OSHA Inspection: CS METALS, INC.

Issued

Dec 18, 2014

Abate by

Jan 7, 2015

Penalty

Initial $5,390 · Current $5,390

Hazardous substances 0260073115201591

General-duty citation text

29 CFR 1910.134(f)(2): The employer did not ensure that an employee using a tight-fitting facepiece respirator was fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.    a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, the employer did not ensure employees required to wear tight fitting half face respirators when overexposed to arsenic, lead, iron oxide, and copper fume, were properly fit tested.

Issued

Dec 18, 2014

Abate by

Dec 30, 2014

Penalty

Initial $5,390 · Current $0 Reduced

Hazardous substances 0260073115201591

General-duty citation text

29 CFR 1910.134(h)(2)(i): All respirators were not stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and they were not packed or stored to prevent deformation of the facepiece and exhalation valve.     a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about June 26, 2014, the employer did not ensure employees were properly storing their half face tight fitting respirators.  Respirators were stored inside of hard hats, sitting on top of protective clothing, and hanging from the head band throughout the torch cutting areas.

Issued

Dec 18, 2014

Abate by

Dec 30, 2014

Penalty

Initial $5,390 · Current $0 Reduced

Hazardous substances 0260073115201591

General-duty citation text

29 CFR 1910.134(h)(4): The employer did not ensure that respirators that fail an inspection or are otherwise found to be defective are removed from service, and are discarded or repaired or adjusted in accordance with the following procedures.    a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, the employer did not ensure a half face tight fitting respirator used by an employee in the North field was removed from service when it was found to be defective.  The respirator was missing an inhalation valve on the left side of the face piece but was used by the employee for two days during which the employee was overexposed to arsenic, lead, iron oxide, and copper fume.

Issued

Dec 18, 2014

Penalty

Initial $5,390 · Current $5,390

Hazardous substances 02601591

General-duty citation text

29 CFR 1910.141(d)(3)(iv): Showers were not provided with hot and cold water feeding a common discharge line.   a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about June 26, 2014, the employer did not ensure the showers available to employees overexposed to lead while performing torching operations, were provided with hot water.

Issued

Dec 18, 2014

Abate by

Jan 22, 2015

Penalty

Initial $5,390 · Current $5,390

Hazardous substances 0731

General-duty citation text

29 CFR 1910.1000(a)(2): An employee's exposure to any substance in Table Z-1, the exposure limit of which was not preceded by a "C", exceeded the 8-hour Time Weighted Average given for that substance any 8-hour work shift of a 40-hour work week.  a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, an employee performing torch cutting activities in the North field was overexposed to copper fume at an eight hour time weighted average concentration of 0.138 mg/m3 which exceeded the OSHA Permissible Exposure limit of 0.10 mg/m3 by 130%.

Issued

Dec 18, 2014

Abate by

May 1, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 0731

General-duty citation text

29 CFR 1910.1000(e): To achieve compliance with paragraphs (a) through (d) of this section, administrative or engineering controls were not determined and implemented whenever feasible. When such controls were not feasible to achieve full compliance, protective equipment or any other protective measures were not used to keep the exposure of employees to air contaminants within the limits prescribed in this section. Any equipment and/or technical measures used for this purpose must be approved for each particular use by a competent industrial hygienist or other technically qualified person.   a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, the employer did not ensure engineering controls were implemented for employees performing torch cutting operations.  An employee performing torch cutting operations in the North field was overexposed to copper fume at an eight hour time weighted average concentration of 0.138 mg/m3 which exceeded the OSHA Permissible Exposure limit of 0.10 mg/m3 by 130%.    Step 1: Provide effective respiratory protection to and ensure it is used by exposed employees as an interim protective 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.       Step 2: 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.        All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person.  90 day progress reports are required during the abatement period.        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.       Feasible engineering controls include, but are not limited to using longer torches so the employee is removed from the generated fumes, proper positioning of the worker to ensure they are standing upwind of the fumes while torching, institute fans and local exhaust ventilation.                           Step1: Abatement Date-                    Step2: Abatement Date-                    Step3: Abatement Date-

Issued

Dec 18, 2014

Abate by

Jan 22, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(c): The employer did not assure that no employee was exposed to inorganic arsenic at concentrations greater than 10 micrograms per cubic meter of air (10 ug/m(3)), averaged over any 8-hour period.    a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, an employee working in the North field was overexposed to arsenic at an eight hour time weighted average concentration of 12.6 ug/m3 which exceeded the OSHA PEL of 10 ug/m3 by 126%.

