OSHA Inspection: COOK FOAM PRODUCTS, INC.

Issued

Jul 17, 2014

Abate by

Aug 31, 2014

Penalty

Initial $3,500 · Current $2,275 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(c)(2): The employer did not ensure that no employee was exposed to an airborne concentration of methylene chloride in excess of 125 parts per million as determined over a sampling period of 15 minutes:    (a) Foam assembly department, on or about June 2, 2014: An employee spraying Helmiprene 1533 adhesive was exposed to a 15 minute short term exposure of methylene chloride at 408.5 parts per million (ppm); or 3.27 times the STEL of 125 ppm during the 15 minute sampling period.     (b) Foam assembly department, on or about June 2, 2014: An employee spraying Helmiprene 1533 adhesive was exposed to a 15 minute short term exposure of methylene chloride at 160.7 parts per million (ppm); or 1.28 times the STEL of 125 ppm during the 15 minute sampling period.     (c) Foam assembly department, on or about June 2, 2014: An employee spraying Helmiprene 1533 adhesive was exposed to a 15 minute short term exposure of methylene chloride at 324.8 parts per million (ppm); or 2.59 times the STEL of 125 ppm during the 15 minute sampling period.    (d) Foam assembly department, on or about June 2, 2014: An employee spraying Helmiprene 1533 adhesive was exposed to a 15 minute short term exposure of methylene chloride at 361.6 parts per million (ppm); or 2.89 times the STEL of 125 ppm during the 15 minute sampling period.      (e) Foam assembly department, on or about June 2, 2014: An employee spraying Helmiprene 1533 adhesive was exposed to a 15 minute short term exposure of methylene chloride at 251.5 parts per million (ppm); or 2.01 times the STEL of 125 ppm during the 15 minute sampling period.      Abatement documentation must be submitted for these items.

Issued

Jul 17, 2014

Abate by

Aug 31, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(f)(1): The employer did not institute and maintain the effectiveness of engineering controls and work practices to reduce employee exposure to or below the permissible exposure limits and wherever the feasible engineering controls and work practices which can be instituted were not sufficient to reduce employee exposure to or below the 8-hour time weighted average permissible exposure limit or short term exposure limit, the employer did not use them to reduce employee exposure to the lowest levels achievable and did not supplement them by the use of respiratory protection that compiled with the requirements of 29 CFR 1910.1052(g):     (a) Foam assembly department, on or about June 2, 2014: Engineering controls and work practices to reduce employee exposure to methylene chloride to the lowest achievable levels were not provided for employees spraying Helmiprene 1533 adhesive.  See Citation 1, Item 1a for exposure results.       Abatement documentation must be submitted for these items.

Issued

Jul 17, 2014

Abate by

Aug 31, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(g)(1)(i): Respirators were not used during periods when an employee's exposure to methylene chloride exceeds the 8-hour time weighted average permissible exposure limit or short term exposure limit:    (a) Foam assembly department, on or about June 2, 2014: A respirator was not provided to employees exposed above the short term exposure limit for methylene chloride while spraying Helmiprene 1533 adhesive.  See Citation 1, Item 1a for exposure results.    Abatement documentation must be submitted for these items.

Issued

Jul 17, 2014

Abate by

Aug 31, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(g)(2)(i): The employer did not implement a respiratory protection program in accordance with 29 CFR 1910.134 (b) through (m) (except (d)(1)(iii)), which covers each employee required by 29 CFR 1910.1052 to use a respirator:    (a) Foam assembly department, on or about June 2, 2014: The employer did not implement a respiratory protection program for three assemblers who were overexposed to methylene chloride.    Abatement documentation must be submitted for these items.

Issued

Jul 17, 2014

Abate by

Sep 30, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(j)(1)(i): The employer did not make medical surveillance available for employees who were or potentially were  exposed to methylene chloride at or above the action level on 30 or more days per year, or above the 8-hour time weighted average permissible exposure limit or the short term exposure limit on 10 or more days per year:    (a) Foam assembly department, on or about June 2, 2014: There was no medical surveillance for three employees who were overexposed to methylene chloride, above the STEL of 125 ppm.     Abatement documentation must be submitted for these items.

Issued

Jul 17, 2014

Penalty

Initial $2,800 · Current $1,820 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:     (a) Foam assembly department, on or about June 2, 2014: The employer had done no initial monitoring for employees spraying Helmiprene 1533, an adhesive containing 60-100% methylene chloride by weight.

Issued

Jul 17, 2014

Abate by

Jul 27, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(e)(1): The employer did not establish a regulated area wherever an employee's exposure to airborne concentrations of methylene chloride exceeded or could reasonably be expected to exceed either the 8-hour Time Weighted Average Permissible Exposure Limit or the Short Term Exposure Limit:  (a) Foam assembly department, on or about June 2, 2014: There was no regulated area established where employees were exposed to methylene chloride above the STEL of 125 ppm.   Abatement certification must be submitted.

Issued

Jul 17, 2014

Abate by

Aug 21, 2014

Penalty

Initial $2,100 · Current $1,365 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(k)(1)(i): The employer did not comply with all requirements of the Hazard Communication Standard (HCS) (1910.1200) for MC:    (a) At the foam assembly department, on or about June 2, 2014: The employees spraying Helmiprene 1533 adhesive were exposed to methylene chloride and were not informed about the health hazards from acute and chronic exposure to methylene chloride, and all other requirements of the Hazard Communication Standard.     Abatement certification must be submitted for these items.

Issued

Jul 17, 2014

Abate by

Aug 21, 2014

Penalty

Initial $0 · Current $0

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) At the foam assembly department, on or about June 2, 2014:  At the time of the inspection, the employees exposed to methylene chloride had not been provided with adequate information and training about hazardous acute and chronic exposure to methylene chloride.  Abatement certification must be submitted for these items.

Issued

Jul 17, 2014

Abate by

Aug 21, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.132(d)(2): The employer did not verify, through a written certification, the identity of the workplace evaluated, the person certifying that the evaluation had been performed, and the date the hazard assessment was done:  (a) At the facility, on or about June 2, 2014: The employer did not perform a hazard assessment to determine mandatory personal protective equipment nor verify that information through a written certification of the evaluation.    Abatement certification must be submitted for these items.