OSHA Inspection: CON-TECH PAINTING INC.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

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

Hazardous substances 9010

General-duty citation text

29 CFR 1926.55(a): Employee(s) were exposed to material(s) at concentrations above those specified in the Threshold Limit Values of Airborne Contaminants for 1970 of the American Conference of Governmental Industrial Hygienists:  a) Oxford Mills, East and West Buildings - Employees performed abrasive blasting of the interior brick walls and were exposed to silica at concentrations greater than the Permissible Exposure Limit (PEL).  Employee exposure monitoring conducted on 7/3/13 showed that an employee performing abrasive blasting was exposed to silica at an 8-hour Time Weighted Average (TWA) of 42.6 mppcf, approximately 1.4 times the Permissible Exposure Limit of 29.8 mppcf as an 8-hour time weighted average.  Sampling was conducted for 186 minutes and a zero exposure was assumed for the unsampled portion of the 8-hour shift.     b) Oxford Mills, East and West Building - Employees performed clean-up activities using dry sweeping and shoveling after abrasive blasting and were exposed to silica in excess of the Permissible Exposure Limit (PEL).  Employee exposure monitoring conducted on 7/10/13 showed that an employee performing cleanup operations after abrasive blasting was exposed to silica at an 8-hour Time Weighted Average (TWA) of 54.5 mppcf, approximately 2.5 times the Permissible Exposure Limit of 21.9 mppcf as an 8-hour time weighted average.  Sampling was conducted for 429 minutes and a zero exposure was assumed for the unsampled portion of the 8-hour shift.    Note:  Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 9010

General-duty citation text

29 CFR 1926.55(b): Feasible administrative or engineering controls were not implemented to reduce employee exposure:   a) Oxford Mills, East and West Buildings - Employees performed abrasive blasting of the interior brick walls in the East and West Buildings and feasible administrative or engineering controls were not used to reduce employee exposure to silica.   Employee exposure monitoring conducted on 7/3/13 showed that an employee performing abrasive blasting was exposed to silica at an 8-hour Time Weighted Average (TWA) of 42.6 mppcf, approximately 1.4 times the Permissible Exposure Limit of 29.8 mppcf as an 8-hour time weighted average.  Sampling was conducted for 186 minutes and a zero exposure was assumed for the unsampled portion of the 8-hour shift.    b) Oxford Mills, East and West Building - Employees performed clean-up activities using dry sweeping and shoveling after abrasive blasting of the interior brick walls, and feasible administrative or engineering controls were not used to reduce employee exposure.  Employee exposure monitoring conducted on 7/10/13 showed that an employee performing cleanup operations after abrasive blasting was exposed to silica at an 8-hour Time Weighted Average (TWA) of 54.5 mppcf, approximately 2.5 times the Permissible Exposure Limit of 21.9 mppcf as an 8-hour time weighted average.  Sampling was conducted for 429 minutes and a zero exposure was assumed for the unsampled portion of the 8-hour shift.    Note:  Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

