated quarterly for a Melter exposed to lead levels exceeding the PEL.  On May 19, 2009, the Melter was exposed to 70.0 ug/m3 of lead as a 8-hour TWA.  Lead monitoring was not repeated until February 12, 2010.  On February 12, 2010, the Melter was exposed to 7.9 ug/m3 of lead as a 8-hour TWA.  Lead monitoring was not repeated until November 22, 2010.  Monitoring had not been conducted at the required frequency until at least two consecutive measurements, taken at least seven (7) days apart, were below the PEL.

Issued

May 13, 2013

Abate by

Jun 15, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(d)(7): Additional exposure monitoring was not conducted when there was a change in production, process, control or personnel, or any other reason to suspect a change that may have resulted in new or additional exposure to lead:    a) Keystone Foundry Division of United Brass Works, Inc.- On or about March 14, 2013, a pourer was exposed to lead at a time weighted average (TWA) of  220  micrograms per cubic meter of air (ug/m3).  The exposure level was derived from one sample collected over 472 minutes and assumed zero exposure for the remaining work shift.  The company had not conducted additional monitioring when there was a change in personnel.

Issued

May 13, 2013

Abate by

Aug 15, 2013

Penalty

Initial $3,000 · Current $0 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(3)(ii): Written compliance programs for lead did not include information required by 1910.1025(e)(3)(ii)(A) thru (H):      a) Keystone Foundry Division of United Brass Works, Inc.- On or about March 14, 2013, the company's  written Lead Compliance Program did not include:     1.) A description of each operation in which lead is emitted; e.g. machinery used, material processed, controls in place, crew size, employee job responsibilities, operating procedures and maintenance practices;    2.) A description of the specific means that will be employed to achieve compliance, including engineering plans and studies used to determine methods selected for controlling exposure to lead;    3.) A report of the technology considered in meeting the permissible exposure limit;    4.) Air monitoring data which documents the source of lead emissions;    5.) A detailed schedule for implementation of the program, including documentation such as copies of purchase orders for equipment, construction contracts, etc.;    6.) A work practice program which includes items required under paragraphs (g), (h) and (i) of this regulation;    7.) An administrative control schedule required by paragraph (e)(6), if applicable; and    8.) Other relevant information.

Issued

May 13, 2013

Abate by

Jun 15, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(3)(iv): Written compliance programs for lead were not revised and updated annually to reflect the current status of the program:       a) Keystone Foundry Division of United Brass Works, Inc.- On or about March 14, 2013, the company's  written Lead Compliance Program had not been updated annually to reflect the current status of the program.

Issued

May 13, 2013

Abate by

Jun 15, 2013

Penalty

Initial $3,000 · Current $0 Reduced

Hazardous substances 15919010

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.) Keystone Foundry Division of United Brass Works, Inc.- On or about January 10, 2013 grinders, melters and pourers were required to wear 3M Versaflo Powered Air Purifying respirators during melting and pouring operations;     b.) Keystone Foundry Division of United Brass Works, Inc.- On or about January 10, 2013 grinders were required to wear 3M Moldex 2200 N95 Particulate respirators during grinding operations; and    c.) Keystone Foundry Division of United Brass Works, Inc.- On or about January 10, 2013 the laborer was required to wear a Moldex 220 N95 Particulate respirator during cleaning operations.  The company had not developed a written respiratory protection program.