OSHA Inspection: NORTH AMERICAN POLYMER COMPANY, LTD

Issued

Dec 26, 2013

Abate by

Feb 13, 2014

Penalty

Initial $1,200 · Current $720 Reduced

Hazardous substances 17302460A614

General-duty citation text

29 CFR 1910.134(c)(1)(i): The written respiratory protection program did not contain procedures for selecting respirators for use in the workplace:    (a) Paint Processing Room, Spray Booth, Corrosive Processing Room - Employees use full facepiece supplied air  respirators and half mask respirators with combination cartridges when pouring Low Odor Stripper (contains methylene chloride, methanol and ammonium hydroxide) and Overspray & Gun Cleaner (contains methylene chloride and toluene). Procedures for the selection of these respirators were not included in the employer's written repiratory protection program.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Dec 26, 2013

Abate by

Feb 13, 2014

Penalty

Initial $2,000 · Current $1,200 Reduced

Hazardous substances 1730A614T247

General-duty citation text

29 CFR 1910.134(d)(1)(ii): The employer did not select and use a NIOSH-certified respirator in compliance with the conditions of its certification:    (a) Corrosive Processing Room - On October 16, 2013, an employee wore a Bullard supplied air hood with hose and other components of the Axis Air Group, Inc. supplied air system, while dispensing Low Odor Stripper (contains methylene chloride) from 5 gallon containers into 1 gallon containers. This supplied air system is not NIOSH-approved.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Dec 26, 2013

Abate by

Feb 13, 2014

Penalty

Initial $2,000 · Current $1,200 Reduced

Hazardous substances 166017302460A614

General-duty citation text

29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee was fit tested or required to use the respirator in the workplace:    (a) Paint Processing Room, Corrosive Processing Room, Spray Booth - Employees pouring Low-Odor Stripper and Overspray & Gun Cleaner are required to wear supplied air hoods and full facepiece and half mask respirators and they have not  been provided a medical evaluation.     Note:  The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Dec 26, 2013

Abate by

Feb 13, 2014

Penalty

Initial $2,000 · Current $1,200 Reduced

Hazardous substances 0175166017302460

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:    (a) Paint Processing Room, Spray Booth, Corrosive Processing Room - Employees were required to use full facepiece respirators with supplied air and half mask respirators when dispensing Low Odor Stripper in the Corrosive Processing Room and Spray Booth; and, when dispensing Overspray & Gun Cleaner in the Paint Processing Room and they were not fit tested.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Dec 26, 2013

Abate by

Feb 13, 2014

Penalty

Initial $1,600 · Current $960 Reduced

Hazardous substances 16601730A614

General-duty citation text

29 CFR 1910.134(h)(2)(i): Respirators were not stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals or were not packed or stored to prevent deformation of the facepiece and exhalation valve:    (a) Corrosive Processing Room - Supplied air respirator hoses and hood were stored in this room. These items were not stored in an air-tight container or plastic bag away from moisture and damaging chemicals, such as hydrofluoric acid and sulfuric acid.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Dec 26, 2013

Abate by

Feb 13, 2014

Penalty

Initial $2,000 · Current $1,200 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(d)(2): The employer did not perform initial monitoring to determine each employee's exposure to methylene chloride:    Initial monitoring to measure employee exposure to methylene chloride was not performed when:    a) an employee poured Low Odor Stripper (contains 67% methylene chloride) in the spray booth in mid-August, 2013, and,    b) an employee poured Overspray & Gun Cleaner (contains 57.84% methylene chloride) in the Paint Processing Room on or about September 17, 2013.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Dec 26, 2013

Abate by

Feb 13, 2014

Penalty

Initial $2,000 · Current $1,200 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(l)(1): The employer did not provide information and training for each affected employee prior to or at the time of initial assignment to a job involving potential exposure to methylene chloride:    a) Employees poured Low Odor Stripper (contains 67% methylene chloride), Super Orange Stripper (contains 80-85% methylene chloride) and Overspray & Gun Cleaner (contains 57.84% methylene chloride) and they were not provided information and training about the hazards of methylene chloride prior to or at the time of initial assignment to a job involving exposure to methylene chloride.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Dec 26, 2013

Abate by

Feb 13, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(l)(3)(i): The employer did not inform each affected employee of the requirements of 29 CFR 1910.1052 and the information available in its appendices and/or how to access or obtain a copy of it in the workplace:    a) Employees poured Low Odor Stripper (contains 67% methylene chloride), Super Orange Stripper (contains 80-85% methylene chloride) and Overspray & Gun Cleaner (contains 57.84% methylene chloride) and they were not informed of the requirements of the methylene chloride standard, the information available in it appendices or how to obtain a copy of it in the workplace.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Dec 26, 2013

Abate by

Jan 23, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 17309965

General-duty citation text

29 CFR 1910.1200(h)(3): The employee hazard communication training did not include the requirements of 29 CFR 1910.1200(h)(3)(i) through (h)(3)(iv):  a) Employees poured Low Odor Stripper (contains 67% methylene chloride), Super Orange Stripper (contains 80-85% methylene chloride), Overspray & Gun Cleaner (contains 57.84% methylene chloride) and dispensed Universal Catalyst (contains HDI, hexamethylene diisocyanate) and their hazard communication training did not include: methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.); the physical and health hazards of the chemicals in the work area; the measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices and emergency procedures; and, the details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, and how employees can obtain and use the appropriate hazard information.  In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Dec 26, 2013

Penalty

Initial $1,200 · Current $720 Reduced

General-duty citation text

29 CFR 1910.1200(f)(5)(i): The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the identity of the hazardous chemical(s) contained therein:    (a) Paint Processing Room: A 55 gallon can of waste paint, a half gallon metal can and a half gallon plastic bottle were not labeled, tagged or marked with the identity of the hazardous chemical.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Dec 26, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(f)(5)(ii): The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the appropriate hazard warnings:  (a) Paint Processing Room: A 55 gallon can of waste paint, a half gallon metal can and a half gallon plastic bottle were not labeled, tagged or marked with the appropriate hazard warnings.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.