OSHA Inspection: PATRIOT METAL PRODUCTS, INC.

Issued

Feb 6, 2014

Penalty

Initial $2,380 · Current $1,785 Reduced

Hazardous substances 9135

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) An employee, powder coater, was exposed to particulates not otherwise regulated (total dust) at an 8 hour time weighted average of 55.17 milligrams per cubic meter of air (mg/M3) while operating the manual powder coat gun.  The employee was required to wear a negative pressure respirator and was not medically evaluated to determine his ability to wear the respirator without suffering adverse health effects, on or about November 5, 2013.     "ABATEMENT OBSERVED DURING INSPECTION - NO CERTIFICATION REQUIRED"     Note:  The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.

Issued

Feb 6, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 9135

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) An employee, powder coater, was exposed to particulates not otherwise regulated (total dust) at an 8 hour time weighted average of 55.17 milligrams per cubic meter of air (mg/M3) while operating the manual powder coat gun.  The employee was required to wear a negative pressure respirator and did not have the fit of his respirator determined, on or about November 5, 2013.     "ABATEMENT OBSERVED DURING INSPECTION - NO CERTIFICATION REQUIRED"

Issued

Feb 6, 2014

Abate by

Mar 26, 2014

Penalty

Initial $2,380 · Current $1,785 Reduced

Hazardous substances 9135

General-duty citation text

29 CFR 1910.1000(a)(2): Employee(s) were exposed to an airborne concentration of Particulates not otherwise regulated (PNOR) - total dust listed in Table Z-1 in excess of the 8 hour Time Weighted Average concentration of 15 milligrams per cubic meter:    (a) An employee, powder coater, was exposed to particulates not otherwise regulated (PNOR) - total dust at an 8 hour time weighted average of 55.17 milligrams per cubic meter of air (mg/M3) while operating the manual powder coat gun.  The exposure was 3.68 times the Permissible Exposure Limit of 15 mg/M3.  The PEL was established to prevent upper respiratory irritation and chronic obstructive disease.  The exposure was established over 413 minutes of personal sampling conducted on November 5, 2013.  Zero exposure was assumed for the unsampled period of time.       "ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED"

Issued

Feb 6, 2014

Abate by

Mar 26, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 9135

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) An employee, powder coater, was exposed to particulates not otherwise regulated (total dust) at an 8 hour time weighted average of 55.17 milligrams per cubic meter of air (mg/M3) while operating the manual powder coat gun.  Feasible administrative or engineering controls were not implemented to reduce the employee exposure, on or about November 5, 2013.      General methods of control would include, but are not limited to the following:  1.  Modify the application booth's gun array so that the areas missed by the robotic pattern are covered.    2.  Lengthen the manual gun length so that the operator's body is located outside the booth when manually coating.    3. Position the operator in an area, either inside the current booth, or outside of it, such that the airflow within the booth is sufficient to remove the airborne powder from the employee's breathing zone.  "ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED"   Abatement Schedule    Step 1 A written detailed plan of abatement shall be submitted to the Area Director outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposures 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.     Step 2 Abatement shall have been completed by the implementation of feasible engineering and /or administrative controls upon verification of their effectiveness in achieving compliance.       Date by Which Violation Must be Abated:    STEP - 1     (30 days)     Date by Which Violation Must be Abated:    STEP - 2     (90 days)

Issued

Feb 6, 2014

Abate by

Mar 5, 2014

Penalty

Initial $1,785 · Current $1,339 Reduced

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(h)(1): A hazard was present or was likely to be present from skin or eye contact with chromium (VI); however, the employer did not provide appropriate personal protective clothing and equipment at no cost to employees, and/or did not ensure that employees used such clothing and equipment:    (a) Employees working on the deck of the plating line had hexavalent chromium deposited on their forearms, at concentrations up to 2.2 micrograms per 100 square centimeters,  and did not wear protective equipment which covered their lower arms, on or about November 15, 2013.    "ABATEMENT CERTIFICATION REQUIRED"

Issued

Feb 6, 2014

Abate by

Mar 26, 2014

Penalty

Initial $2,975 · Current $2,231 Reduced

General-duty citation text

29 CFR 1910.132(a): Protective equipment was not used when necessary whenever hazards capable of causing injury and impairment were encountered:    (a) An employee, powder coater, was exposed to potential static electricity hazards while operating a hand held manual powder coating gun.   Personal protective equipment, which could include static dissipative footwear, grounding ankle strap, or wrist bonding straps were not used to assure operator grounding when the employee was within the powder coating application area, November 5, 2013    Abatement Note: NFPA 77 Recommended Practice on Static Electricity and NFPA 33 Standard for Spray Application Using Flammable or Combustible Materials provide technical guidance and methods of controlling or eliminating the hazards of static electricity.    "ABATEMENT CERTIFICATION REQUIRED"

Issued

Feb 6, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(d)(1): The employer with a workplace or work operation covered by this standard did not determine the 8-hour time-weighted average exposure for each employee exposed to chromium (VI):  (a) Employees working on the plating line were exposed to airborne concentrations of chromium (VI) up to 0.47 micrograms per cubic meter, and an initial monitoring had not been conducted, on or about November 5, 2013.    "ABATEMENT OBSERVED DURING INSPECTION - NO CERTIFICATION REQUIRED"

Issued

Feb 6, 2014

Abate by

Mar 5, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.22(b)(2): Permanent aisles and passageways were not appropriately marked:  a) Plating line, an auxiliary set of stairs used to access the upper deck, were located under an over-head conveyor which carried metal parts.  The parts had the potential to fall off and onto employees, and the floor markings and stair markings directly underneath, did not guide employees to avoid the specific danger area, on or about December 9, 2013.  "ABATEMENT CERTIFICATION REQUIRED"

Issued

Feb 6, 2014

Abate by

Mar 5, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.305(a)(2)(i): Temporary electrical power and lighting installations rated 600 volts, nominal, or less were used for purposes other than those permitted in subparagraphs (A), (B) and (C) of this paragraph:  a) Powder coating booth,  two 120 VAC lights mounted on the exterior of the booth were powered via flexible braided cables run from duplex outlets, through several openings in the booth, and hung across the booth, October 28, 2013.  "ABATEMENT CERTIFICATION RERQUIRED"