OSHA Inspection: EDSAL MANUFACTURING

Issued

Sep 6, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.22(a)(1): All places of employment, passageways, storerooms, and service rooms shall be kept clean and orderly and in a sanitary condition.   a.  On or about June 26, in the facility, employees were exposed to slip, trip and fall hazards when scrap metal pieces were used to fill in an unlevel walking/working surface, the floor.

Issued

Sep 6, 2013

Abate by

Oct 2, 2013

Penalty

Initial $7,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.36(h)(3): The outdoor exit route must be reasonably straight and have smooth, solid, substantially level walkways;   a.  On or about August 29, 2013, near the powder coating cabinet line, the exit route from the building was not smooth, solid or level exposing employees to hazards of not being able to exit the building.  The exit route from the building consisted of uneven and broken scraps of wood.

Issued

Sep 6, 2013

Abate by

Jan 15, 2014

Penalty

Initial $6,000 · Current $3,000 Reduced

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 the cabinet line powder painting booth was exposed to continuous noise levels at 138.9% of the permissible daily dose level, when measured with an 80 dBA threshold, or an average equivalent sound level of the approximately 92.3 dBA for the 401 minute sampling time on June 26, 2013.  Exposure calculation included a zero increment for the 79 minutes not sampled.      b.  In the facility, an employee working in the home line powder painting booth was exposed to continuous noise levels at 76.52% of the permissible daily dose level, when measured with an 80 dBA threshold, or an average equivalent sound level of the approximately 88.0 dBA for the 385 minute sampling time on June 26, 2013.  Exposure calculation included a zero increment for the 95 minutes not sampled.       c.  In the facility, an employee working in the cabinet line powder painting booth was exposed to continuous noise levels at 66.94% of the permissible daily dose level, when measured with an 80 dBA threshold, or an average equivalent sound level of the approximately 87.1 dBA for the 406 minute sampling time on June 26, 2013.  Exposure calculation included a zero increment for the 74 minutes not sampled.      d.  In the facility, an employee working in the home line powder painting booth was exposed to continuous noise levels at 58.68% of the permissible daily does level, when measured with an 80 dBA threshold, or an average equivalent sound level of the approximately 86.1 dBA for the 391 minute sampling time on June 26, 2013.   Exposure calculation included a zero increment for the 89 minutes not sampled.

Issued

Sep 6, 2013

Abate by

Jan 15, 2014

Penalty

Initial $7,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.107(d)(2): General. All spraying areas shall be provided with mechanical ventilation adequate to remove flammable vapors, mists, or powders to a safe location and to confine and control combustible residues so that life is not endangered. Mechanical ventilation shall be kept in operation at all times while spraying operations are being conducted and for a sufficient time thereafter to allow vapors from drying coated articles and drying finishing material residue to be exhausted.     a.  On or about August 7, 2013, in the two (2) touch up powder coating area(s), employees were exposed to the hazards of combustible dust when the ventilation provided to the spray area(s) was insufficient and allowed inches of combustible dust to accumulate in the powder coating areas.

Issued

Sep 6, 2013

Abate by

Jan 15, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.107(g)(2): Cleaning. All spraying areas shall be kept as free from the accumulation of deposits of combustible residues as practical, with cleaning conducted daily if necessary. Scrapers, spuds, or other such tools used for cleaning purposes shall be of nonsparking material.    a.  On or about June 26, 2013, in the two (2) touch up powder coating spray areas, combustible residues had accumulated throughout the work area exposing employees to hazards associated with combustible dust.  Cleaning operations were not conducted daily in all areas including but not limited to underneath the platforms where employees worked.

Issued

Sep 6, 2013

Abate by

Jan 15, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.107(h)(2): Type approval. Electrostatic apparatus and devices used in connection with coating operations shall be of approved types.      a.  On or about April 1, 2013, in the two (2) touch up powder coating spray area(s), electrostatic apparatus equipment and devices were used to spray combustible powder.  The combustible powder spray application equipment and related ventilation system was not approved and listed by a nationally recognized testing laboratory exposing employees to hazards associated with combustible dust.

Issued

Sep 6, 2013

Abate by

Jan 15, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.107(i)(3): Equipment approval and specifications. Electrostatic hand spray apparatus and devices used in connection with coating operations shall be of approved types. The high voltage circuits shall be designed so as to not produce a spark of sufficient intensity to ignite any vapor-air mixtures nor result in appreciable shock hazard upon coming in contact with a grounded object under all normal operating conditions. The electrostatically charged exposed elements of the handgun shall be capable of being energized only by a switch which also controls the coating material supply.      a. On or about April 1, 2013, in the touch up powder coating area(s), ordinary (non-approved) wiring and associated electrostatic hand spraying equipment was located inside the spray area(s).  Employees were exposed to electrical hazards when the non approved wiring and electrostatic hand spraying equipment was used in an area where combustible dust was transferred and could result in a spark being generated in a combustible atmosphere resulting in a fire/explosion hazard.

Issued

Sep 6, 2013

Abate by

Jan 15, 2014

Penalty

Initial $0 · Current $0

Hazardous substances M102

General-duty citation text

29 CFR 1910.107(l)(4)(i): All areas shall be kept free of the accumulation of powder coating dusts, particularly such horizontal surfaces as ledges, beams, pipes, hoods, booths, and floors.      a.  On or about April 1, 2013, in the home line, cabinet line and  two (2) touch up powder coating spray area(s), combustible powder coating dust had accumulated through the spray and surrounding work areas exposing employees to hazards associated with combustible dust.  The combustible dust had accumulated on areas such as but not limited to beams, ledges, floors and walls and had not been removed through cleaning or maintenance procedures.      b.  On or about September 7, 2013, in the facility located at 4345 S. Packers, Chicago, near the new powder coating line, combustible powder coating dust had accumulated through the spray and surrounding work areas exposing employees to hazards associated with combustible dust.  The combustible dust had accumulated on areas such as but not limited to beams, ledges, floors and walls and had not been removed through to cleaning or maintenance procedures.

