OSHA Inspection: ASHLAND FOUNDRY AND MACHINE WORKS, INCORPORATED

Issued

Jul 23, 2015

Abate by

Aug 27, 2015

Penalty

Initial $2,700 · Current $0 Reduced

General-duty citation text

29 CFR 1910.305(a)(2)(ix): All lamps for general illumination were not protected from accidental contact or breakage by a suitable fixture or lampholder with a guard or other suitable means.    a) Casting Finishing operations, incandescent light bulbs powered by 120 volts AC were used for inspection and task work and were not protected by cage, of shatter proof construction, or otherwise made safe to prevent employees from exposure to electrical shock, on or about, June 4, 2015.    ABATEMENT CERTIFICATION REQUIRED

Issued

Jul 23, 2015

Abate by

Dec 31, 2017

Penalty

Initial $5,400 · Current $5,000 Reduced

Hazardous substances 9130

General-duty citation text

29 CFR 1910.1000(a)(2) Employees were exposed to an airborne concentration of particulates not otherwise regulated, respirable fraction, listed in Table Z-1 in excess of the 8 hour Time Weighted Average concentration:      a) Air Arc Big Booth, An employee was exposed to particulates not otherwise regulated, respirable fraction, at an 8 hour time weighted average of 18.67 milligrams per cubic meter of air (mg/M3) while finishing castings.  The exposure was 3.7 times the Permissible Exposure Limit of 5 mg/M3.  The PEL was established to prevent decrease in lung function and pulmonary obstructive disease.  The exposure was established over 448 minutes of personal sampling conducted on June 4, 2015.  Zero exposure was assumed for the unsampled period of time.      ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED

Issued

Jul 23, 2015

Abate by

Dec 31, 2017

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) Air Arc Big Booth, An employee was exposed to particulates not otherwise regulated, respirable fraction, at an 8 hour time weighted average of 18.67 milligrams per cubic meter of air (mg/M3) while finishing castings and feasible administrative or engineering controls were not implemented.  The exposure was 3.7 times the Permissible Exposure Limit of 5 mg/M3.  The PEL was established to prevent decrease in lung function and pulmonary obstructive disease.  The exposure was established over 448 minutes of personal sampling conducted on June 4, 2015.  Zero exposure was assumed for the unsampled period of time.      ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED      General methods of control would include, but are not limited to the following:      1. Increase the exhaust ventilation.  One way this can be accomplished is by removing the horizontal sheet metal baffling from the face of the exhaust hood.  Replace it with strong wire or re-bar mesh such that less surface area of the hood is blocked.      2. Place the cleaning of the hood and exhaust ductwork on a preventative maintenance schedule such that restrictive blockages are prevented which decreases efficiency of collection.      3. Increase capture of the blast plume.  One way this can be accomplished is by attaching sheet metal shroud pieces or wings at 45 degrees to the face along the top and sides of the hood.  This will allow better airflow into the hood and direct some of the blast plume into the hood.  The wings can be as large as feasible without compromising the safety of the employee who must handle the castings.      Abatement Schedule      Step 1 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 of controls.      All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person.       Step 2 Abatement shall have been completed by the implementation of feasible engineering and /or administrative controls upon verification of their effectiveness in achieving compliance.      Date by Which Violation Must be Abated:    STEP - 1     (30 days)      Date by Which Violation Must be Abated:    STEP - 2     (90 days)

Issued

Jul 23, 2015

Abate by

Aug 12, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 9130

General-duty citation text

29 CFR 1910.134(h)(4) Respirators that failed an inspection or were otherwise found to be defective were not removed from service and discarded or repaired:    a) Air Arc Big Booth, a supplied air respirator was noted as having a partially collapsed air feed tube which interfered with airflow to the breathing zone of the employee, on or about, June 4, 2015.    ABATEMENT CERTIFICATION REQUIRED

Issued

Jul 23, 2015

Abate by

Dec 31, 2017

Penalty

Initial $6,300 · Current $6,000 Reduced

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(c): Employees were exposed to an airborne concentration of chromium (VI) which exceeded 5 micrograms per cubic meter of air, as an 8-hour time-weighted average:      a) Upgrade Welding, an employee was exposed to chromium (VI) at an 8 hour time weighted average of 0.0152 milligrams per cubic meter of air (mg/M3) while finishing castings.  The exposure was 3.0 times the Permissible Exposure Limit of 0.005 mg/M3 (5 micrograms/M3) The PEL was established to prevent lung cancer, liver damage, and blood changes, including leukocytosis, leukopenia, and eosinophilia. The exposure was established over 429 minutes of personal sampling conducted on June 10, 2015.  Zero exposure was assumed for the unsampled period of time.      ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED

