OSHA Inspection: MIDWEST SPORTING GOODS

Issued

Mar 25, 2014

Abate by

Aug 5, 2014

Penalty

Initial $2,400 · Current $1,200 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(c)(1): The employer shall assure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m(3)) averaged over an 8-hour period (8-hr TWA):    a. On or about January 17, 2014, at the facility's indoor shooting range, an employee required to perform range officer duties was exposed to airborne lead at an 8-hour time-weighted average level of 109 micrograms per cubic meter of air, approximately 2.2 times the permissible exposure limit of 50 micrograms per cubic meter of air (8-hr TWA) during a 60 minute sampling period.  Zero exposure assumed for the 420 minutes not sampled.    b. On or about January 17, 2014, at the facility's indoor shooting range, an employee required to perform range officer duties was exposed to airborne lead at an 8-hour time-weighted average level of 68 micrograms per cubic meter of air, approximately 1.4 times the permissible exposure limit of 50 micrograms per cubic meter of air (8-hr TWA) during a 57 minute sampling period.  Zero exposure assumed for the 423 minutes not sampled.

Issued

Mar 25, 2014

Abate by

Aug 5, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(1): Feasible engineering and work practice controls (including administrative controls) were not implemented to reduce employee exposure to or below the permissible exposure limit:  On or about January 17, 2014, at the facility's indoor shooting range, employees required to perform range officer duties were exposed to airborne lead in excess of the permissible exposure limit (see Citation 1 Item 1a).  Feasible engineering and work practice controls (including administrative controls) were not implemented to reduce employee exposure to or below the permissible exposure limit.  General methods of control that may be applicable to the process include, but are not limited to, the following:  1. Evaluate the efficiency (i.e; capture velocity, duct velocity, static pressure) of the existing supply air and exhaust ventilation system servicing the indoor shooting range.  Airflow along the firing line should be no more than 75 fpm with a minimum acceptable flow of 50 fpm (NIOSH 1976).  The exhaust system should be designed to provide minimum duct air velocities of 2500-3000 fpm (Industrial Ventilation Manual, 24th Edition, Table 3-2) [ACGIH 2004].  2. Use jacketed or non-lead bullets.  Abatement normally will be multistep as follows:  STEP 1: Effective respiratory protection in accordance with 29 CFR 1910.134 shall be provided and used by exposed employees as an interim protection 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.  Abatement period: 30 days  STEP 2: Submit to the Area Director, a written detailed plan of abatement outlining a schedule for the implementation of engineering measures to control employee exposure to lead.  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 control options; 2. Selection of optimum control methods and completion design; 3. Procurement, installation, and operation of selected control measures; 4. Testing and acceptable 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.  Abatement Period: 60 days  STEP 3: Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.  Abatement Period: 90 days

Issued

Mar 25, 2014

Abate by

Aug 5, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(3)(i): Each employer shall establish and implement a written compliance program to reduce exposures to or below the permissible exposure limit, and interim levels if applicable, solely by means of engineering and work practice controls:  On or about January 17, 2014, at the facility's indoor shooting range, employees required to perform range officer duties were exposed to airborne lead in excess of the permissible exposure limit (see Citation 1, Item 1a).  A written compliance program was not established and/or implemented to reduce lead exposures to or below the permissible exposure limit solely by means of engineering and work practice controls.

Issued

Mar 25, 2014

Abate by

Aug 5, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(4)(i): When ventilation is used to control exposure, measurements which demonstrate the effectiveness of the system in controlling exposure, such as capture velocity, duct velocity, or static pressure shall be made at least every 3 months. Measurements of the system's effectiveness in controlling exposure shall be made within 5 days of any change in production, process, or control which might result in a change in employee exposure to lead:  On or about January 17, 2014, at the facility's indoor shooting range, employees required to perform range officer duties were exposed to airborne lead in excess of the permissible exposure limit (see Citation 1, Item 1a).  Measurements which demonstrate the effectiveness of the available ventilation system in controlling exposure was not made at least every 3 months.

Issued

Mar 25, 2014

Abate by

May 9, 2014

Penalty

Initial $2,400 · Current $1,200 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(g)(1): If an employee is 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, the employer shall provide at no cost to the employee and assure that the employee uses appropriate protective work clothing:    On or about January 17, 2014, at the facility's indoor shooting range, employees required to perform range officer duties were exposed to airborne lead above the PEL (see Citation 1, Item 1a).  Appropriate protective work clothing, including, but not limited to, coveralls or similar full-body work clothing, was not used.

Issued

Mar 25, 2014

Abate by

May 9, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(i)(2)(i): The employer shall provide clean change rooms for employees who work in areas where their airborne exposure to lead is above the PEL, without regard to the use of respirators:  On or about January 17, 2014, at the facility's indoor shooting range, employees required to perform range officer duties were exposed to airborne lead above the PEL (see Citation 1, Item 1a).  Clean change rooms were not provided for affected employees.

Issued

Mar 25, 2014

Abate by

May 9, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(i)(3)(i): The employer shall assure that employees who work in areas where their airborne exposure to lead is above the PEL, without regard to the use of respirators, shower at the end of the work shift:  On or about January 17, 2014, at the facility's indoor shooting range, employees required to perform range officer duties were exposed to airborne lead above the PEL (see Citation 1, Item 1a).  Employees were not required to shower at the end of the work shift.

Issued

Mar 25, 2014

Abate by

May 9, 2014

Penalty

Initial $2,400 · Current $1,200 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(j)(1)(i): The employer shall institute a medical surveillance program for all employees who are or may be exposed at or above the action level for more than 30 days per year:    On or about January 17, 2014, at the facility's indoor shooting range, employees required to perform range officer duties were exposed to airborne lead in excess of the permissible exposure limit (see Citation 1, Item 1a).  A medical surveillance program including blood lead and zinc protoporphyrin (ZPP) level sampling and analysis was not instituted for all affected employees.

Issued

Mar 25, 2014

Abate by

Jun 30, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 8111

General-duty citation text

29 CFR 1910.95(g)(1): The employer shall establish and maintain an audiometric testing program as provided in this paragraph by making audiometric testing available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 decibels:    a. On or about January 17, 2014, at the facility's indoor shooting range, an employee required to perform range officer duties was exposed to noise at an 8-hour time-weighted average of 89.6 decibels during a 59 minute sampling period.  Exposure calculation included a zero increment for the 421 minutes not sampled.      b. On or about January 17, 2014, at the facility's indoor shooting range, an employee required to perform range officer duties was exposed to noise at an 8-hour time-weighted average of 87.1 decibels during a 61 minute sampling period.  Exposure calculation included a zero increment for the 419 minutes not sampled.    Audiometric testing was not made available to all affected employees.