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

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(c)(1): The employer shall assure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m(3)) averaged over an 8-hour period.  a) Oxford Mills, East and West Buildings - Employees performing abrasive blasting of the interior brick walls were exposed to lead at concentrations greater than the permissible exposure limit of 50 micrograms/cubic meter averaged over an 8 hour period.  Employee exposure monitoring conducted on 7/3/13 showed that a blaster performing abrasive blasting was exposed to lead at an 8-hour Time Weighted Average (TWA) of 128 micrograms per cubic meter (ug/m3), approximately 2.6 times the Permissible Exposure Limit of 50 ug/m3 as an 8-hour time weighted average.  Sampling was conducted for 164 minutes and a zero exposure was assumed for the unsampled portion of the 8-hour shift.    b)  Oxford Mills, East and West Building - Employees performing clean-up activities after abrasive blasting were exposed to lead in excess of the Permissible Exposure Limit (PEL)  of 50 micrograms per cubic meter of lead.  Employee exposure monitoring conducted on 7/10/13 showed that an employee performing cleanup operations after abrasive blasting  was exposed to lead at an 8-hour Time Weighted Average (TWA) of 186 micrograms per cubic meter (ug/m3), approximately 3.7 times the Permissible Exposure Limit of 50 ug/m3 as an 8-hour time weighted average.  Sampling was conducted for 58 minutes and a zero exposure was assumed for the unsampled portion of the 8-hour shift.    Note:   Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(e)(1): The employer did not implement all feasible engineering and work practice controls, including administrative controls, to reduce and maintain employee exposure to lead to or below the permissible exposure limit:  a) Oxford Mills, East and West Buildings - Employees performing abrasive blasting of the interior brick walls were exposed to lead at concentrations greater than 50 micrograms/cubic meter averaged over an 8 hour period, and the employer did not implement engineering and work practice controls to limit the employee exposures to or below the permissible exposure limit.  Employee exposure monitoring conducted on 7/3/13 showed that a blaster performing abrasive blasting was exposed to lead at an 8-hour Time Weighted Average (TWA) of 128 micrograms per cubic meter (ug/m3), approximately 2.6 times the Permissible Exposure Limit of 50 ug/m3 as an 8-hour time weighted average.  Sampling was conducted for 164 minutes and a zero exposure was assumed for the unsampled portion of the 8-hour shift.    b)  Oxford Mills, East and West Building - Employees performed clean-up activities using dry sweeping and shoveling after abrasive blasting and the employer did not implement engineering and work practice controls to reduce and maintain employee exposure to at or below the permissible exposure limit.  Employee exposure monitoring conducted on 7/10/13 showed that an employee performing cleanup operations after abrasive blasting was exposed to lead at an 8-hour Time Weighted Average (TWA) of 186 micrograms per cubic meter (ug/m3), approximately 3.7 times the Permissible Exposure Limit of 50 ug/m3 as an 8-hour time weighted average.  Sampling was conducted for 58 minutes and a zero exposure was assumed for the unsampled portion of the 8-hour shift.  Wipe and bulk samples of the dust in the East and West Building, in areas where blasting and cleanup was completed, taken on 4/5/13, 4/8/13, and 5/13/13 contained lead.    Note:  Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 15, 2013

Penalty

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

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(d)(1)(i): Each employer who had a workplace or operation covered by 29 CFR 1926.62 did not initially determine if any employee was exposed to lead at or above the action level of 30 micrograms per cubic meter of air (ug/m3) calculated as an 8-hour time-weighted average (TWA):  a) Oxford Mills, East and West Buildings - Employees performed abrasive blasting of the interior surfaces in the East and West Buildings and the employer did not determine if any employee was exposed to lead at or above the action level of 30 micrograms per cubic meter of lead, exposing employees to lead.  Employee exposure monitoring conducted on 7/3/13 showed that a blaster performing abrasive blasting was exposed to lead at an 8-hour Time Weighted Average (TWA) of 128 micrograms per cubic meter (ug/m3), approximately 2.6 times the Permissible Exposure Limit of 50 ug/m3 as an 8-hour time weighted average.  Sampling was conducted for 164 minutes and a zero exposure was assumed for the unsampled portion of the 8-hour shift.    b) Oxford Mills,, East and West Building - Employees performed clean-up activities using dry sweeping and shoveling after abrasive blasting and the employer did not determine if any employee was exposed to lead at or above the action level of 30 micrograms per cubic meter of lead, exposing employees to lead.   Employee exposure monitoring conducted on 7/10/13 showed that an employee performing cleanup operations after abrasive blasting in the room at the north end of the West Building was exposed to lead at an 8-hour Time Weighted Average (TWA) of 186 micrograms per cubic meter (ug/m3), approximately 3.7 times the Permissible Exposure Limit of 50 ug/m3 as an 8-hour time weighted average.  Sampling was conducted for 58 minutes and a zero exposure was assumed for the unsampled portion of the 8-hour shift.    Note:  Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $2,400 · Current $1,200 Reduced

