OSHA Inspection: POLYWAD, INC.

Issued

May 7, 2014

Abate by

Jun 20, 2014

Penalty

Initial $2,000 · Current $1,100 Reduced

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(e)(2): Initial monitoring was not performed for each workplace, or work operation covered by 29 CFR 1910.1018 to accurately determine the airborne concentration of inorganic arsenic to which employees may be exposed:   a) Employees in the production area were manufacturing ammunition which contained arsenic, on or about December 10, 2013.  The employer did not conduct air monitoring to determine employee exposure to inorganic arsenic.  b) An employee was cleaning the gun range which contained arsenic, on or about March 28, 2014.  The employer did not conduct air monitoring to determine employee exposure to inorganic arsenic.  In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF 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

May 7, 2014

Abate by

Jun 20, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(d)(2): An initial determination was not made to determine if any employee may be exposed to lead at or above the action level:  a) Employees in the production area were manufacturing ammunition which contained lead, on or about December 10, 2013.  The employer did not conduct air monitoring to determine employee exposure to lead.  b) An employee was cleaning the gun range which contained lead, on or about March 28, 2014.  The employer did not conduct air monitoring to determine employee exposure to lead.  In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF 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

May 7, 2014

Abate by

Jun 20, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 0490

General-duty citation text

29 CFR 1910.1027(d)(2)(i): The employer did not monitor employee exposures to cadmium and did not base initial determinations on the monitoring results:     a) Employees in the production area were manufacturing ammunition which contained cadmium, on or about December 10, 2013.  The employer did not determine whether or not materials being handled contained cadmium nor did the employer determine the possibility that employee exposure to cadmium would be at or above the action level.  b) An employee was cleaning the gun range which contained cadmium, on or about March 28, 2014.  The employer did not conduct air monitoring to determine employee exposure to cadmium.  In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF 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

May 7, 2014

Abate by

Jun 20, 2014

Penalty

Initial $2,000 · Current $1,100 Reduced

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(j)(1): Where the possibility of skin or eye irritation from inorganic arsenic existed, the employer did not provide, at no cost, to the employee and did not ensure that employees used the appropriate protective work clothing and equipment:  a) An employee was cleaning the gun range which contained arsenic, on or about March 28, 2014. The employer did not ensure that employees wore personal protective equipment (PPE), such as, but not limited to, coveralls or similar full-body work clothing; hats and shoes or disposable shoe coverlets;  face shields, vented goggles, or other appropriate protective equipment which complies with 1910.133.

Issued

May 7, 2014

Abate by

Jun 20, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(g)(1): Appropriate protective work clothing and equipment were not provided at no cost to the employee when employee(s) were 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:   a) An employee was cleaning the gun range which contained lead, on or about March 28, 2014. The employer did not ensure that employees wore personal protective equipment (PPE), such as, but not limited to, coveralls or similar full-body work clothing; hats and shoes or disposable shoe coverlets;  or other appropriate protective equipment which complies with 1910.133.

Issued

May 7, 2014

Abate by

Jun 20, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 0490

General-duty citation text

29 CFR 1910.1027(i)(1): Where skin or eye irritation was associated with cadmium exposure at any level, the employer did not provide, at no cost to the employee, and ensure that employees used appropriate protective work clothing and equipment that prevented contamination of the employee and the employee's garments:   a) An employee was cleaning the gun range which contained cadmium, on or about March 28, 2014. The employer did not ensure that employees wore personal protective equipment (PPE), such as, but not limited to, coveralls or similar full-body work clothing; hats and shoes or disposable shoe coverlets;  or other appropriate protective equipment which complies with 1910.133.