Issued

Sep 6, 2013

Abate by

Jan 15, 2014

Penalty

Initial $7,000 · Current $3,500 Reduced

General-duty citation text

29 CFR 1910.107(l)(2)(i): In addition to the provisions of paragraph (d) of this section, where applicable, exhaust ventilation shall be sufficient to maintain the atmosphere below the lowest explosive limits for the materials being applied. All nondeposited air-suspended powders shall be safely removed via exhaust ducts to the powder recovery cyclone or receptacle. Each installation shall be designed and operated to meet the foregoing performance specification.     a.  On or about April 1, 2013, in the two (2) touch up powder coating spray area(s), all nondeposited air-suspended powder was not removed to a powder recovery cyclone or receptacle thereby exposing employees to hazards associated with combustible powder.  The ventilation system in place was designed to drop powder into the spray area(s) rather than remove it properly to a cyclone.

Issued

Sep 6, 2013

Abate by

Jan 15, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.107(l)(2)(ii): Powders shall not be released to the outside atmosphere.     a.  On or about April 1, 2013, in the two (2) touch up powder coating spray area(s), nondeposited air-suspended powders are released to the outside atmosphere exposing employees to hazards associated with combustible dust.  The two (2) spray area(s) are equipped with a ventilation system designed to release the powder to the atmosphere and is not designed to contain the powder.

Issued

Sep 6, 2013

Abate by

Jan 15, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.107(l)(7)(v): The electrical equipment shall be so interlocked with the ventilation system that the equipment cannot be operated unless the ventilation fans are in operation.     a.  On or about April 1, 2013, employees working in the two (2) powder coating touch up areas, were required to spray combustible powder while utilizing hand and/or electrostatic spraying equipment.  An interlock was not installed in the powder coating touch up(s), which prevented electrical equipment from operation without the ventilation system in operation.  Employees were thereby exposed to hazards associated with fires and explosions.

Issued

Sep 6, 2013

Abate by

Oct 24, 2013

Penalty

Initial $5,000 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.132(f)(1): The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following:    a.  On or about June 26, 2013, all employees working in the powder coating areas were not trained on the proper use of personal protective equipment (PPE) when provided.  The training shall include the following:    1.  When PPE is necessary.   2.  What PPE is necessary.   3.  How to properly don, doff, adjust and wear PPE.  4.  The limitations of the PPE.  5.  The proper care, maintenance, useful life and disposal of the PPE.   Employee exposure included but was not limited to combustible dust and/or titanium dioxide.

Issued

Sep 6, 2013

Abate by

Oct 24, 2013

Penalty

Initial $6,000 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.134(e)(1): General. The employer shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.   a.  On or about June 26, 2013, in the powder coating booths and powder coating spray area(s), employees were required to wear respiratory protection.  The employer failed to medically evaluate all employees prior to being required to wear respiratory protection.

Issued

Sep 6, 2013

Abate by

Oct 24, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(k): Training and information. This paragraph requires the employer to provide effective training to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary. This paragraph also requires the employer to provide the basic information on respirators in Appendix D of this section to employees who wear respirators when not required by this section or by the employer to do so.    a.  On or about June 26, 2013, in the powder coating booths and powder coating spray area(s), employees were required to wear respiratory protection.  The employer failed to ensure that all employees required to wear respiratory protection were provided with training which included but was not limited to the proper use, limitations, and maintenance of the respiratory protection.

Issued

Sep 6, 2013

Abate by

Nov 15, 2013

Penalty

Initial $7,000 · Current $3,500 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 June 26, 2013, in the home line powder coating booth, an employee was exposed to particulates, not otherwise classified, at an eight hour time weighted average of 55.2 milligrams per meter cubed.  This limit was established to prevent employees form suffering from adverse health effects such as cumulative lung damage.

Issued

Sep 6, 2013

Abate by

Jan 23, 2014

Penalty

Initial $0 · Current $0

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 June 26, 2013, in the home line powder coating booth, an employee performing electrostatic spray powder coating was exposed to airborne total dust at an 8 hour time weighted average of 55.2 milligrams per cubic meter (mg/m3), approximately 3.7 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 that hand electrostatic spraying equipment is properly adjusted and maintained to reduce excessive powder from being released.   3.  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.    4.  Clothing, equipment and surfaces should be cleaned in such a manner as to avoid creating exposure from dust clouds.  5.  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

Sep 6, 2013

Penalty

Initial $25,000 · Current $12,500 Reduced

General-duty citation text

29 CFR 1910.37(a)(3): Exit routes must be free and unobstructed. No materials or equipment may be placed, either permanently or temporarily, within the exit route. The exit access must not go through a room that can be locked, such as a bathroom, to reach an exit or exit discharge, nor may it lead into a dead-end corridor. Stairs or a ramp must be provided where the exit route is not substantially level.    a.  On or about April 1, 2013, near the powder coating cabinet line, the exit route was blocked with material storage.  Employees were thereby exposed to the hazards associated with not being able to immediately exit the building.   The Edsal Manufacturing was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.37(a)(3), which was contained in OSHA inspection number 313940553, citation number 1, item number 1a, and was affirmed as a final order on April 20, 2011, with respect to a workplace located at 4345 S. Packer Avenue, Chicago, IL  60609.