OSHA Inspection: CHICAGO DRYER COMPANY

Issued

2015-06-11 00:00:00

Abate by

2015-08-12 00:00:00

Penalty

Initial $4500.00 · Current $2565.00 Reduced

Hazardous substances 9135

General-duty citation text

29 CFR 1910.134(c)(1): A written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented for required respirator use:    a) Chicago Dryer Company, Chicago, IL, did not develop and implement a written respiratory protection program with worksite-specific procedures where respirators were necessary to protect the health of workers or whenever respirators were required by the employer.  Affected employees performing powder coating tasks were required to use North half mask negative pressure respirators equipped with organic vapor cartridges and pre-filters.    The respiratory protection program must be administered by a suitably trained program administrator and shall include, at a minimum, procedures for selecting respirators; medical evaluations; fit testing; procedures for proper use in routine and reasonably foreseeable emergency situations; procedures for cleaning, storing, inspecting, repairing and discarding respirators; employee training regarding respiratory hazards they are exposed to, proper uses and limitations of respirators; and procedures for regularly evaluating the effectiveness of the respirator program.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE 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

2015-06-11 00:00:00

Abate by

2015-08-12 00:00:00

Penalty

Initial $3600.00 · Current $2050.00 Reduced

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:    a) Chicago Dryer Company, Chicago, IL, did not provide a respiratory medical evaluation to workers where respirators were necessary to protect the health of workers or whenever respirators were required by the employer. Affected employees performing powder coating tasks in both paint rooms were required to wear North half mask negative pressure respirators equipped with organic vapor cartridges and pre-filters.    In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

2015-06-11 00:00:00

Abate by

2015-08-12 00:00:00

Penalty

Initial $3600.00 · Current $2050.00 Reduced

General-duty citation text

29 CFR 1910.134(f)(2): Employee(s) using tight-fitting facepiece respirators were not fit tested prior to initial use of the respirator:    a) Chicago Dryer Company, Chicago, IL, did not perform fit tests on workers where respirators were necessary to protect the health of workers or whenever respirators were required by the employer.  Affected employees performing powder coating tasks in both paint rooms were required to wear North half mask negative pressure respirators equipped with organic vapor cartridges and pre-filters.    In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

2015-06-11 00:00:00

Abate by

2015-08-12 00:00:00

Penalty

Initial $3600.00 · Current $2050.00 Reduced

Hazardous substances 9135

General-duty citation text

29 CFR 1910.134(k)(1): The employer did not provide respirator training that would ensure each employee could demonstrate knowledge of items in section (i)-(vii):    a) Chicago Dryer Company, Chicago, IL, did not ensure employees required to wear respiratory protection were provided appropriate training.  Affected employees performing powder coating tasks in both paint rooms were required to wear North half mask negative pressure respirators equipped with organic vapor cartridges and pre-filters.    In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

2015-06-11 00:00:00

Abate by

2015-10-23 00:00:00

Penalty

Initial $5400.00 · Current $3131.00 Reduced

Hazardous substances 9135

General-duty citation text

29 CFR 1910.1000(a)(2): Employee(s) were exposed to an airborne concentration of particulates not otherwise regulated (PNOR), total dust, listed in Table Z-1 in excess of the 8-hour Time-Weighted Average concentration of 15 milligrams per cubic meter of air (15 mg/M3):    a) At Chicago Dryer Company, Chicago, IL, an employee performing powder coating in the second floor paint room was exposed to an 8-hour time-weighted average level of 847.92 mg/M3 of particulates not otherwise regulated (PNOR), total dust, approximately 56.5 times the OSHA permissible exposure limit of 15 mg/M3. This limit is established to prevent irritation of the respiratory system and lung disease. The exposure level was established from a sample collected over a 407 minute period during one 8-hour work shift on March 24, 2015.  Zero exposure was assumed for the unsampled time period of 73 minutes.       In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE 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

