OSHA Inspection: BDDW STUDIO LLC

Issued

Feb 12, 2014

Abate by

Mar 4, 2015

Penalty

Initial $4,900 · Current $3,675 Reduced

Hazardous substances 9210M102

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to the hazard of fire and explosion of wood dust from lack of deflagration vents or deflagration suppression systems, isolation devices on the inlet and outlet side of dust collectors and in dust conveying ductwork, by permitting enclosureless dust collection systems with maximum air handling capacities greater than 5000 cfm to be located inside of buildings, and permitting recycled air from air material separators air to be exhausted inside the building:       a) BDDW Studio LLC, Rough Mill and Solid Wood - Employees were potentially exposed to severe burn injuries in that the two enclosureless Extrema Typhoon 3000 Series Modular Dust Collectors, with a maximum air handling capacity of 10,000 cfm, were located inside the building and were not equipped with  deflagration vents or a deflagration suppression system and an isolation device was not provided on the inlet side of the dust collector and in the dust conveying ductwork to prevent fires and deflagrations from propagating from the dust collector back through the inlet ductwork to the woodworking equipment.   Observed on or about 8/15/13.      b) BDDW Studio LLC, Rough Mill ? Employees were potentially exposed to severe burn injuries in that the Extrema DCY 1425 L3 (Extrema Magnum Series Mass Storage Dust Collector) with a maximum air handling capacity of 10,500 cfm was located inside the building and was not equipped with deflagration vents or deflagration suppression systems, and isolation device separating it from the woodworking machinery and from the Extrema Typhoon 3000 Series Modular Dust Collector to which it was connected via ductwork.  Observed on or about 8/15/13.      c) BDDW Studio LLC, Rough Mill - Employees were potentially exposed to severe burn injuries in that open top 55 gallon rubber trash cans were used to collect dust from the Extrema DCY 1425 L3 (Extrema Magnum Series Mass Storage Dust Collector) as well as the enclosureless Extrema Typhoon 3000 Series Modular Dust Collector, and an air gap of approximately 1? existed between the dust collectors and the rubber trash cans.  Observed on or about 8/15/13.      d)  BDDW Studio LLC, 2nd Floor Sanding Room ? Employees were potentially exposed to severe burn injuries in that the Torit Downflo Checkerboard Dust Collector Model SDF 6, S/N IG383000-001 with an operating range of 1000 to 4000 cfm which collected exhausted air directly from two downdraft sanding tables and from the room with six Grizzly vacuum sanding tables, and exhaust air from the dust collector was recycled back into the room.  The dust collector was not equipped with deflagration relief vents or a deflagration suppression system, as well as isolation devices to prevent fires and deflagrations from propagating from the dust collector into the sanding room and through the ductwork to the sanding tables.   Observed on or about 8/15/13.      ABATEMENT NOTE: Among other methods, one feasible and acceptable method to correct these conditions noted includes following the National Fire Protection Association (NFPA) 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, 2007 Edition, including, but not limited to:    Instances a and b:  Relocate enclosureless dust collectors that exceed 5000 cfm as their maximum air-handling capacity outdoors (NFPA 664, Chapter 8, Section 8.2.2.5.1.4)    Install approved deflagration devices, isolation devices, and explosion protection systems in the dust collectors and dust conveying ductwork in accordance with the requirements noted in NFPA 664 Chapter 8.  Examples of isolation methods would include mechanical isolation (such as rotary airlock valves), chemical isolation (discharge of a chemical extinguishing agent into interconnecting pipe or duct), and flame front diverters (such as backblast dampers and high-speed abort gates).      Instance c:  Equip cyclones and storage bins with deflagration venting or suppression systems (NFPA 664, Chapter 8, Section 8.2.2.5.3 and Section 8.10.3.2, respectively);    Instance d:  Install ductwork venting the exhaust air from the dust collector to the outside of the building.  Install approved deflagration devices, isolation devices, and explosion protection systems in the dust collection systems and ductwork in accordance with the requirements noted in NFPA 664.