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(e)(2)(i): The employer did not establish and implement a written compliance program to achieve compliance with 29 CFR 1926.62(c) prior to commencement of the job:  a) Oxford Mills, East and West Buildings - Employees performed abrasive blasting of the interior surfaces in the East and West Buildings and the employer did not establish and implement a written compliance program to ensure that no employee is exposed to lead at concentrations greater than 50 micrograms per cubic meter averaged over an 8 hour period, exposing employees to lead.  Employee exposure monitoring conducted on 7/3/13 showed that a blaster performing abrasive blasting was exposed to lead at an 8-hour Time Weighted Average (TWA) of 128 micrograms per cubic meter (ug/m3), approximately 2.6 times the Permissible Exposure Limit of 50 ug/m3 as an 8-hour time weighted average.  Sampling was conducted for 164 minutes and a zero exposure was assumed for the unsampled portion of the 8-hour shift.    b) Oxford Mills, East and West Building - Employees performed clean-up activities using dry sweeping and shoveling after abrasive blasting and the employer did not establish and implement a written compliance program to ensure that no employee is exposed to lead at concentrations greater than 50 micrograms per cubic meter averaged over an 8 hour period, exposing employees to lead.   Employee exposure monitoring conducted on 7/10/13 showed that an employee performing cleanup operations after abrasive blasting in the room at the north end of the West Building was exposed to lead at an 8-hour Time Weighted Average (TWA) of 186 micrograms per cubic meter (ug/m3), approximately 3.7 times the Permissible Exposure Limit of 50 ug/m3 as an 8-hour time weighted average.  Sampling was conducted for 58 minutes.  A zero exposure was assumed for the unsampled portion of the 8-hour shift.    Note:   Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Dec 6, 2013

Penalty

Initial $2,400 · Current $1,200 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, as referenced in 29 CFR 1926.62(f)(2)(i):          a) Oxford Mills, East and West Buildings - Employees performing abrasive blasting were required to wear Bullard 88VX blasting helmets with compressed air.  The employer did not establish and implement a written respiratory protection program with worksite specific procedures as interim protection until an exposure assessment is performed, exposing employees to lead.  Observed on or about 4/5/13.        b) Oxford Mills, West Building - Employees performing abrasive blasting wore Bullard 88VX blasting helmets and 3M 7586 half-mask respirators underneath.  Employee exposure monitoring on 7/3/13 showed that employees performing abrasive blasting were exposed to lead in excess of the permissible exposure limit of 50 micrograms per cubic meter (ug/m3), and the employer did not establish and implement a written respiratory protection program with worksite specific procedures.        c) Oxford Mills, West Building - Employees performing cleanup activities after abrasive blasting wore 3M 7586 half-mask air purifying respirators with P100 filters or 3M 6899B full facepiece air purifying respirators with P100 cartridges.  Employee exposure monitoring on 7/10/13 showed that employees were exposed to lead in excess of the permissible exposure limit, and the employer did not establish and implement a written respiratory protection program with worksite specific procedures.       NOTE:  Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1910.134(f)(2): Employee(s) using tight-fitting facepiece respirators were not fit tested prior to initial use of the respirator, whenever a different respirator face-piece (size, style, model or make) was used, and at least annually thereafter as referenced in 1926.103:       a) Oxford Mills, West Building - An employee wore a 3M 7586 half-mask respirator with P100 filters during cleanup operations after abrasive blasting and was not provided with a fit-test by the employer prior to the initial use of the respirator, exposing the employee     to lead.  Employee exposure monitoring on 7/10/13 showed that an employee performing cleanup activities after abrasive blasting was exposed to lead in excess of the permissible exposure limit of 50 micrograms per cubic meter (ug/m3).       b) Oxford Mills, West Building - Employees wore 3M 7586 half-mask air purifying respirators or 3M 6899B full facepiece air purifying respirators, with P100 filters during cleanup operations after abrasive blasting.  The employer did not provide fit-testing for the employees on an annual basis, exposing the employees to lead.  Employee exposure monitoring showed that employees were exposed to lead at amounts which exceeded the Permissible Exposure Limit (PEL).  Observed on or about 7/3/13.       Note:  Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.  Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1910.134(h)(1): Respirators were not cleaned and disinfected using the procedures in Appendix B-2 of 29 CFR 1910.134 or equivalent procedures recommended by the respirator manufacturer, as referenced in 1926.62 (f)(2)(ii):    a) Oxford Mills, East and West Buildings - Employees wore Bullard 88VX blasting helmets with compressed air during abrasive blasting operations.  The blasting helmets and compressed air were required as interim protection until an exposure determination is completed.  The blasting helmets were not cleaned, exposing employees to lead.  Observed on or about 4/5/13.    b) Oxford Mills, West Building - Employees wore Bullard 88VX blasting helmets with half-mask air purifying respirators underneath, during abrasive blasting operations.  The helmets and the half-mask respirators were not cleaned, exposing employees to lead.  Employee exposure monitoring on 7/3/13 showed that employees were exposed to lead in amounts which exceeded the permissible exposure limit (PEL) of 50 micrograms/cubic meter (ug/m3) as an 8-hour time weighted average (TWA).      c) Oxford Mills, West Building - Employees wore half-mask of full facepiece air purifying respirators during cleanup of the dust from abrasive blasting.  The respirators were not cleaned, exposing employees to lead.  Employee exposure monitoring on 7/10/13, showed that employees were exposed to lead in amounts which exceeded the permissible exposure limit of 50 ug/m3 as an 8-hour TWA.     Note:  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.  Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $1,600 · Current $800 Reduced