2015-06-11 00:00:00

Abate by

2015-10-23 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 9135

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):  Effective engineering controls were not instituted and maintained by Chicago Dryer Company in the second floor powder coating paint room to reduce the employee exposure to particulates not otherwise regulated (PNOR), total dust, below the permissible exposure limit (PEL).  Employees working in the second floor powder coating paint room were exposed to PNOR, total dust, in excess of the PEL.  See instance description in item 5a of this citation.  Methods of engineering, administrative and work practice controls under these circumstances include, but are not limited to:    1) Ensure that an effective written respiratory protection program, in accordance with 29 CFR 1910.134, is developed, implemented, and followed.  Train affected employees on the proper use, selection, maintenance, as well as other program requirements and enforce respirator use.    2) Seek expertise of a competent individual such as an engineer or industrial hygienist who regularly provides independent consulting service as a ventilation expert for this or similar industries to evaluate the existing engineering control systems, working conditions, the materials being processed, and the equipment & tools used.    3) Perform a comprehensive exhaust ventilation survey and determine whether ventilation is adequate by ensuring the system is balanced and operational, checking the directional flow of any supplied make-up air in the process, checking the existing ventilation system for leaks to control exposure to fugitive or dispersed particulate/powder/dust.    4) Regularly check for particulate accumulation on any filtration devices and inside any related duct work, and replace/clean as necessary.    5) Perform periodic (i.e., quarterly) checks of the exhaust ventilation system(s) to ensure that the capture velocity is effective, and that the system(s) is/are functioning properly, and make adjustments as necessary.    6) Perform monthly preventative maintenance on the dust collecting system and, if necessary, install/implement a system to improve ventilation/exhaust and to reduce employee exposures.    7) Implement a more aggressive administrative control program including more vigorous housekeeping of floors and other horizontal surfaces where deposited particulate can be re-introduced into the workplace air. Use dustless methods of cleaning such as vacuuming. General housekeeping should be intensified to mitigate dust accumulation that contain respirable particulates.    8) Limit the length of time the operation is done per employee during the work shift.    9) Limit employee exposure(s) by rotating the employee(s), according to a written schedule, performing the operations.    ABATEMENT NOTE:    STEP 1:  An effective respiratory protection program shall be implemented and used by the affected employee(s) as an interim measure of protection.    Abatement date:  07/29/2015    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 PNOR, total dust, as referenced in this citation.  This plan shall include, at a minimum, target dates for the following action, which must be consistent with the dates required by this citation:    (1)  Evaluation of engineering/administrative controls; (2)  Selection of the optimum control methods and completion of design; (3)  Procurement, installation and operation of selected control measures; (4) Testing and acceptance or modification/redesign of controls.    All proposed control measure shall be evaluated for each particular use by a competent industrial hygienist or other technically qualified person(s).  30-day progress reports to OSHA are required during the abatement period.    Abatement date: 09/10/2015    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 date: 10/23/2015  In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE 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

2015-06-11 00:00:00

Abate by

2015-07-29 00:00:00

Penalty

Initial $4500.00 · Current $2565.00 Reduced

Hazardous substances 0691

General-duty citation text

29 CFR 1910.1026(d)(1): The employer with a workplace or work operation covered by this standard did not determine the 8-hour time-weighted average exposure for each employee exposed to chromium (VI). The employer is to make this determination in accordance with either paragraph (d)(2), the scheduled monitoring option, or paragraph (d)(3), the performance-oriented option.    Chicago Dryer Company, Chicago, IL- did not initially determine the 8-hour time-weighted average exposure levels for employees exposed to hexavalent chromium during processing or tasks performed on stainless steel, such as welding.     a) On February 19, 2015, a Chicago Dryer Company employee in the Century Department conducting MIG welding on a stainless steel part was determined to have an 8-hour time-weighted average exposure level to hexavalent chromium of 0.0006 mg/M3 during the 80-minute sampling period, exceeding the criterion limit of 0.0005 mg/M3, which triggers the requirement for initial monitoring. Zero exposure was assumed for the unsampled time period of 400 minutes.     In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

