OSHA Inspection: BWISE MANUFACTURING, LLC

Issued

Dec 18, 2014

Abate by

Mar 20, 2015

Penalty

Initial $4,590 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.107(l)(4)(i): All areas were not kept free of the accumulation of powder coating dusts, particularly such horizontal surfaces as ledges, beams, pipes, hoods, booths, and floors:      Powder Coating Department - The areas surrounding the powder coating booth contained piles of accumulated dust that was combustible. The dust was located on the ledges of the booth, floors and piping of the batch oven, on or about November 12, 2014.       Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and state employees and their representatives were informed of this abatement.

Issued

Dec 18, 2014

Abate by

Mar 20, 2015

Penalty

Initial $4,590 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.132(a): Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, were not provided, used, and maintained in a sanitary and reliable condition wherever it was necessary by reason of hazards of processes or environment, chemical hazards, capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact:    (a) Powder Coating Department - The employer did not provide employees with an adequate number of aluminizing garments to protect them from the high temperatures of the batch ovens. The ovens reach temperatures up to 400 degrees. There was one (1) coat for up to three (3) employees working in the ovens, on or about June 18, 2014.    (b) Powder Coating Department - The employer did not provide spray painting employees with adequate gloves, and other protective equipment to protect employees from the absorption of 1,3,5 triglycidyl isocyanurate (TGIC), on or about June 18, 2014.  Gloves being used had holes in them.    (c) Powder Coating Department - The employer provided gloves that did not provide adequate thermal protection and did not adequately protect arms of employees who pull hot trailers out of the batch ovens. Employees were receiving burns though their gloves, or above the gloves on or about June 18, 2014.        Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and state employees and their representatives were informed of this abatement.

Issued

Dec 18, 2014

Abate by

Mar 20, 2015

Penalty

Initial $0 · Current $1,500

Hazardous substances 9130T405

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:      Bwise Manufacturing, LLC - The employer did not provide medical evaluations before employees wore or were required to wear a filtering facepiece (dust mask) respirators or a half mask respirator in the workplace, on or about June 18, 2018.      Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and state employees and their representatives were informed of this abatement.

Issued

Dec 18, 2014

Abate by

Mar 20, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 9130T405

General-duty citation text

29 CFR 1910.134(k)(3): The employer did not provide the training prior to requiring the employee to use a respirator in the workplace:    Powder Coating Department - The employer did not provide information and training to employees who are required to wear filtering facepiece (dust mask), air supplied respirators and half mask respirator in the workplace, on or about November 12, 2014    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and state employees and their representatives were informed of this abatement.

Issued

Dec 18, 2014

Penalty

Initial $2,295 · Current $750 Reduced

General-duty citation text

29 CFR 1910.134(i)(1)(ii): Compressed breathing air did not meet at least the requirements for Grade D breathing air described in ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1-1989, to include requirements in sections (A)-(E):     (a) Powder Coating Department - Employees use supplied air respirators with Bullard type hoods while powder coat spraying trailers.  The compressed breathing air used with the respirators did not meet the requirements for grade D breathing air on or about June 18, 2014.     No Abatement Certification or Documentation Required.

Issued

Dec 18, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(i)(5)(i): Compressors used to supply breathing air to respirators were not so constructed and situated so as to prevent entry of contaminated air into the air-supply system:  (a) Powder Coating Department - Employees used supplied air respirators with Bullard type hoods while powder coat spraying trailers.  The compressor for the breathing air was situated the work area where lift truck exhaust or dust could be drawn into the air supplied to the respirator on or about June 18, 2014.   No Abatement Certification or Documentation Required.

Issued

Dec 18, 2014

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(i)(5)(iv): The employer did not ensure that compressors used to supply breathing air to respirators were constructed as to have a tag containing the most recent change date and the signature of the person authorized by the employer to perform the change. The tag was not maintained at the compressor:   (a) Powder Coating Department - The employer did not ensure that the Allegro compressor, serial number 187404 contained a tag with the most recent filter change date with a signature of the person authorized to change the filter, on or about June 18, 2014.      No Abatement Certification or Documentation Required.