Hazardous substances 15919010

General-duty citation text

29 CFR 1926.62(g)(2)(i): The employer did not provide the protective clothing required in 29 CFR 1926.62(g)(1) in a clean and dry condition at least weekly:  a) Oxford Mills, East and West Buildings - Employees wore the same Clemco coveralls which were not cleaned, every day during abrasive blasting operations for up to 5 months.  The use of coveralls or similar full body clothing is required as interim protection during abrasive blasting, and the employer did not provide clean protective clothing at least weekly.  Observed on or about 4/5/13.    Note:  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 15919010

General-duty citation text

29 CFR 1926.62(g)(2)(ii): The employer did not provide for the cleaning, laundering, and disposal of protective clothing and equipment required by 29 CFR 1926.62(g)(1):    a) Oxford Mills, East and West Buildings - Employees performing abrasive blasting operations up to and including 4/5/13 were exposed to lead in excess of the permissible exposure limit  (PEL) of 50 micrograms/cubic meter and the employer did not provide for the cleaning, laundering and disposal of protective clothing and equipment.    Employee exposure monitoring conducted on 7/3/13 showed that a blaster performing abrasive blasting was exposed to lead at an 8-hour Time Weighted Average (TWA) of 128 micrograms per cubic meter (ug/m3), approximately 2.6 times the Permissible Exposure Limit of 50 ug/m3 as an 8-hour time weighted average.  Sampling was conducted for 164 minutes and a zero increment was added for the 316 minutes not sampled.   Observed on or about 4/5/13.    Note:  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 15919010

General-duty citation text

29 CFR 1926.62(g)(2)(viii): The employer did not prohibit the removal of lead from protective clothing or equipment by blowing, shaking, or any other means that dispersed lead into the air:  a) Oxford Mills, East and West Buildings - Employees performing abrasive blasting removed the dust from their coveralls  by shaking them and by blasting them with compressed air, exposing the employees to lead.  Employees are required to wear coveralls or other similar whole body clothing as interim protection during abrasive blasting operations.  Wipe and bulk sampling of the dust from the abrasive blasting operation in the West Building contained lead.  Observed on or about 4/5/13.    Note:  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Sep 25, 2013