Issued

Dec 18, 2014

Abate by

May 1, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(g)(1)(i): The employer did not institute at the earliest possible time but not later than December 31, 1979, engineering and work practice controls to reduce exposures to or below the permissible exposure limit, except to the extent that the employer can establish that such controls are not feasible.   a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, the employer did not ensure engineering controls were implemented for employees performing torch cutting operations.  An employee performing torch cutting operations in the North field was overexposed to arsenic at an eight hour time weighted average concentration of 12.6 ug/m3 which exceeded the OSHA PEL of 10 ug/m3 by 126 %.   Step 1: Provide effective respiratory protection to and ensure it is used by exposed employees as an interim protective 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.      Step 2: 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 .      All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person.  90 day progress reports are required during the abatement period.      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.      Feasible engineering controls include, but are not limited to using longer torches so the employee is removed from the generated fumes, proper positioning of the worker to ensure they are standing upwind of the fumes while torching, and institute fans and local exhaust ventilation.                       Step1: Abatement Date-                   Step2: Abatement Date-                   Step3: Abatement Date-

Issued

Dec 18, 2014

Abate by

Jan 7, 2015

Penalty

Initial $5,390 · Current $5,390

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(g)(2)(i): The employer did not establish and implement a written program to reduce exposures to or below the permissible exposure limit by means of engineering and work practice controls.     a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, the employer did not ensure an arsenic compliance program was developed which covered employees performing torch cutting operations who were exposed to arsenic at 12.6 ug/m3 as an 8 hour time weighted average which exceeded the OSHA PEL of 10.0 ug/m3 by 126%.

Issued

Dec 18, 2014

Abate by

Jan 7, 2015

Penalty

Initial $5,390 · Current $0 Reduced

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(k)(4): A written housekeeping and maintenance plan was not kept which listed appropriate frequencies for carrying out housekeeping operations, and for cleaning and maintaining dust collection equipment. The plan was not available for inspection by the Assistant Secretary.     a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, the employer did not ensure a written arsenic housekeeping plan was developed that details the frequency of cleaning surfaces and floors in the change rooms, showers, lunchrooms, and lavatory.  Employees performing torch cutting operations were exposed to arsenic at 12.6 ug/m3 as an 8 hour time weighted average which exceeded the OSHA PEL of 10.0 ug/m3 by 126%.

Issued

Dec 18, 2014

Abate by

Jan 7, 2015

Penalty

Initial $5,390 · Current $0 Reduced

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(n)(1)(i)(A): The employer did not institute a medical surveillance program for all employees who were or will be exposed above the action level, without regard to the use of respirators, at least 30 days per year.     a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, the employer did not ensure an arsenic medical surveillance program was instituted which covered employees performing torch cutting operations.  Employees were exposed to arsenic at 12.6 ug/m3 as an 8 hour time weighted average which exceeded the OSHA PEL of 10.0 ug/m3 by 126%.

Issued

Dec 18, 2014

Abate by

May 1, 2015

Penalty

Initial $5,390 · Current $0 Reduced

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(o)(1)(i): The employer did not train each employee who was subject to exposure to inorganic arsenic above the action level without regard to respirator use, or for whom there is the possibility of skin or eye irritation from inorganic arsenic, in accordance with the requirements of this section. The employer did not institute a training program and ensure employee participation in the program.     a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, the employer did not ensure employees performing torch cutting operations who were exposed to arsenic above the action level, were provided training on the following topics:       1.      Information in Appendix A;   2.      The quantity, location, manner of use, storage, sources of exposure, and the specific nature of operations which could result in exposure to inorganic arsenic as well as any necessary protective steps;   3.      The purpose, proper use, and limitation of respirators;   4.      The purpose and a description of the medical surveillance program as required by paragraph (n) of this section;   5.      The engineering controls and work practices associated with the employee's job assignment; and   6.      A review of this standard.

Issued

Dec 18, 2014

Abate by

Dec 30, 2014

Penalty

Initial $61,600 · Current $41,670 Reduced

Hazardous substances 0260073115201591

General-duty citation text

29 CFR 1910.134(g)(1)(i)(A): The employer permitted respirators with tight-fitting facepieces to be worn by employees who have facial hair that came between the sealing surface of the facepiece and the face or that interfered with valve function:    a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, the employer did not ensure employees working in the North and East fields were clean shaven when wearing tight fitting respirators to protect themselves from overexposures to substances such as but not limited to iron oxide, arsenic, copper and lead fumes.

Issued

Dec 18, 2014

Abate by

Dec 30, 2014

Penalty

Initial $61,600 · Current $41,670 Reduced

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(j)(1)(i): Where the possibility of skin or eye irritation from inorganic arsenic exists, and for all workers working in regulated areas, the employer did not provide at no cost to the employee and assure that employees used appropriate and clean protective work clothing and equipment such as coveralls or similar full body work clothing.      a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, the employer did not ensure employees wore coveralls or other full body protective clothing when overexposed to arsenic during torch cutting operations.