Issued

Dec 18, 2014

Abate by

Mar 20, 2015

Penalty

Initial $4,590 · Current $1,500 Reduced

Hazardous substances 9130T405

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer did not identify and evaluate the respiratory hazard(s) in the workplace; this evaluation did not include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form:    (a) Bwise Manufacturing, LLC - The employer did not evaluate the powder coating process  to determine employee(s) exposure to the powder coating dust while painting the trailers. Employees were exposed to 1,3,5 tryglycidyl isocyanurate and overexposed to respirable dust, on or about June 18, 2014.            Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and state employees and their representatives were informed of this abatement.

Issued

Dec 18, 2014

Abate by

Mar 4, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 9130

General-duty citation text

29 CFR 1910.1000(a)(2): Employee(s) were exposed to an airborne concentration of Respirable Particulates Not Otherwise Regulated, listed in Table Z-1 in excess of the 8 hour Time Weighted Average concentration of 5 mg/m3:    (a) Bwise Manufacturing, LLC - An employee powder coat spraying trailers was exposed to respirable dust at an 8 hour Time Weighted Average (TWA) of 20.00 mg/M3, approximately 4.0 times the permissible exposure limit (PEL) of 5 mg/M3, on or about November 12, 2014. The exposure level was derived from two samples collected over a 489 minute period.    (B) Bwise Manufacturing, LLC - An employee powder coat spraying trailers was exposed to respirable dust at an 8 hour Time Weighted Average (TWA) of 15.00 mg/M3, approximately 3.0 times the permissible exposure limit (PEL) of 5 mg/M3, on or about November 12, 2014. The exposure level was derived from two samples collected over a 517 minute period.    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and state employees and their representatives were informed of this abatement.

Issued

Dec 18, 2014

Abate by

Jan 22, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 9130

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) Bwise Manufacturing, LLC - An employee powder coat spraying trailers was exposed to respirable dust at an 8 hour Time Weighted Average (TWA) of 20.00 mg/M3, approximately 4.0 times the permissible exposure limit (PEL) of 5 mg/M3, on or about November 12, 2014 without feasible engineering or administrative controls having been implemented. The exposure level was derived from two samples collected over a 489 minute period.    (B) Bwise Manufacturing, LLC - An employee powder coat spraying trailers was exposed to respirable dust at an 8 hour Time Weighted Average (TWA) of 15.00 mg/M3, approximately 3.0 times the permissible exposure limit (PEL) of 5 mg/M3, on or about November 12, 2014 without feasible engineering or administrative controls having been implemented. The exposure level was derived from two samples collected over a 517 minute period.    ABATEMENT NOTE:      All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person.  Ninety (90)day progress reports are required during the abatement period.             *STEP 1        Establish an effective respiratory protection program as an interim protective measure.            *STEP 2         Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposure 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; and    4. Testing and acceptance or modification/redesign of controls.            *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 certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photographic or video evidence of abatement or other written records.    GENERAL METHODS OF CONTROL APPLICABLE IN THESE CIRCUMSTANCES INCLUDE, BUT ARE NOT LIMITED TO, THE FOLLOWING:     1. Ensure that when employees are spray painting they are positioned so that they are not praying in the direction of each other.     2. Contact the manufacturer to ensure that the powder booth is assembled in accordance with their recommendation.  3. Allow one employee to paint in the booth which may reduce the overall exposure of employees.  4. Shut down one side of the filters and allow employee(s) to spray in the direction of the other set of filters which will reduce the scattering of dust and allow for greater recovery of product .       Date by Which Violation Must be Abated:    Step  1     01/04/15 - 15 days      Date by Which Violation Must be Abated:    Step  2     01/19/15 - 45 days      Date by Which Violation Must be Abated:    Step  3     03/05/15 - 90 days

Issued

Dec 18, 2014

Abate by

Mar 20, 2015

Penalty

Initial $3,825 · Current $1,750 Reduced

General-duty citation text

29 CFR 1910.1200(h)(1): Employer did not provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees had not previously been trained about was introduced into their work area:      (a) Powder Coating Department - The employer did not provide employees in the powder coating department information and training on the chemicals they work with such as but not limited to primer gray epoxy, low cure black and red TGIC and the hazards of combustible dust, on or about June 18, 2014.         Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and state employees and their representatives were informed of this abatement.