Abate by

Oct 15, 2013

Penalty

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

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(h)(1): "All surfaces shall be maintained as free as practicable of accumulations of lead".  a) Oxford Mills, West Building - Employees worked, stored their equipment and supplies and put on their personal protective equipment in the blasting prep room.  The employer did not maintain surfaces in the blasting prep room as free as practicable of accumulations of lead, exposing employees to lead.  A bulk sample of the dust on the floor of the blasting prep room on 4/8/13 contained lead.  Observed on or about 4/5/13.    b) Oxford Mills, East and West Buildings - Employees performed abrasive blasting of the interior surfaces in the East and West Buildings.  The employer did not maintain surfaces in East and West Buildings Bulk as free as practicable of accumulations of lead, exposing employees to lead.  Bulk and wipe samples of the dust on floors and surfaces in the East and West Buildings taken on 4/5/13, 4/8/13, 5/13/13 and 7/5/13 and 7/10/13, after the blasting and cleanup operations were performed contained lead in amounts ranging from 317 to 3829 micrograms/100 square centimeters.      Note:   Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(h)(2): Where  possible, clean-up of floors and other surfaces where lead accumulated was not accomplished by vacuuming or other methods that minimized the likelihood of lead becoming airborne:  a) Oxford Mills, East and West Building -  Cleanup of floors and other surfaces where dust containing lead accumulated after abrasive blasting of interior brick walls, wood beams, wood ceilings, metal beams and metal columns in the East and West Buildings was performed by blowing, dry sweeping and shoveling, and vacuuming with a vacuum that was not equipped with HEPA filters, exposing employees to lead.  Observed on or about 4/5/13.  b) Oxford Mills, West Building - Cleanup of floors and other surfaces where lead accumulated after abrasive blasting of the end room on the north side was performed by dry sweeping.  The cleanup of the dust was not performed by vacuuming or other methods that minimized the likelihood of lead becoming airborne, exposing employees to lead.  Employee exposure monitoring on 7/10/13 results showed that employees were exposed to lead in amounts which exceeded the permissible exposure limit (PEL) of 50 micrograms per cubic meter.  Observed on or about 7/10/13.     Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(h)(3): Shoveling, dry or wet sweeping, and brushing were used when vacuuming or other equally effective methods were effective:  a) Oxford Mills, East and West Building - The employer did not provide a vacuum with HEPA filters for cleaning the dust after abrasive blasting.  Employees used dry sweeping and shoveling to clean the dust from abrasive blasting of the interior surfaces in the East and  West Buildings, exposing employees to lead.  Samples of the dust in the East and West Buildings after blasting and cleanup were completed contained lead, in amounts ranging from 317 to 3829 micrograms lead per 100 cubic centimeters.  Observed on or about 4/5/13.      b) Oxford Mills, West Building - The employer did not provide a HEPA vacuum for cleaning the surfaces after abrasive blasting of the interior brick walls of the north end of the west building, exposing employees to lead.  Employees swept and shoveled the dust into buckets, exposing employees to lead.   Employee exposure monitoring during cleanup operations on 7/10/13 showed that employees were exposed to lead in amounts which exceeded the permissible exposure limit of 50 micrograms per cubic meter.    Note:   Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(h)(4): Where vacuuming methods were selected, the vacuums were not equipped with HEPA filters and/or were not used and emptied in a manner which minimized the reentry of lead into the workplace:  a) Oxford Mills, East and West Buildings -  Cleanup of floors and other surfaces where lead accumulated after abrasive blasting of interior brick walls, wood beams and ceiling, and metal beams and columns was performed by vacuuming with a vacuum that was not equipped with a HEPA filter, exposing employees to lead.  Wipe and bulk samples of the dust on floors and surfaces in the East and West Buildings after blasting and cleanup were completed amounts ranging from 317 to 3829 micrograms of lead per 100 square centimeters.  Observed on or about 4/8/13.  Note:   Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(h)(5): Compressed air shall not be used to remove lead from any surface unless the compressed air is used in conjunction with a ventilation system designed to capture the airborne dust created by the compressed air.  a) Oxford Mills, East and West Building -  Employees cleaned floors and other surfaces where dust containing lead accumulated after abrasive blasting of interior brick walls, wood beams, wood ceilings, metal beams and metal columns by blowing with compressed air.  A ventilation system was not used in conjunction with the compressed air, exposing employees to lead.  Wipe and bulk samples of the dust after blasting and cleanup were performed, contained lead, in amounts ranging from 317 to 3829 micrograms per 100 square centimeters.  Observed on or about 4/8/13.      Note: Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $1,600 · Current $800 Reduced

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(i)(2)(i): The employer did not provide clean change areas for employees whose airborne exposure to lead was above the permissible exposure limit, and as interim protection for employees performing tasks as specified in paragraph (d)(2) of this section, without regard to the use of respirators:    a) Oxford Mills, East and West Buildings - The employer did not provide clean change areas as interim protection for employees who performed abrasive blasting of the interior surfaces in the East and West Buildings, exposing employees to lead.  Observed on or about 4/5/13.    b) Oxford Mills, West Building - The employer did not provide clean change areas for employees who performed abrasive blasting of the interior brick surface of the end room on the north side of the West Building, exposing employees to lead.   Employee exposure monitoring on 7/3/13 showed that an employee performing abrasive blasting was exposed to lead in amounts which exceeded the Permissible Exposure Limit of 50 micrograms per cubic meter (ug/m3) as an 8-hour time weighted average.     c) Oxford Mills, West Building - The employer did not provide clean change areas for employees performing clean-up activities after abrasive blasting of the interior brick surface in the end room on the north side of the West Building.  Employee exposure  monitoring on 7/10/13 showed that an employee was exposed to lead in amounts which exceeded the Permissible Exposure Limit (PEL)  of 50 ug/m3 of lead as an 8-hour time weighted average.     Note:  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Sep 25, 2013

Abate by

Oct 1, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(i)(3)(i): The employer did not provide shower facilities, where feasible, for use by employees whose airborne exposure to lead was above the permissible exposure limit:  a) Oxford Mills, East and West Buildings - The employer did not provide shower facilities, for use by employees performing abrasive blasting and cleanup operations, exposing employees to lead.  Employee exposure monitoring on 7/3/13 and 7/10/13 showed that employees performing abrasive blasting and cleanup operations were exposed to lead in excess of the Permissible Exposure Limit of 50 micrograms/cubic meter.      Note:  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Sep 25, 2013