Issued

Dec 18, 2014

Abate by

Jan 7, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(g)(1)(i): If an employee is exposed to lead above the PEL, without regard to the use of respirators or where the possibility of skin or eye irritation exists, the employer did not provide at no cost to the employee and assure that the employee used appropriate protective work clothing and equipment such as but not limited to coveralls or similar full-body work clothing:    a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about August 29, 2014, the employer did not ensure employees were wearing coveralls or other full body protective clothing when overexposed to lead during torch cutting operations.

Issued

Dec 18, 2014

Abate by

Jan 23, 2015

Penalty

Initial $61,600 · Current $41,670 Reduced

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(j)(2)(v): The employer did not assure that contaminated protective clothing which was to be cleaned, laundered, or disposed of, was placed in a closed container in the change-room which prevented dispersion of inorganic arsenic outside the container.    a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about June 26, 2014, the employer did not ensure work clothing contaminated with arsenic was placed in a closed container in the change room.

Issued

Dec 18, 2014

Abate by

Jan 23, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(g)(2)(v): The employer did not assure that contaminated protective clothing which was to be cleaned, laundered, or disposed of, was placed in a closed container in the change-room which prevented dispersion of lead outside the container.    a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about June 26, 2014, the employer did not ensure work clothing contaminated with lead was placed in a closed container in the change room.

Issued

Dec 18, 2014

Abate by

Dec 30, 2014

Penalty

Initial $61,600 · Current $41,670 Reduced

Hazardous substances 0260

General-duty citation text

29 CFR 1910.1018(m)(2)(i): The employer did not assure that employees working in regulated areas or subject to the possibility of skin or eye irritation from inorganic arsenic shower at the end of the work shift.    a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about June 26, 2014, the employer did not ensure employees overexposed to arsenic while torching steel were showering at the end of the work shift.

Issued

Dec 18, 2014

Abate by

Dec 30, 2014

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(i)(3)(i): The employer did not 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.  a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about June 26, 2014, the employer did not ensure employees overexposed to lead while torching steel were showering at the end of the work shift.

Issued

Dec 18, 2014

Abate by

Jan 22, 2015

Penalty

Initial $61,600 · Current $41,670 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(c)(1): The employer did not assure that no employee was exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m(3)) averaged over an 8-hour period.    a.  CS Metals, Inc. worksite located in St. Mary's, Ohio:  On or about August 29, 2014, an employee working in the North Field was overexposed to lead at an eight-hour time weighted average concentration of 187 ug/m3 which exceeded the OSHA Permissible Exposure limit of 50 ug/m3 by 374%.    CS Metals, Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.1025(c)(1), which was contained in OSHA Inspection Number 314655887, Citation number 1,  Item number 2a, and was affirmed as a final order on October 26, 2010, with respect to a workplace located at 2020 Vanderbilt Road, Birmingham, AL.

Issued

Dec 18, 2014

Abate by

May 1, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(1)(i): Where any employee was exposed to lead above the permissible exposure limit for more than 30 days per year, the employer did not implement engineering and work practice controls (including administrative controls) to reduce and maintain employee exposure to lead in accordance with the implementation schedule in Table I, except to the extent that the employer can demonstrate that such controls are not feasible. Wherever the engineering and work practice controls which can be instituted were not sufficient to reduce employee exposure to or below the permissible exposure limit, the employer did not use them to reduce exposures to the lowest feasible level and shall supplement them by the use of respiratory protection which complies with the requirements of paragraph (f) of this section.  a.  CS Metals, Inc. worksite located in St. Mary's, Ohio:  On or about August 29, 2014, engineering controls were not determined and implemented to protect employees from overexposures to lead.  An employee working in the North Field was overexposed to lead at an eight-hour time weighted average concentration of 187 ug/m3 which exceeded the OSHA Permissible Exposure limit of 50 ug/m3 by 374%.  CS Metals, Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.1025(e)(1)(i), which was contained in OSHA Inspection Number 314655887, Citation number 1,  Item number 2b, and was affirmed as a final order on October 26, 2010, with respect to a workplace located at 2020 Vanderbilt Road, Birmingham, AL.   Step 1: Provide effective respiratory protection to and ensure it is used by exposed employees as an interim protective 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.    Step 2: 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 .    All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person.  90 day progress reports are required during the abatement period.    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.  Feasible engineering controls include, but are not limited to using longer torches so the employee is removed from the generated fumes, proper positioning of the worker ensure they are standing upwind of the fumes while torching, and institute fans and local exhaust ventilation.               Step1: Abatement Date-                 Step2: Abatement Date-                 Step3: Abatement Date-

Issued

Dec 18, 2014

Penalty

Initial $10,780 · Current $7,545 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.141(d)(1): Washing facilities were not maintained in a sanitary condition.    a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about June 26, 2014, showers located in the changing room of the decon trailer were contaminated with lead and not maintained in a sanitary condition.       CS Metals, Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.141(d)(1), which was contained in OSHA Inspection Number 314655887, Citation number 2,  Item number 1, and was affirmed as a final order on October 26, 2010, with respect to a workplace located at 2020 Vanderbilt Road, Birmingham, AL.