Issued

Jul 23, 2015

Abate by

Dec 31, 2017

Penalty

Initial $0 · Current $0

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:      a) Upgrade Welding, an employee was exposed to chromium (VI) at an 8 hour time weighted average of 0.0152 milligrams per cubic meter of air (mg/M3) while finishing castings and feasible engineering controls or work practices were not implemented.  The exposure was 3.0 times the Permissible Exposure Limit of 0.005 mg/M3.  The PEL was established to prevent lung cancer, liver damage, and blood changes, including leukocytosis, leukopenia, and eosinophilia. The exposure was established over 429 minutes of personal sampling conducted on June 10, 2015.  Zero exposure was assumed for the unsampled period of time.      ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED       General methods of control would include, but are not limited to the following:      1. Replace the existing smoke filtration unit with a more effective unit capable of increased fume capture during welding and air arcing.      2. Fabricate a jig in which the snorkel capture device can rest specifically during air arcing.  The jig should have shrouding such that the fume and particle blast directs the material into the snorkel.      3. Place the cleaning of the hood and exhaust ductwork on a preventative maintenance schedule such that restrictive blockages are prevented which decreases efficiency of collection.      Abatement Schedule      Step 1 Effective respiratory protection shall be provided to and 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 of controls.      All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person.       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.      Date by Which Violation Must be Abated:    STEP - 1     (15 days)      Date by Which Violation Must be Abated:    STEP - 2     (30 days)      Date by Which Violation Must be Abated:    STEP - 3     (90 days)

Issued

Jul 23, 2015

Abate by

Aug 12, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(g)(1)(i): The employer did not provide each employee an appropriate respirator during periods necessary to install or implement feasible engineering and work practice controls:    a) Upgrade Welding, employees were exposed to chromium (VI) at an 8 hour time weighted average of 0.0152 milligrams per cubic meter of air (mg/M3) while finishing castings and did not wear respiratory protection, on or about June 10, 2015.  ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED

Issued

Jul 23, 2015

Abate by

Aug 27, 2015

Penalty

Initial $4,500 · Current $4,500

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(k)(1)(i)(A) The employer did not make medical surveillance available for all employees who were or could be occupationally exposed to chromium (VI) at or above the action level for 30 or more days a year:    a) Air Arc Carousel, an employee was exposed to chromium (VI) above the Action Level at an 8 hour time weighted average of 0.0033 milligrams per cubic meter of air (mg/M3) while finishing castings and a medical surveillance program was not in effect, on or about June 10, 2015.    b) Air Arc Carousel an employee was exposed to chromium (VI) above the Action Level at an 8 hour time weighted average of 0.0026 milligrams per cubic meter of air (mg/M3) while finishing castings and a medical surveillance program was not in effect, on or about June 10, 2015.    c) Upgrade Welding, an employee was exposed to chromium (VI) above the Action Level at an 8 hour time weighted average of 0.0152 milligrams per cubic meter of air (mg/M3) while finishing castings and a medical surveillance program was not in effect, on or about June 10, 2015.    d) Upgrade Welding Cell, an employee was exposed to chromium (VI) above the Action Level at an 8 hour time weighted average of 0.0026 milligrams per cubic meter of air (mg/M3) while finishing castings and a medical surveillance program was not in effect, on or about June 10, 2015.    e) Cleaning Welding, an employee was exposed to chromium (VI) above the Action Level at an 8 hour time weighted average of 0.0027milligrams per cubic meter of air (mg/M3) while finishing castings and a medical surveillance program was not in effect, on or about June 10, 2015.  f) Air Arc Big Booth, an employee had documented exposure levels to chromium (VI) above the action level in a July 2014 report while finishing castings and a medical surveillance program was not in effect, on or about, June 10, 2015.    ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED

Issued

Jul 23, 2015

Abate by

Aug 27, 2015

Penalty

Initial $4,500 · Current $4,500

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(h)(2)(ii) The employer did not ensure that no employee removed chromium (VI)-contaminated protective clothing or equipment from the workplace, except for those employees whose job it was to launder, clean, maintain, or dispose of such clothing or equipment:      a) Air Arc Big Booth, an employee was exposed to chromium (VI), and took his contaminated pants home on a daily basis, on or about June 10, 2015.      b) Air Arc Carousel, an employee was exposed to chromium (VI), and took his contaminated pants home on a daily basis, on or about June 10, 2015.       c) Upgrade Welding, an employee was exposed to chromium (VI), and took his contaminated pants home on a daily basis, on or about June 10, 2015.      d) Upgrade Welding Cell, an employee was exposed to chromium (VI), and took his contaminated pants and shoes home on a daily basis, on or about June 10, 2015.      e) Cleaning Welding, an employee was exposed to chromium (VI), and took his contaminated pants home on a daily basis, on or about June 10, 2015.       f) Cleaning Welding, an employee was exposed to chromium (VI), and took his contaminated pants and shoes home on a daily basis, on or about June 10, 2015.       ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED

Issued

Jul 23, 2015

Abate by

Aug 27, 2015

Penalty

Initial $2,700 · Current $0 Reduced

Hazardous substances 0689

General-duty citation text

29 CFR 1910.1026(e)(2) The employer did not ensure that a regulated area for chromium (VI) was demarcated from the rest of the workplace in a manner that adequately established and alerted employees of the boundaries of the regulated area:      a) Air Arc Carousel and Big Booth center was not posted with signage which notified employees of the regulated areas, on or about June 10, 2015.      b) Upgrade Welding area was not posted with signage which notified employees of the regulated areas, on or about June 10, 2015.      ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED