OSHA Inspection: P & W FOUNDRY, INC.

Issued

Jan 21, 2014

Abate by

Mar 10, 2014

Penalty

Initial $2,800 · Current $1,000 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.134(c)(1): A written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented for required respirator use:     a) The employer failed implement a respiratory protection program for a grinder in the Grinding Department who was exposed lead at an 8-hour TWA (time weighted average) of 0.981 mg/m3, approximately 19.6 times the limit of 0.05 mg/m3.    The grinder voluntarily wore a 3M 8511 filtering facepiece (dust mask), in which found to be inadequate while lead levels exceeded the maximum use concentration (MUC) for dust mask being used.     The employer failed to implement a respiratory protection program that shall include the following:   (1) Select an adequate respirator for protection against lead exposure within the Grinding Department.   (2) Provide medical evaluations for employees within the Grinding Department.   (3) Provide fit testing for employees within the Grinding Department   (4) Train employees on the proper use and maintenance of respirators being worn.      Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Jan 21, 2014

Abate by

Jul 3, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 0730

General-duty citation text

29 CFR 1910.1000(a)(1): Employee(s) were exposed to an airborne concentration of copper dust listed in Table Z-1 in excess of the ceiling concentration of 1.0 mg/m3:      a) A grinder within the Grinding Department was exposed to an 8-hour TWA (Time Weighted Average) of copper grinding dust at 1.49 mg/m3, approximately 1.49 time the limit of 1.0 mg/m3. The samples were collected on 8/15/13 during a 355 minute sampling period. Exposure calculations include a zero increment 125 minutes not sampled.       Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Jan 21, 2014

Abate by

Jul 3, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 0730

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):        a) A grinder within the Grinding Department was exposed to an 8-hour TWA (Time Weighted Average) of copper grinding dust at 1.49 mg/m3, approximately 1.49 time the limit of 1.0 mg/m3. The samples were collected on 8/15/13 during a 355 minute sampling period. Exposure calculations include a zero increment 125 minutes not sampled.   Feasible engineering controls include, but are not limited to:     (1) Installation of local exhaust ventilation during grinding and cutting operations within the grinding room.                       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 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/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.     All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person. 90 day process reports are required during the abatement period.        Step 3:  Abatement shall have been completed by the implementation of feasible engineering controls and/or administrative controls upon verification of their effectiveness in achieving compliance.          Date by which Step 1 must be abated:  00/00/00    Date by which Step 2 must be abated:  00/00/00   Date by which Step 3 must be abated:  00/00/00    Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Jan 21, 2014

Abate by

Jul 3, 2014

Penalty

Initial $0 · Current $0

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) A grinder within the Grinding Department was exposed to lead at an 8-hour TWA (Time Weighted Average) of 0.30 mg/m3, approximately 6 times the limit of 0.05 mg/m3; this limit is established to prevent high blood lead exposure. The samples were collected on 8/15/13 during a 350 minute sampling period. Exposure calculations include a zero increment for the 130 minutes not sampled.      a) A grinder within the Grinding Department was exposed to lead at an 8-hour TWA (Time Weighted Average) of 0.981 mg/m3, approximately 19.6 times the limit of 0.05 mg/m3; this limit is established to prevent high blood lead exposure. The samples were collected on 8/15/13 during a 355 minute sampling period. Exposure calculations include a zero increment for the 125 minutes not sampled    Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Jan 21, 2014

Abate by

Jul 3, 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) were not implemented to reduce and maintain employee exposure to lead.    a) A grinder within the Grinding Department was exposed to lead at an 8-hour TWA (Time Weighted Average) of 0.30 mg/m3, approximately 6 times the limit of 0.05 mg/m3; this limit is established to prevent high blood lead exposure. The samples were collected on 8/15/13 during a 350 minute sampling period. Exposure calculations include a zero increment for the 130 minutes not sampled.      b) The grinder in the Grinding Department was exposed to lead at an 8-hour TWA (Time Weighted Average) of 0.981 mg/m3, approximately 19.6 times the limit of 0.05 mg/m3; this limit is established to prevent high blood lead exposure. The samples were collected on 8/15/13 during a 355 minute sampling period. Exposure calculations include a zero increment for the 125 minutes not sampled.    Feasible engineering controlls include, but are not limited to:    (1) Installation of local exhaust ventilation during grinding and cutting operations within the grinding room.           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 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/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.     All proposed control measures shall be approved for each particular use by a competent industrial hygenist or other technically qualified person. 90 day process reports are required during the abatement period.      Step 3:  Abatement shall have been completed by the implementation of feasible engineering controls and/or administrative controls upon verification of their effectiveness in achieving compliance.         Date by which Step 1 must be abated:  00/00/00       Date by which Step 2 must be abated:  00/00/00      Date by which Step 3 must be abated:  00/00/00      Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Jan 21, 2014

Abate by

Jul 3, 2014

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:      The employer failed to implement and establish a written compliance programs to reduce lead exposures at or below the permissble exposure limit (PEL) for the following:    a) A grinder within the Grinding Department was exposed to lead at an 8-hour TWA (Time Weighted Average) of 0.30 mg/m3, approximately 6 times the limit of 0.05 mg/m3; this limit is established to prevent high blood lead exposure. The samples were collected on 8/15/13 during a 350 minute sampling period. Exposure calculations include a zero increment for the 130 minutes not sampled.      b) A grinder within the Grinding Department was exposed to lead at an 8-hour TWA (Time Weighted Average) of 0.981 mg/m3, approximately 19.6 times the limit of 0.05 mg/m3; this limit is established to prevent high blood lead exposure. The samples were collected on 8/15/13 during a 355 minute sampling period. Exposure calculations include a zero increment for the 125 minutes not sampled.    Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Jan 21, 2014

Abate by

Mar 10, 2014

Penalty

Initial $2,800 · Current $1,000 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(g)(1): Appropriate protective work clothing and equipment were not provided at no cost to the employee 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) The employer failed to assure employees who were exposed airborne lead concentrations above OSHA's Permissible Exposure Limit (PEL) of 0.05 mg/m3 were provided protective clothing and equipment at no cost.     Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Jan 21, 2014

Abate by

Mar 10, 2014

Penalty

Initial $2,800 · Current $1,000 Reduced

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) The employer failed to assure employees who were exposed airborne lead concentrations above OSHA's Permissible Limit (PEL) of 0.05 mg/m3 showered at the end of the work shift.     Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Jan 21, 2014

Abate by

Mar 10, 2014

Penalty

Initial $2,800 · Current $1,000 Reduced

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 that thirty days per year.      a) The employer failed to establish a medical surveillance program for employees who were exposed airborne lead concentrations above OSHA's Permissible Exposure Limit (PEL) of 0.05 mg/m3.      Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Jan 21, 2014

Abate by

Mar 10, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(j)(2)(i): The employer did not make available biological monitoring, including blood sampling and analysis for lead and zinc protoporphyrin levels for each employee covered under 29 CFR 1910.1025 (j)(1)(i):   a) The employer did not make available biological monitoring for employees who were exposed airborne lead concentrations above OSHA's Permissible Exposure Limit (PEL) of 0.05 mg/m3.    Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Jan 21, 2014

Abate by

Mar 10, 2014

Penalty

Initial $2,800 · Current $1,000 Reduced

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) The employer failed to inform employees on the physical and health hazards of lead while performing job task such as cutting and grinding on brass/bronze castings. Employees within the grinding area were exposed to airborne lead concentrations above OSHA's Permissible Exposure Limit (PEL) of 0.05 mg/m3.      Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Jan 21, 2014

Abate by

Mar 10, 2014

Penalty

Initial $2,800 · Current $0 Reduced

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) The employer failed to post warning signs for lead exposure within the grinding area where employees performed job tasks such as cutting and grinding on brass/bronze castings. Employees were exposed to airborne lead concentrations above OSHA's Permissible Exposure Limit (PEL) of 0.05 mg/m3.      Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).