Issued

Feb 12, 2014

Abate by

Jul 7, 2014

Penalty

Initial $4,900 · Current $3,675 Reduced

Hazardous substances 9210M102

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) BDDW Select LLC - Personnel were potentially exposed to explosion hazards from the explosive dust that had accumulated on walls, equipment and other surfaces in areas that included, but were not limited to the Rough Mill, Solid Wood, and the 2nd floor Sanding Room.  Dust accumulations were present on beams, joists, equipment/machinery, tops of light fixtures, the tops of pipes/ductwork, ledges, and walls.  Observed on or about 8/15/13.

Issued

Feb 12, 2014

Abate by

Jul 7, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 9210M102

General-duty citation text

29 CFR 1910.22(a)(2): The floor of every workroom shall be maintained in a clean and, so far as possible, a dry condition:    a) BDDW Select LLC - Personnel were potentially exposed to explosion hazards from the explosive dust that had accumulated on the floors of areas that included but were not limited to the Rough Mill, Solid Wood, and the 2nd floor Sanding Room.  Observed on or about 8/15/13.      b) BDDW Select LLC - Employees discarded disposable gloves, respirators, and other debris on the floor throughout the facility, exposing employees to trip hazards.  Observed on or about 8/15/13.

Issued

Feb 12, 2014

Abate by

Jul 7, 2014

Penalty

Initial $0 · Current $0

Hazardous substances M102

General-duty citation text

29 CFR 1910.307(c): Electrical equipment in hazardous (classified) locations was not intrinsically safe, approved for the hazardous (classified) location, or safe for the hazardous (classified) location:       a.  BDDW Studio LLC, Rough Mill and Solid Wood - Electrical equipment including, but not limited to fans, electrical outlet boxes, overhead lights, electric motors, portable radios in a Class II, Division I location, where samples taken identified the presence of combustible dust, was not intrinsically safe, approved for a Class II, Division I location, or safe for a Class II, Division I location.  Observed on or about 8/15/13.        b.  BDDW Studio LLC, 2nd Floor Sanding Room - Electrical equipment including but not limited to portable fans, overhead lights, electrical outlet boxes,  electric iron, motors in the six Grizzly vacuum sanding tables, and a Dayton exhaust fan in a Class II Division I location, where a sample taken identified the presence of combustible dust, was not intrinsically safe, approved for a Class II, Division I location, or safe for a Class II, Division I location.  Observed on or about 8/15/13.

Issued

Feb 12, 2014

Abate by

Jul 7, 2014

Penalty

Initial $2,800 · Current $2,100 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) BDDW Studio LLC - The employer did not establish and implement a hearing conservation program, exposing employees to noise hazards.  An employee grinding brass was exposed to a time weighted average (TWA) of 90.7 dB for a 356 minute time period, with an assumed exposure of zero for the remaining 123 minutes of the 8 hour shift the 8-hour time weighted average was 82.1 % dose.  Observed on or about 8/15/13.       ABATEMENT NOTE:  A hearing conservation program in accordance with the 29 CFR 1910(c) through (o) shall include:     exposure monitoring, audiometric testing, provision of hearing protectors, and training.