Issued

May 7, 2014

Abate by

Jun 20, 2014

Penalty

Initial $2,800 · Current $1,680 Reduced

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(k)(1): All surfaces were not maintained as free as practicable of accumulations of inorganic arsenic:   Wipe samples revealed arsenic in the following locations, on or about December 10, 2013: a) Maintenance repair room-12 micrograms b) Armory-22 micrograms c) Door of shooting range-10 micrograms d) Keyboard inside of range-10 micrograms e) Table in shooting range-27 micrograms

Issued

May 7, 2014

Abate by

Jun 20, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(h)(1): All surfaces were not maintained as free as practicable of accumulations of lead:    Wipe samples revealed lead in the following locations, on or about December 10, 2013: a) Maintenance repair room-4,482 micrograms b) Armory-2,317 micrograms c) Jolly 1-90 micrograms d) Door of shooting range-6,805 micrograms e) Keyboard inside of range-5,136 micrograms f) Table in shooting range-20,740 micrograms  In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

May 7, 2014

Abate by

Jun 20, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 0490

General-duty citation text

29 CFR 1910.1027(k)(1): Surfaces were not maintained as free as practicable of accumulations of cadmium:     Wipe samples revealed cadmium in the following locations, on or about December 10, 2013:  a) Maintenance repair room-6.5 micrograms b) Armory-0.026 micrograms c) Door of shooting range-2 micrograms d) Keyboard inside of range-2.4 micrograms e) Table in shooting range-4.7 micrograms     In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

May 7, 2014

Abate by

Jun 20, 2014

Penalty

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

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(p)(1)(ii): The employer did not communicate to employee(s) the hazards of inorganic arsenic, addressing at least the following: cancer; liver effects; skin effects; respiratory irritation; nervous system effects; and acute toxicity effects.  a) Employees in the production area were manufacturing ammunition which contained arsenic, and had not received training containing the biological effects of arsenic exposure, on or about December 10, 2013.    b) An employee was cleaning the gun range which contained arsenic, and had not received training containing the biological effects of arsenic exposure, on or about March 28, 2014.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF 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

May 7, 2014

Abate by

Jun 20, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(l)(1)(ii): The employer did not train each employee who is subject to exposure to lead at or above the action level, or for whom the possibility of skin or eye irritation exists, in accordance with the requirements of 29 CFR 1910.1025:   Employees were manufacturing ammunition and cleaning the gun range which contained lead, and had not received training containing the biological effects of lead exposure, on or about December 10, 2013.   In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF 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

May 7, 2014

Abate by

Jun 20, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 0490

General-duty citation text

29 CFR 1910.1027(m)(4)(i): The employer did not institute a training program for all employees who were potentially exposed to cadmium, ensure employee participation in the program, and maintain a record of the contents of such program:   Employees were manufacturing ammunition and cleaning the gun range which contained cadmium and had not received training containing the biological effects of cadmium exposure, on or about December 10, 2013.   In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF 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

May 7, 2014

Abate by

Jun 20, 2014

Penalty

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

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(h)(2)(ii):  Shoveling, sweeping or brushing methods were used to remove lead accumulations where vacuuming or other equally effective methods had not been tried and found to be ineffective:    a)  Employees were required to clean the production floor by sweeping to remove lead and contaminants on or about December 10, 2013 without having tried and found vacuuming or other methods to be ineffective.    b)  Employees were required to clean the shooting range by sweeping to remove lead and contaminants on or about March 28, 2014 without having tried and found vacuuming or other methods to be ineffective.

Issued

May 7, 2014

Abate by

Jul 11, 2014

Penalty

Initial $1,200 · Current $720 Reduced

General-duty citation text

29 CFR 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace 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 such as, but are not limited to, methyl ethyl ketone, nickel plated shots, steel shots, propellant 362/363,  and paints. A site specific hazard communication program, which include specific target organ effects, had not been developed, on or about December 10, 2013.

Issued

May 7, 2014

Abate by

Jul 11, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h)(3)(iv): Employee training did not include the details of the hazard communication program developed by the employer, including an explanation of the labeling system and the material safety data sheet, and how employees can obtain and use the appropriate hazard information:  Employees working with hazardous chemicals such as, but not limited to methyl ethyl ketone, nickel plated shots, steel shots, propellant 362/363 and paints. re exposed to inhalation and skin contact hazards.  The employer failed to ensure all employees were trained on the new label elements (pictograms) and SDS format, on or about December 17, 2013.     In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).