OSHA Inspection: EATON INDUSTRIES LLC

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

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

Hazardous substances 1591

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)    Employees were required to wear the disposable filtering facepiece respirators and were not provided with any medical determination.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.134(f)(1): The employer did not ensure that employee(s) required to use a tight-fitting facepiece respirator passed the appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT):.    (a)    Employees were required to wear the disposable filtering facepiece respirators and were not provided with any qualitative or quantitative fit test.

Issued

Jun 19, 2013

Abate by

Jul 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.134(g)(1)(i)(A): Respirators with tight-fitting facepieces were worn by employees who had facial hair that came between the sealing surface of the facepiece and the face or that interfered with valve function:  (a)    During the March 23, 2013 cleaning of the shooting range the employee wearing the 3M disposable respirator had a multi-day growth of beard that interferred with the fit of the respirator.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.134(k)(1): The employer did not provide respirator training that would ensure each employee could demonstrate knowledge of items in section (i)-(vii):    (a)    Employees were required to wear the disposable filtering facepiece respirators and were not provided with effective, comprehensive, understandable respirator training.

Issued

Jun 19, 2013

Abate by

Jan 16, 2014

Penalty

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

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)    The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 80 micrograms per cubic meter of air, approximately 1.6 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 6, 2013 during a 125 minute sampling period.  Exposure calculations include a zero increment for the 355 minutes not sampled.      (b)    The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 270 micrograms per cubic meter of air, approximately 5.4 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 23, 2013 during a 47 minute sampling period.  Exposure calculations include a zero increment for the 433 minutes not sampled.      (c)    The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 263 micrograms per cubic meter of air, approximately 5.3 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 23, 2013 during a 46 minute sampling period.  Exposure calculations include a zero increment for the 434 minutes not sampled.

Issued

Jun 19, 2013

Abate by

Jul 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

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)    Employees such as those cleaning the shooting range and those working in the retail part of the shop were not monitored to determine their exposure to lead dust.

Issued

Jun 19, 2013

Abate by

Jan 16, 2014

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 the employer did not implement engineering and work practice controls (including administrative controls) to reduce and maintain employee exposure to lead below the 50 um/m3 permissible exposure limit:    (a)    The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 80 micrograms per cubic meter of air, approximately 1.6 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 6, 2013 during a 125 minute sampling period.  Exposure calculations include a zero increment for the 355 minutes not sampled.      (b)    The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 270 micrograms per cubic meter of air, approximately 5.4 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 23, 2013 during a 47 minute sampling period.  Exposure calculations include a zero increment for the 433 minutes not sampled.      (c)    The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 263 micrograms per cubic meter of air, approximately 5.3 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 23, 2013 during a 46 minute sampling period.  Exposure calculations include a zero increment for the 434 minutes not sampled.      The shooting range ventilation system, designed to ensure occupants were not exposed to lead, was not adequate during the range cleaning activity.      An abatement plan is required by 29 CFR Part 1903 and is to be submitted within twenty-five (25) calendar days after the final order date.    The abatement plan is to contain the steps being taken to abate the violation, a schedule for achieving abatement, and the interim measures being taken to protect employees.  Ninety (90) day progress reports are required during the abatement period.    Step 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 permissible exposure limits.    Step 1 abatement date is xx/xx/2013.  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 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 and/or administrative control options;  2.     Selection of optimum control methods and completion of design;  3.     Procurement, installation, and operation of selected control measures;   4.     Testing and acceptance or modification/redesign of controls.    Step 2 abatement date is xx/xx/2012.  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.  All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person.    Step 3 abatement date is xx/xx/2012.