Issued

Dec 18, 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.  a. CS Metals, Inc. worksite located in St Mary's, Ohio:  On or about June 26, 2014, the employer did not ensure all surfaces such as but not limited to the insides of lockers, floors, and other equipment located in the change room  were maintained as free as practical of accumulations of lead.    CS Metals, Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.1025(h)(1), which was contained in OSHA Inspection Number 314655887, Citation number 1,  Item number 6, and was affirmed as a final order on October 26, 2010, with respect to a workplace located at 2020 Vanderbilt Road, Birmingham, AL.

Issued

Dec 18, 2014

Abate by

Jan 22, 2015

Penalty

Initial $10,780 · Current $7,545 Reduced

Hazardous substances 1520

General-duty citation text

29 CFR 1910.1000(a)(2):  An employee's exposure to any substance in Table Z-1, the exposure limit of which is not preceded by a "C", exceed the 8-hour Time Weighted Average given for that substance in any 8-hour work shift of a 40-hour work week.    a.  CS Metals, Inc. worksite located in St. Mary's, Ohio:  On or about August 29, 2014, an employee working in the East Field was overexposed to iron oxide at an eight-hour time weighted average concentration of 11.25 mg/m3 which exceeded the OSHA Permissible Exposure limit of 10 mg/m3 by 112%.    b: CS Metals, Inc. worksite located in St. Mary's, Ohio:  On or about August 29, 2014, an employee working in the North Field was overexposed to iron oxide at an eight-hour time weighted average concentration of 17.96 mg/m3 which exceeded the OSHA Permissible Exposure limit of 10 mg/m3 by 179%.    CS Metals, Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.1000(a)(2), which was contained in OSHA Inspection Number 314655887, Citation number 1,  Item number 1a, and was affirmed as a final order on October 26, 2010, with respect to a workplace located at 2020 Vanderbilt Road, Birmingham, AL.

Issued

Dec 18, 2014

Abate by

Jan 22, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 1520

General-duty citation text

29 CFR 1910.1000(e): To achieve compliance with paragraphs (a) through (d) of this section, administrative or engineering controls were not determined and implemented whenever feasible. When such controls are not feasible to achieve full compliance, protective equipment or any other protective measures were not used to keep the exposure of employees to air contaminants within the limits prescribed in this section. Any equipment and/or technical measures used for this purpose must be approved for each particular use by a competent industrial hygienist or other technically qualified person. Whenever respirators are used, their use shall comply with 1910.134.  a.  CS Metals, Inc. worksite located in St. Mary's, Ohio:  On or about August 29, 2014, engineering controls were not determined and implemented to protect employees from overexposures to iron oxide.  An employee working in the East Field was overexposed to iron oxide at an eight-hour time weighted average concentration of 11.25 mg/m3 which exceeded the OSHA Permissible Exposure limit of 10 mg/m3 by 112%.  b: CS Metals, Inc. worksite located in St. Mary's, Ohio:  On or about August 29, 2014, engineering controls were not determined and implemented to protect employees from overexposures to iron oxide.  An employee working in the North Field was overexposed to iron oxide at an eight-hour time weighted average concentration of 17.96 mg/m3 which exceeded the OSHA Permissible Exposure limit of 10 mg/m3 by 179%.  CS Metals, Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.1000(e), which was contained in OSHA Inspection Number 314655887, Citation number 1,  Item number 1b, and was affirmed as a final order on October 26, 2010, with respect to a workplace located at 2020 Vanderbilt Road, Birmingham, AL.    Step 1: Provide effective respiratory protection to and ensure it is used by exposed employees as an interim protective 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.    Step 2: 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 .    All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person.  90 day progress reports are required during the abatement period.    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.    Feasible engineering controls include, but are not limited to using longer torches so the employee is removed from the generated fumes, proper positioning of the worker ensure they are standing upwind of the fumes while torching, and institute fans and local exhaust ventilaiton.                 Step1: Abatement Date-                 Step2: Abatement Date-                 Step3: Abatement Date-