Penalty

Initial $0 · Current $0

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(i)(5)(i): The employer shall provide adequate handwashing facilities for use by employees exposed to lead in accordance with 29 CFR 1926.51(f).  a) Oxford Mills, East and West Buildings - Employees exposed to lead during abrasive blasting and cleanup activities were provided with a spigot with no drain, in the basement of the West Building.  Employees were not provided with soap and hand towels, exposing employees to lead.  Observed on or about 4/5/13.    Note:  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Sep 25, 2013

Abate by

Oct 15, 2013

Penalty

Initial $2,400 · Current $1,200 Reduced

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(j)(1)(i): The employer did not make available initial medical surveillance, consisting of biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels, to employees occupationally exposed on any day to lead at or above the action level:  a) Oxford Mills, East and West Buildings - The employer did not make initial medical surveillance available as interim protection for employees performing abrasive blasting of the interior surfaces in the East and West Buildings as referenced in 1926.62 (d)(2)(iv)(B).  Observed on or about 4/5/13.    b) Oxford Mills, West Building - The employer did not make initial medical surveillance available for employees who abrasive blasting of the interior brick walls on 7/3 and 7/4/13.  Employee exposure monitoring on 7/3/13  showed that employees performing abrasive blasting were exposed to lead in excess of the action level of 30 micrograms per cubic meter (ug/m3).    c) Oxford Mills, West Building - The employer did not make initial medical surveillance available for employees who performed cleanup activities after abrasive blasting, beginning on 7/10/10.   Employee exposure monitoring on 7/10/13 showed that employees performing cleanup activities after abrasive blasting was exposed to lead in excess of the action level of 30 micrograms per cubic meter (ug/m3).   Note:  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Sep 25, 2013

Abate by

Oct 15, 2013

Penalty

Initial $1,200 · Current $600 Reduced

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(l)(1)(ii): The employer did not train each employee who were subject to exposure to lead at or above the action level on any day, or who were subject to exposure to lead compounds which may cause skin or eye irritation (e.g., lead arsenate, lead azide) in accordance with the requirements of 29 CFR 1926.62 and the employer did not institute a training program and ensure employee participation in the program:  a) Oxford Mills, West Building - The employer did not provide training for employees who were exposed to lead above the action level performing abrasive blasting of the interior brick walls beginning on 7/3/13.  Employee exposure monitoring conducted on 7/3/13 showed that  employees performing abrasive blasting were exposed to lead in excess action level of 30 micrograms per cubic meter (ug/m3).    b) Oxford Mills, West Building - The employer did not provide training for employees performing clean-up activities after abrasive blasting was completed, beginning on 7/10/13.   Employee exposure monitoring on 7/10/13 showed that employees performing cleanup activities after abrasive blasting were exposed to lead in excess of the action level of 30 micrograms per cubic meter (ug/m3).    Note:  Abatement certification required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.

Issued

Sep 25, 2013

Abate by

Dec 6, 2013

Penalty

Initial $1,200 · Current $600 Reduced

Hazardous substances 1591BWPB

General-duty citation text

29 CFR 1926.62(m)(1)(i): The employer shall post the following warning signs in each work area where an employee's exposure to lead is above the PEL.      DANGER   LEAD WORK AREA   MAY DAMAGE FERTILITY OR THE UNBORN CHILD   CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM   DO NOT EAT, DRINK OR SMOKE IN THIS AREA    a) Oxford Mills, West Building - The employer did not post warning signs in areas where employees performed abrasive blasting of the interior brick walls in the north end area of the West Building.   Employee exposure monitoring on 7/3/13 showed that an employee performing abrasive blasting was exposed to lead in excess of the permissible exposure limit of 50 micrograms per cubic meter (ug/m3).      b) Oxford Mills, West Building - The employer did not post warning signs in areas where employees performed cleanup activities after abrasive blasting.  Employee exposure monitoring on 7/10/13 showed that an employee performing cleanup activities after abrasive blasting was exposed to lead in excess of the permissible exposure limit of 50 micrograms per cubic meter (ug/m3).      Note:  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states employees and their representatives were informed of this abatement.