OSHA Inspection: INDUSTRIAL CONSTRUCTION SERVICES AND DESIGN, INC.

Issued

Feb 7, 2014

Penalty

Initial $0 · Current $3,500

Hazardous substances 15911592

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.   On or about October 17, 2013, an employee, welder, who was welding on structural steel during the installation of a new ventilation system was exposed to an 8 hour time weighted average (TWA) of 108 micrograms of inorganic lead per cubic meter of air.  This level is 2.16 times the permissible exposure limit of 50 micrograms per cubic meter of air.  This exposure occurred over a 420 minute sampling period.  A zero exposure was assumed for the 60 minutes not sampled.       Feasible abatement methods include but are not limited to:    1.)  Provided localized exhaust ventilation to remove welding fume during the welding operation.  2.) Remove lead contamination or lead paint prior to conducting any welding operations.     No abatement certification or documentation required.

Issued

Feb 7, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 15911592

General-duty citation text

29 CFR 1926.62(f)(2)(i): The employer did not implement a respiratory protection program in accordance with 29 CFR 1910.134(b) through (d) (except (d)(1)(iii)), and (f) through (m) for each employee required by 29 CFR 1926.62 to use a respirator:     a. Hammond Lead Site - On or about October 17, 2013, an employee, welder, who was welding on structural steel during the installation of a new ventilation system was exposed to an 8 hour time weighted average (TWA) of 108 micrograms of inorganic lead per cubic meter of air.  This level is 2.16 times the permissible exposure limit of 50 micrograms per cubic meter of air.  This exposure occurred over a 420 minute sampling period.  A zero exposure was assumed for the 60 minutes not sampled

Issued

Feb 7, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.134(f)(2): Employee(s) using tight-fitting face piece respirators were not fit tested prior to initial use of the respirator:      a. Hammond Lead Site - On or about October 17, 2013, an employee, welder, who was welding on structural steel during the installation of a new ventilation system was exposed to an 8 hour time weighted average (TWA) of 108 micrograms of inorganic lead per cubic meter of air.  This level is 2.16 times the permissible exposure limit of 50 micrograms per cubic meter of air.  This exposure occurred over a 420 minute sampling period.  A zero exposure was assumed for the 60 minutes not sampled  The employer did not provide respirator fit testing for employee required to wear 3M 8293 or Moldex 2730 negative pressure respirators who was exposed to the hazards of lead in excess of the Permissible Exposure Limit (PEL).     Note: 29 CFR 1926.62(f)(2)(i): The employer did not implement a respiratory protection program in accordance with 29 CFR 1910.134(b) through (d) (except (d)(1)(iii)), and (f) through (m) for each employee required by 29 CFR 1926.62 to use a respirator.

Issued

Feb 7, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 15911592

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 face piece and exhalation valve:        a.  On or about October 17, 2013, an employee, welder, who was welding on structural steel during the installation of a new ventilation system was exposed to an 8 hour time weighted average (TWA) of 108 micrograms of inorganic lead per cubic meter of air.  This level is 2.16 times the permissible exposure limit of 50 micrograms per cubic meter of air.  This exposure occurred over a 420 minute sampling period.  A zero exposure was assumed for the 60 minutes not sampled  The employees did not properly store respirators when not in use, by placing them on lead contaminated surfaces.

Issued

Feb 7, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.134(k): Training and information.  The employer did not provide effective training to employees who are required to use respirators:    a. Hammond Lead Site -  On or about October 17, 2013, an employee, welder, who was welding on structural steel during the installation of a new ventilation system was exposed to an 8 hour time weighted average (TWA) of 108 micrograms of inorganic lead per cubic meter of air.  This level is 2.16 times the permissible exposure limit of 50 micrograms per cubic meter of air.  This exposure occurred over a 420 minute sampling period.  A zero exposure was assumed for the 60 minutes not sampled.  The employer did not provide respirator training for employee required to wear 3M8293 or Moldex 2730 negative pressure respirators, who was exposed to the hazards of lead in excess of the Permissible Exposure Limit (PEL).

Issued

Feb 7, 2014

Penalty

Initial $3,500 · Current $3,500

Hazardous substances 15911592

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. Hammond Lead Plant - On or about October 17, 2013, The employer did not establish and implement a written compliance program which included the following for employees exposed to the hazards of lead:          - A description of each activity in which lead is emitted; e.g. equipment used, material involved, controls in place, crew size, employee job responsibilities, operating procedures and maintenance practices;1926.62(e)(2)(ii)(B).   - A description of the specific means that will be employed to achieve compliance and, where engineering controls. are required engineering plans and studies used to determine methods selected for controlling exposure to lead;1926.62(e)(2)(ii)(C).   - A report of the technology considered in meeting the PEL;1926.62(e)(2)(ii)(D) Air monitoring data which documents the source of lead emissions;1926.62(e)(2)(ii)(E).    - A detailed schedule for implementation of the program, including documentation such as copies of purchase orders for equipment, construction contracts, etc.;1926.62(e)(2)(ii)(F).    - A work practice program which includes items required under paragraphs (g), (h) and (i) of this section and incorporates other relevant work practices such as those specified in paragraph (e)(5) of this section;1926.62(e)(2)(ii)(G).    - An administrative control schedule required by paragraph (e)(4) of this section, if applicable;1926.62(e)(2)(ii)(H).    - A description of arrangements made among contractors on multi-contractor sites with respect to informing affected employees of potential exposure to lead and with respect to responsibility for compliance with this section as set-forth in 1926.16.1926.62(e)(2)(ii)(I).       NOTE: The compliance program shall provide for frequent and regular inspections of job sites, materials, and equipment to be made by a competent person.

Issued

Feb 7, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 15911592

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 micro-grams per cubic meter of air calculated as an 8-hour time-weighted average (TWA):      a.  On or about October 17, 2013, an employee, welder, who was welding on structural steel during the installation of a new ventilation system was exposed to an 8 hour time weighted average (TWA) of 108 micrograms of inorganic lead per cubic meter of air.  This level is 2.16 times the permissible exposure limit of 50 micrograms per cubic meter of air.  This exposure occurred over a 420 minute sampling period.  A zero exposure was assumed for the 60 minutes not sampled.

Issued

Feb 7, 2014

Penalty

Initial $3,500 · Current $3,500

Hazardous substances 15911592

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. Hammond Lead Plant -  On or about October 17, 2013, an employee, welder, who was welding on structural steel during the installation of a new ventilation system was exposed to an 8 hour time weighted average (TWA) of 108 micrograms of inorganic lead per cubic meter of air.  This level is 2.16 times the permissible exposure limit of 50 micrograms per cubic meter of air.  This exposure occurred over a 420 minute sampling period.  A zero exposure was assumed for the 60 minutes not sampled.  The employer did not provide a training program in accordance with paragraph (l)(2) of this section, for employees exposed to the hazards of lead while working on lead contaminated structural steel.

Issued

Feb 7, 2014

Abate by

Mar 14, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 15911592

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. Hammond Lead Site -    On or about October 17, 2013, an employee, welder, who was welding on structural steel during the installation of a new ventilation system was exposed to an 8 hour time weighted average (TWA) of 108 micrograms of inorganic lead per cubic meter of air.  This level is 2.16 times the permissible exposure limit of 50 micrograms per cubic meter of air.  This exposure occurred over a 420 minute sampling period.  A zero exposure was assumed for the 60 minutes not sampled.   A zero exposure was assumed for the 60 minutes not sampled.  The employer did not provide zinc protoporphyrin testing.