2015-06-11 00:00:00

Abate by

2015-07-29 00:00:00

Penalty

Initial $3600.00 · Current $2050.00 Reduced

Hazardous substances 0691

General-duty citation text

29 CFR 1910.1026(l)(1): The employer did not ensure that all employees who were assigned to workplaces where there was exposure to chromium (VI) were provided with information and training as required by the Hazard Communication Standard 29 CFR 1910.1200:    a) Chicago Dryer Company, Chicago, IL, did not provide the required information and training on the hazards of hexavalent chromium to employees that weld on stainless steel parts.     In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

2015-06-11 00:00:00

Abate by

2015-07-29 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 02400730073113001620

General-duty citation text

29 CFR 1910.1200(h)(1): Employees were not provided effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard that the employees had not been previously trained about was introduced into their work area:  a) Chicago Dryer Company, Chicago, IL, did not provide effective information and training to employees who work with or are exposed to hazardous chemicals, including compressed gases, such as nitrogen and argon, the solvent xylene used to clean parts prior to painting, the Sherwin Williams Powdura hybrid paint powders (contains calcium carbonate, titanium dioxide and 0.1% crystalline quartz silica), metal particulates, including iron and copper, from the lathe and grinding operations, wood dust from sawing operations, welding fumes (contains manganese, copper, and zinc oxide), and the Fibrefrax (contains fiber wool) used to line the canopies.                   In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

2015-06-11 00:00:00

Abate by

2015-07-29 00:00:00

Penalty

Initial $2700.00 · Current $1539.00 Reduced

Hazardous substances 02400691073007311300

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:    a)  Chicago Dryer Company, Chicago, IL, did not provide an adequate or effective written hazard communication program in accordance with 29 CFR 1910.1200(e)(1) to address the hazardous chemicals that employees work with or are exposed to, including compressed gases, such as nitrogen and argon, the solvent xylene used to clean parts prior to painting, the Sherwin Williams Powdura hybrid paint powders (contains calcium carbonate, titanium dioxide and 0.1% crystalline quartz silica), metal particulates, including iron and copper, from the lathe and grinding operations, wood dust from sawing operations, welding fumes (contains manganese, copper, and zinc oxide), and the Fibrefrax (contains fiber wool) used to line the canopies.       The employer's written hazard communication program must at least describe how the following program elements would be met:    1) Labeling requirements for the containers/packages of the hazardous chemicals, including in-plant secondary containers;  2) Maintenance and availability of safety data sheets (SDSs);    3) Employee/worker training on the hazardous chemicals they use or are exposed to in their workplace;   4) A complete and accurate list or inventory of the hazardous chemicals known to be in the workplace that can be cross-referenced with the required safety data sheets (SDSs);    5) Methods to inform employees of the hazards of non-routine tasks, and    6) Methods to inform other employers/contractors of SDS availability, labeling system and any other precautionary measures to protect employees.      In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

2015-06-11 00:00:00

Abate by

2015-07-29 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 02400730073113001620

General-duty citation text

29 CFR 1910.1200(h)(3)(iv):   The details of the hazard communication program developed by the employer did not include an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employee could obtain and use the appropriate hazard information:  a) Chicago Dryer Company, Chicago, IL has not provided the required training on the revised Hazard Communication Standard label elements (e.g., pictograms and signal words) and the new format of the Safety Data Sheet (SDS) (i.e., section order and types of information contained within each section of the SDS), which was effective as of December 1, 2013, to employees working with or exposed to chemicals, including compressed gases, such as nitrogen and argon, the solvent xylene used to clean parts prior to painting, the Sherwin Williams Powdura hybrid paint powders (contains calcium carbonate, titanium dioxide and 0.1% crystalline quartz silica), metal particulates, including iron and copper, from the lathe and grinding operations, wood dust from sawing operations, welding fumes (contains manganese, copper, and zinc oxide), and the Fibrefrax (contains fiber wool) used to line the canopies.   In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).