OSHA Inspection: IMPERIAL INDUSTRIES INC.

Issued

May 11, 2015

Abate by

Jun 2, 2015

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.107(g)(2):  All spraying areas were not kept as free from the accumulation of deposits of combustible residues as practical, with cleaning conducted daily if necessary. Scrapers, spuds, or other such tools used for cleaning purposes were not of nonsparking material:  a)  On or about 11/12/2014, the walls and floors of the Industrial Paint building were not kept free from accumulations of deposits of combustible residue.  b)  On or about 1/20/2015, employees used potentially sparking tools such as steel air chisels and steel scrapers to remove accumulations of deposits of combustible residues from walls and the floor of the Industrial Paint building.

Issued

May 11, 2015

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.1026(d)(2)(vi): The employer did not perform additional monitoring when there had been a change in the production process, raw materials, equipment, personnel, work practices, or control methods that resulted or may have resulted in new or additional exposures to chromium (VI), or when the employer had any reason to believe that new or additional exposures had occurred:    a)  On or about 11/19/2014, the employer had not performed additional monitoring when there had been a change in the production process such as when Calumet welding employees for the first time fabricated a stainless steel DOT tank.

Issued

May 11, 2015

Abate by

Jun 2, 2015

Penalty

Initial $4,500 · Current $4,500

General-duty citation text

29 CFR 1910.1026(e)(1):  The employer did not establish a regulated area wherever an employee's exposure to airborne concentrations of chromium (VI) was, or could reasonably be expected to be, in excess of the permissible exposure limit:  a)  On or about 11/12/2014, the employer did not establish regulated areas in the Calumet building when an employee plasma cutting stainless steel in the DOT area was exposed to airborne concentrations of chromium (VI) at a level of 5.6 ug/m3 as an 8-hour TWA which exceeded the PEL 1.1 times.

Issued

May 11, 2015

Abate by

Jun 17, 2015

Penalty

Initial $0 · Current $33,250

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(f)(1)(i): Feasible engineering controls and work practices were not instituted to reduce and maintain employee exposures to chromium (VI) at or below the permissible exposure limit. Where feasible engineering and work practice controls would not reduce employee exposure to chromium (VI) to or below the permissible exposure limit, the employer did not apply these feasible controls to reduce employee exposures to the lowest chromium (VI) levels achievable:    a)  In the Calumet area, a DOT plasma cutter employee was exposed to airborne chromium (VI) at a level of 5.6 ug/m3 as an 8-hour TWA on 11/19/2014, approximately 1.1 times the PEL of 5 ug/m3. This exposure was determined by air sampling conducted over 439 minutes during one shift, with zero exposure being assumed for the unsampled 41 minutes of an 8-hour work shift.    b)  In the Industrial 2nd Stage area, a welder employee was exposed to airborne chromium (VI) at a level of 8.3 ug/m3 as an 8-hour TWA on 02/24/2015, approximately 1.6 times the PEL of 5 ug/m3. This exposure was determined by the employer's air sampling conducted over 458 minutes during one shift, with zero exposure being assumed for the unsampled 22 minutes of an 8-hour work shift.    Applicable administrative or engineering controls may include, but are not limited to the following:       1) Utilize the downdraft ventilated plasma cutting table in Guardrail area to plasma cut stainless steel pieces. Train employees to not conduct plasma cutting of stainless steel and ensure employees follow the work practice controls.       2) Utilize fume extraction guns, fume extraction hoods, and/or other local ventilation controls for use in areas where they are able to be used.        3) Substitute MIG welding on stainless steel for TIG or Sub Arc welding to reduce exposures to chromium (VI) during welding operations.    4) Institute combinations of the controls listed above to reduce exposures. Conduct exposure monitoring and employee surveys to determine what the most effect combination of controls are for the dynamic work environment.

Issued

May 11, 2015

Abate by

Jun 17, 2015

Penalty

Initial $49,500 · Current $33,250 Reduced

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(d)(2)(iv): The employer used the scheduled monitoring option, and monitoring revealed employee exposures to chromium (VI) to be above the permissible exposure limit; however, the employer did not perform periodic monitoring at least every three months:    a)  On or about 11/12/2014, the employer did not perform periodic monitoring at least every three months when employees were conducting welding operations on a stainless steel tanks in Industrial Tops/Cones and Industrial Upper Bay and after the employer's last air monitoring on 01/08/2014 revealed an employee's exposure to chromium (VI) was above the PEL.