Issued

Feb 12, 2014

Abate by

May 5, 2014

Penalty

Initial $3,500 · Current $2,625 Reduced

Hazardous substances 9120M102

General-duty citation text

29 CFR 1910.132(a):  Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact:    a) BDDW Studio LLC, Rough Mill and Solid Wood - Employees did not wear easily removable flame-retardant and non-static generating clothing when they performed activities in which combustible dust became airborne, including opening the dust collectors and changing dust collection bags.  Observed on or about  8/15/13.      b) BDDW Studio LLC, Rough Mill - Employees did not wear easily removable flame-retardant and non-static generating clothing when they performed activities in which combustible dust became airborne, including operating the DC 3000 Series Modular Dust Collector and the DC 1425L3 Dust Collector with an air gap of approximately 1 ft. between the dust collector and the open top 55 gallon rubber trash cans which were used as collection devices.  Observed on or about 8/15/13.      c) BDDW Studio LLC, Rough Mill and Solid Wood - Employees did not wear easily removable flame-retardant and non-static generating clothing when they performed activities in which combustible dust became airborne, including using compressed air to blow dust out of woodworking equipment.  Observed on or about 8/15/13.    d) BDDW Studio LLC, 2nd Floor Sanding Room -  Employees did not wear easily removable flame-retardant and non-static generating clothing when they performed activities in which combustible dust became airborne, including changing the filters in the Grizzly downdraft tables, dumping the dust from the Torit-Downflo dust collector into an open top 55 gallon rubber trash can and sweeping dust from the floor.  Observed on or about 8/15/13.      e) BDDW Studio LLC, 3rd Floor Spray Room and 1st Floor Metal Shop - Employees were not provided with and required to wear faceshields and aprons when they prepared and sprayed wood bleach, ICA SB10A which contains 45 % hydrogen peroxide and is corrosive and SB10B which contains 2 to 7.5% sodium hydroxide and is highly corrosive; and ferric acetate (made at the facility from vinegar, which has a pH of 2.2 and is corrosive, and steel wool); and used B/Ox 311, a metal patina which contains phosphoric acid and selenous acid and is corrosive with a pH of 0 to 2.  Observed on or about 8/15/13.    NOTE:  Among other methods, one feasible abatement method to correct this hazard is to require employees to wear flame-resistant, non-static-generating clothing, including safety shoes that are static-dissipating when employees perform these and other activities in which airborne combustible dust may be generated.

Issued

Feb 12, 2014

Abate by

May 5, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.132(d)(2): The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.      a) BDDW Studio LLC - The employer did not verify that the required workplace hazard assessment to determine what personal protective equipment (PPE) was necessary when employees performed operations where they were exposed to hazardous chemicals, was performed through a written evaluation which identifies the workplace being evaluated and the document as a certification of hazard assessment; the person certifying that the evaluation had been performed, and the dates of the hazard assessment.   Employees were exposed to hazardous chemicals when they sprayed wood with paint, wood bleach and ferric acetate; were exposed to wood dust when they sanded and changed filters and bags on dust collectors; welded, soldered and performed grinding on metals; wiped down wood with oils, and performed other operations.  Observed on or about 8/15/13.

Issued

Feb 12, 2014

Abate by

Mar 4, 2014

Penalty

Initial $4,900 · Current $2,675 Reduced

General-duty citation text

29 CFR 1910.151(c): Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use:    a) BDDW Studio LLC - The employer did provide an eye wash/safety shower or drench hose within the work area for immediate emergency use, when employees were exposed to corrosive liquids which can cause eye and skin burns.  Employees mixed and sprayed wood bleach, ICA SB10A which contains 45 % hydrogen peroxide and is corrosive and SB10B which contains 2 to 7.5% sodium hydroxide and is highly corrosive; sprayed ferric acetate (made at the facility from vinegar, which has a pH of 2.2 and is corrosive, and steel wool); and B/Ox 311, a metal patina which contains phosphoric acid and selenous acid and is corrosive with a pH of 0 to 2.  Observed on or about  8/15/13.

