OSHA Inspection: AMPCO METAL INC.

Issued

Sep 11, 2013

Abate by

Aug 7, 2015

Penalty

Initial $3,500 · Current $2,480 Reduced

Hazardous substances 0731

General-duty citation text

29 CFR 1910.1000(a)(2): Employee(s) were exposed to an airborne concentration of copper listed in Table Z-1 in excess of the 8 hour Time Weighted Average concentration of 0.1 milligrams per cubic meter (mg/m3):     AMPCO Metal Inc, Foundry Area -      a) On March 20, 2013, an employee working (adding metal, drossing and pouring) on Line 1 was exposed to a concentration of copper fume of 0.261 mg/m3. This is in excess of the Time-Weighted Average (TWA) listed in Table Z-1. The copper fume concentration is approximately 2.6 times the acceptable TWA of 0.1 mg/m3. The exposure was measured over 477 minutes. Zero exposure was assumed for the unsampled period of 3 minutes. The copper fume limit is established to prevent metal fume fever, upper respiratory tract irritation, discoloration of the skin and hair, metallic or sweet taste.      b) On March 20, 2013, an employee helping (drossing, pouring) on Lines 1-5 and cutting bars was exposed to a concentration of copper fume of 0.257 mg/m3. These are in excess of the TWA listed in Table Z-1. The copper fume concentration is approximately 2.6 times the acceptable TWA of 0.1 mg/m3. The exposure was measured over 417 minutes. Zero exposure was assumed for the unsampled period of 63 minutes. The copper fume limit is established to prevent metal fume fever, upper respiratory tract irritation, discoloration of the skin and hair, metallic or sweet taste.      c) On March 20, 2013, an employee working (adding metal, drossing and pouring) on Lines 2-5 was exposed to a concentration of copper fume of 0.281 mg/m3. This is in excess of the TWA listed in Table Z-1. The copper fume concentration is approximately 2.8 times the acceptable TWA of 0.1 mg/m3. The exposure was measured over 445 minutes. Zero exposure was assumed for the unsampled period of 35 minutes. The copper fume limit is established to prevent metal fume fever, upper respiratory tract irritation, discoloration of the skin and hair, metallic or sweet taste.     d) On July 17, 2013, an employee working (adding metal drossing and pouring) on Lines 2-5 was exposed to a concentration of copper fume of 0.124 mg/m3. This is in excess of the TWA listed in Table Z-1. The copper fume concentration is approximately 1.2 times the acceptable TWA of 0.1 mg/m3. The exposure was measured over 341 minutes. Zero exposure was assumed for the unsampled period of 139 minutes. The copper fume limit is established to prevent metal fume fever, upper respiratory tract irritation, discoloration of the skin and hair, metallic or sweet taste.      In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Sep 11, 2013

Abate by

Aug 7, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 0731

General-duty citation text

29 CFR 1910.1000(e): Feasible administrative or engineering controls were not determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):     Effective engineering and administrative controls were not instituted and maintained by AMPCO Metal Inc. during foundry operations to reduce employees' exposures to air contaminants at the following locations:     a) Lines 1-5 - Employees (charging, drossing and pouring) were exposed to copper fume in excess of 0.1 mg/m3 as described in Citation1, Item 1a. The following recommendations of feasible engineering controls demonstrate that there is incremental "room for improvement" over the existing controls.  Methods of controls under these circumstances include, but are not limited to:       1) Seek the expertise of a competent individual such as an engineer or a certified industrial hygienist to assess the               the existing engineering controls.       2) Install local exhaust ventilation on all dross barrels.       3) Eliminate all personal cooling fans. The velocity jets from these devices are disruptive to the          local source ventilation systems such as the canopy hoods and annular slot hoods on the melt deck. Heat stress          issues will be handled by installation of supply air plenum for workers on the melt deck.       4) Provide supply air islands and supply air plenums for the melt deck operators. This technique of providing clean,          uncontaminated outside air to the melt deck may bring the employees under the PEL if local exhaust is                functioning and work practices are scrutinized. In addition, consider establishing idle-areas where employees          can stand under a supply air island which is fed clean, uncontaminated outside air.     b) Line 1 - An employee (charging, drossing and pouring) was exposed to copper fume in excess of 0.1 mg/m3. Methods of control under these circumstances include, but are not limited to:         1) Increase the slot velocity on the annular ring on the furnace to 2000 feet per minute (fpm).    c) Lines 2-5 - Employees (charging, drossing and pouring) were exposed to copper fume in excess of 0.1 mg/m3. Methods of control under these circumstances include, but are not limited to:       1) Modify existing canopy hoods or install annular slot hoods on furnaces 2 and 5. The thermal rise plume containing           copper must be captured for furnaces and tundishes.       2) Install a hood on the duct over the Line 4 tundish.       3) Cap the tundish duct on Line 2. The furnace here is not in use and the hood continues to exhaust air. By capping           the duct, there will be an increase of available exhaust flow at the remaining hoods.      Step 1 - Effective respiratory protection shall be provided and used by employees performing foundry tasks at Lines 1-5.    Abatement Date: Completed   Step 2 - A complete written respiratory protection program shall be developed and implemented with worksite specific procedures.    Abatement Date: 30 days   Step 3 - Written detailed plan of abatement shall be submitted to the Area Director outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposures to copper fume, as referenced in this citation. The plan shall include, at a minimum, target dates for the following actions which must be consistent with the dates required for this citation:       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;      4) Testing and acceptance of control methods. All control methods shall be evaluated for each particular use by a          technically qualified person.   Abatement date: 30 days   Step 4 - Abatement shall have been completed by the implementation of feasible engineering/administrative controls and verification of their effectiveness in achieving compliance.   Thirty (30) day progress reports are required during the abatement period.    Abatement date: 120 days   In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Sep 11, 2013