Issued

Jun 19, 2013

Abate by

Jul 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(2): Respiratory protection was not provided to supplement engineering and work practice controls that did not control employees exposure to or below the permissible exposure limit of 50 micrograms per cubic meter of air:    (a)    The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 80 micrograms per cubic meter of air, approximately 1.6 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 6, 2013 during a 125 minute sampling period.  Exposure calculations include a zero increment for the 355 minutes not sampled.  The employee was not wearing any respiratory protection.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(3)(i): The employer did not establish and implement a written compliance program to reduce exposures to or below the permissible exposure limit, solely by means of engineering and work practice controls:    (a)    There was no written compliance program implemented to reduce employee exposures to lead to or below the permissible exposure limit of 50 micrograms per cubic meter of air such as during the cleaning of the two shooting ranges.  Employee exposures ranged from 80 micrograms per cubic meter of air measured on March 6, 2013 to 270 micrograms per cubic meter of air measured on March 23, 2013.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(4)(i): When ventilation was used to control exposure to lead, measurements which demonstrate the effectiveness of the system in controlling exposure were not made at least every three months:    (a)      There were no ventilation measurements conducted in the short and long shooting ranges either during normal use nor during the cleaning task.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(f)(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)), and (f) through (m) for each employee required by 29 CFR 1910.1025 to use a respirator:    (a)    There was no written respiratory protection program implemented that addressed the disposable filtering facepieces used by employees during the shooting range cleaning task.

Issued

Jun 19, 2013

Abate by

Jul 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(f)(3)(i)(C): The employer did not provide HEPA filters for powered and non-powered air-purifying respirators:  (a)     On March 6, 2013, during the shooting range cleaning task, the employee wore a disposable filtering facepiece that was designated N95 and not HEPA such as a 100-series respirator.    (b)     On March 23, 2013, during the shooting range cleaning task, the two employees wore a disposable filtering facepiece that was designated N95 and not HEPA such as a 100-series respirator.

Issued

Jun 19, 2013

Abate by

Jul 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(g)(1)(i): Appropriate protective work clothing and equipment, such as but not limited to coveralls or similar full-body work clothing, was not provided when employee(s) were exposed to lead above the permissible exposure limit (PEL), without regard to the use of respirators, or where the possibility of skin or eye irritation exists:  (a)     On March 6, 2013, during the shooting range cleaning task the employee was exposed to lead dust at 0.080 mg/m3 and wore his street clothing and not coveralls.

Issued

Jun 19, 2013

Abate by

Jul 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(g)(1)(i): Appropriate protective work clothing and equipment, such as but not limited to gloves, hats, and shoes or disposable shoe coverlets, was not provided when employee(s) were exposed to lead above the permissible exposure limit (PEL), without regard to the use of respirators, or where the possibility of skin or eye irritation exists:  (a)     On March 6, 2013, during the shooting range cleaning task the employee was exposed to lead dust at 0.080 mg/m3 and had no hat, hood or similar head covering.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(g)(2)(iv): Protective clothing against lead was not removed at the completion of the work shift in change rooms provided for that purpose as prescribed in 29 CFR 1910.1025(i)(2):    (a)    There was no change room provided for removing protective clothing after the cleaning of the shooting ranges.

Issued

Jun 19, 2013

Abate by

Jul 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(g)(2)(vii): Containers of contaminated protective clothing and equipment required by 29 CFR 1910.1025 (g)(2)(v) were not labeled as follows: CAUTION: CLOTHING CONTAMINATED WITH LEAD.  DO NOT REMOVE DUST BY BLOWING OR SHAKING.  DISPOSE OF LEAD CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL, STATE OR FEDERAL REGULATIONS:  (a)    On March 6, 2013 during the cleaning task of the shooting range employees disposed of protective booties and gloves into the unlabeled plastic waste bag.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(h)(1): All surfaces were not maintained as free as practicable of accumulations of lead:    (a)    Surfaces such as the metal shelf in the back room, the refrigerator handle, the white plastic table top, the fax machine cover, the top of the computer, the table top in front of the range entrance, the top of the water cooler, the soda vending machine chute and the microwave oven buttons had levels of lead contamination that exceeded 200 micrograms per square foot.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(h)(2)(ii): Shoveling, sweeping or brushing methods were used to remove lead accumulations where vacuuming or other equally effective methods were available and feasible:    (a)    Cleaning of the shooting range involved using a plastic shovel to push the brass into a pile when a vacuum was both available and feasible.