Issued

Feb 12, 2014

Abate by

Jul 7, 2014

Penalty

Initial $4,200 · Current $3,150 Reduced

General-duty citation text

29 CFR 1910.134(c)(1):  In workplaces where respirators were necessary to protect the health of the employees, the employer did not establish and implement a written respiratory protection program with worksite-specific procedures as outlined in 1910.134(c)(1)(i) through (ix):    a) BDDW Studio LLC - Employees were required to wear 3M 6200 and 7502 half-mask air purifying respirators and 3M 8511 N95 filtering facepiece respirators for protection from exposure to wood dust, welding fumes, ferric acetate spray and metal dust, and the employer did not establish and implement a written respiratory protection program, exposing employees to respiratory hazards.    Observed on or about 8/15/13.      ABATEMENT NOTE:  The Respiratory Protection plan shall contain the following work-site specific procedures from 29 CFR 1910.134 (c)(1):             i.            Procedures for selecting respirators for use in the workplace;               ii.         Medical evaluations of employees required to use respirators;               iii.        Fit testing procedures for tight-fitting respirators;               iv.        Procedures for proper use of respirators in routine and reasonably foreseeable                       emergency situations;               v.         Procedures and schedules for cleaning, disinfecting, storing, inspecting,                              repairing, discarding, and otherwise maintaining respirators;               vi.       Procedures to ensure adequate air quality, quantity, and flow of breathing air                       for atmosphere-supplying respirators;               vii.       Training of employees in the respiratory hazards to which they are potentially                 exposed during routine and emergency situations;               viii.      Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance; and              ix.        Procedures for regularly evaluating the effectiveness of the program.

Issued

Feb 12, 2014

Abate by

May 5, 2014

Penalty

Initial $4,900 · Current $2,100 Reduced

General-duty citation text

29 CFR 1910.1200(e)(1): Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, material safety data sheets, and employee information and training will be met, and which also includes the following:    a) BDDW Studio LLC - The employer did not develop and implement a written hazard communication program, which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met.  Employees are exposed to hazardous chemicals including but not limited to:      1.  Watco Danish Oils;    2.  Epoxy Part A and Part B; B/Ox 311, which is corrosive,    3.  Ferric Acetate, a severe skin and respiratory irritant;   4.  ICA SB10A wood bleach which is corrosive;  5.  Metal dusts from grinding operations;  6.  Welding fumes;   7.  Flammable paints and solvents, and    8.  Wood dust.    Observed on or about  8/15/13.

Issued

Feb 12, 2014

Abate by

May 5, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(e)(1)(i): The employer did not develop a list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas):      a) BDDW Studio LLC - The employer did not develop a list of hazardous chemicals used and/or stored in the facility.  Observed on or about 8/16/12.

Issued

Feb 12, 2014

Abate by

May 5, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(f)(5): Except as provided in paragraphs (f)(6) and (f)(7) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information:    a) BDDW Studio LLC, 1st Floor:  Spray bottles containing B/OX 311 and ABC Blackener Precision brand used by the metal shop, were on a shelf and on the floor and were not labelled with the identity and appropriate hazard warnings for the chemicals they contained.  Observed on or about 8/15/13.  Observed on or about  8/15/13.      b) BDDW Studio LLC, 1st floor:  A quart glass bottle used by the metal shop was labelled acetone, but did not include appropriate hazard warnings.  Observed on or about 8/15/13.        c) BDDW Studio LLC,1st Floor:  RioKleen Nickel Pickel solution was in a bath on the hot plate and the bath was not labelled with the identity of the hazardous chemicals it contained and appropriate hazard warnings.  Observed on or about 8/15/13.        d) BDDW Studio LLC, 3rd floor:  Gallon bottles of paint were labelled with the contents and did not include appropriate hazard warnings for the hazardous chemicals contained in the paint.  Observed on or about 8/15/13.

Issued

Feb 12, 2014

Abate by

May 5, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h)(1): Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets.:      a) BDDW Studio LLC - Employees were not provided with effective information and training on physical and health hazards of chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area, exposing employees to serious health and physical hazards including fire and explosion.  Employees were exposed to hazardous chemicals including but not limited to:        1.  Watco Danish Oils;   2.  Epoxy Part A and Part B; B/Ox 311, which is corrosive,    3.  Ferric Acetate, a severe skin and respiratory irritant;   4.  ICA SB10A wood bleach which is corrosive;  5.  Metal dusts from grinding operations;  6.  Welding fumes;  7.  Flammable paints and solvents, and   8.  Combustible dust.    Observed on or about  8/15/13.