Abate by

Oct 29, 2013

Penalty

Initial $2,100 · Current $1,470 Reduced

Hazardous substances 0731136620859010G100

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) AMPCO Metal Inc. did not develop a written hazard communication program in accordance with 29 CFR 1910.1200(e)(1) that describes or includes at least the following:   1) Requirement for labeling of containers of hazardous chemicals; 2) Material safety data sheet availability; 3) Training of employees; 4) A complete list of hazardous chemicals known to be in the workplace; 5) Methods to inform employees of the hazards on non-routine tasks; and 6) Methods to inform other employer(s) of material safety data sheet availability; the labeling system; and any precautionary measures to protect employees.  Employees were exposed to hazardous chemicals, including graphite (slight explosion hazard, pneumoconiosis; eye, skin irritation); copper (metal fume fever; upper respiratory tract irritation, discoloration of the skin and hair); Kast 70X (contains silica - lung disease, silicosis, crystalline silica is considered a human carcinogen); Allied Mineral Products, Inc. Wash 668A (contains silica); Chicago Fire Brick Titan Plastic Fine (contains silica, phosphoric acid - eye burns; skin irritation; silicosis); Ashland Specialty Chemical Company X-othermic ET--647 Hot Topping (contains calcium flouiride, graphite, iron oxide, aluminum dross, neutralized acid - eye, skin, respiratory tract irritation; can cause bone damage).   In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Sep 11, 2013

Abate by

Oct 29, 2013

Penalty

Initial $3,500 · Current $2,450 Reduced

Hazardous substances 0731136620859010G100

General-duty citation text

29 CFR 1910.1200(h)(3)(ii): Employee training did not include the physical and health hazards of the chemicals in the work area:  a) AMPCO Metal Inc. - Employees who work with hazardous chemicals, did not receive training on the physical and health hazards of the chemicals, including graphite (slight explosion hazard, pneumonoconiosis; eye, skin irritation); copper (metal fume fever; upper respiratory tract irritation, discoloration of the skin and hair); Kast 70X (contains silica - lung disease, silicosis, crystalline silica is considered a human carcinogen); Allied Mineral Products, Inc. Wash 668A (contains silica); Chicago Fire Brick Titan Plastic Fine (contains silica, phosphoric acid - eye burns; skin irritation; silicosis); Ashland Specialty Chemical Company X-othermic ET--647 Hot Topping (contains calcium flouiride, graphite, iron oxide, aluminum dross, neutralized acid - eye, skin, respiratory tract irritation; can cause bone damage).   In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Sep 11, 2013

Abate by

Oct 29, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 8111

General-duty citation text

29 CFR 1910.95(k)(1): The employer did not train each employee who is exposed to noise at or above an 8-hour time-weighted average (TWA) of 85 decibels in accordance with the requirements of 29 CFR 1910.95(k). The employer did not institute a training program and ensure employee participation in the program:  a) AMPCO Metal Inc. - The employer did not train each employee exposed to noise at or above the 8-hour TWA of 85 decibels in accordance with the requirements of 29 CFR 1910.95(k). On March 20, 2013, employees working in the foundry area were exposed to noise levels above an 8-hour TWA of 85 decibels.   In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Sep 11, 2013

Abate by

Oct 29, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 07319010

General-duty citation text

29 CFR 1910.134(c)(2)(i): Respirator users were not provided with the information contained in Appendix D to 29 CFR 1910.134 when the employer determined that any voluntary respirator use was permissible:  a) AMPCO Metal Inc., Foundry Area - The employer did not provide employees using filtering facepiece respirators with the information contained in Appendix D when the employer permitted the use of the respirators voluntarily. Employees use 3M Model 8576 P95 and 3M Model 8511 N95 filtering facepiece respirators and 3M Model 8576 elastomeric facepiece respirators with P100 filters, voluntarily.   In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).