Issued

Jun 19, 2013

Abate by

Jan 16, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(i)(3)(i): Employee(s) exposed to lead in excess of the permissible exposure limit (PEL), without regard to the use of respirators, were not required to shower at the end of the work shift:    (a)    Employees who cleaned the shooting ranges on March 6, 2013 and March 23, 2013 and were exposed to lead exceeding the PEL did not shower at the end of the work shift.

Issued

Jun 19, 2013

Abate by

Jul 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(i)(3)(iii): The employer did not ensure that employees who were required to shower per 29 CFR 1910.1025(i)(3)(i) did not leave the workplace wearing any clothing or equipment worn during the work shift:  (a)     On March 6, 2013 the employee cleaning the shooting range was exposed to lead at 80 micrograms per cubic meter of air and wore work clothing home.    (b)     On March 23, 2013 the two employees cleaning the shooting range were exposed to lead at 270 micrograms per cubic meter of air and 263 micrograms per cubic meter of air and wore work clothing home.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(j)(1)(i): A medical surveillance program was not instituted for all employee(s) who were, or could be exposed to lead above the action level for more than thirty days per year:    (a)     Three employees cleaning the shooting ranges had airborne lead exposures of 80 micrograms per cubic meter up to 270 micrograms per cubic meter and there was no medical surveillance program implemented.      The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 80 micrograms per cubic meter of air, approximately 1.6 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 6, 2013 during a 125 minute sampling period.  Exposure calculations include a zero increment for the 355 minutes not sampled.      The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 270 micrograms per cubic meter of air, approximately 5.4 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 23, 2013 during a 47 minute sampling period.  Exposure calculations include a zero increment for the 433 minutes not sampled.      The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 263 micrograms per cubic meter of air, approximately 5.3 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 23, 2013 during a 46 minute sampling period.  Exposure calculations include a zero increment for the 434 minutes not sampled.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

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 29 CFR 1910.1025:    (a)      Employees such as those cleaning the shooting range and those working in the retail part of the shop were not trained.      The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 80 micrograms per cubic meter of air, approximately 1.6 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 6, 2013 during a 125 minute sampling period.  Exposure calculations include a zero increment for the 355 minutes not sampled.      The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 270 micrograms per cubic meter of air, approximately 5.4 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 23, 2013 during a 47 minute sampling period.  Exposure calculations include a zero increment for the 433 minutes not sampled.      The employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average of 263 micrograms per cubic meter of air, approximately 5.3 times the limit of 50 micrograms per cubic meter of air.  The sample was collected on March 23, 2013 during a 46 minute sampling period.  Exposure calculations include a zero increment for the 434 minutes not sampled.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(l)(1)(ii): The employer did not train each employee who is subject to exposure to lead at or above the action level, or for whom the possibility of skin or eye irritation exists, in accordance with the requirements of 29 CFR 1910.1025:    (a)     Employees such as those cleaning the shooting range, with airborne lead exposures of 80 micrograms per cubic meter up to 270 micrograms per cubic meter, were not trained.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(m)(2)(i): 29 CFR 1910.1025(m)(2)(i): Warning signs bearing the legend: WARNING, LEAD WORK AREA, POISON, NO SMOKING OR EATING, were not posted in each work area where the permissible exposure limit (PEL) was exceeded:                                                     (a)    In the shooting range there was no warning sign posted.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $2,400 · Current $0 Reduced

General-duty citation text

29 CFR 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met:    (a)     There was no written chemical hazard communication program developed for chemicals used in the workplace such as the D-Lead all purpose cleaner and the ammunition.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(g)(8): The employer did not maintain copies of the required material safety data sheets for each hazardous chemical in the workplace:    (a)     There were no material safety data sheets maintained for chemicals used in the workplace such as the D-Lead all purpose cleaner and the ammunition.

Issued

Jun 19, 2013

Abate by

Sep 16, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h)(1): Employees were not provided effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard that the employees had not been previously trained about was introduced into their work area:    (a)     There had been no training conducted regarding chemicals used in the workplace such as the D-Lead all purpose cleaner and the ammunition.