OSHA Inspection: CLOSED LOOP INC.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $1,785 · Current $1,785

Hazardous substances 04901591BWPB

General-duty citation text

29 CFR 1910.134(c)(3): The employer shall designate a program administrator who is qualified by appropriate training or experience that is commensurate with the complexity of the program to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness.    a.  At the work site, the employer had a respiratory protection program, effective June 1, 2013 and revised May 2014, for employees who were required to wear respiratory protection at the work site. The employer had not named a program administrator for the Respiratory Protection Program.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $2,380 · Current $2,380

Hazardous substances 04901591BWPB

General-duty citation text

29 CFR 1910.134(e)(1): General. The employer shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.    a.   At the work site, the employer required employees with exposure to lead above the Permissible Exposure Limit (PEL) to use respiratory protection at all times in the plant.  The employer had documentation for fit testing and respirator training of eight employees that did not include a documented medical evaluation before the employee was fit tested and/or allowed to wear a respirator.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1027(l)(6)(i): To determine an employee's fitness for respirator use, the employer shall provide a medical examination that includes the elements specified in (l)(6)(A)-(D). This examination shall be provided prior to the employee's being assigned to a job that requires the use of a respirator or no later than 90 days after this section goes into effect, whichever date is later, to any employee without a medical examination within the preceding 12 months that satisfies the requirements of this paragraph.    a.  At the work site, the employer required employees with exposure to cadmium above the Permissible Exposure Limit (PEL) to use respiratory protection at all times in the plant.  The employer had documentation for fit testing and respirator training of eight employees that did not include a documented medical evaluation before the employee was fit tested and/or allowed to wear a respirator.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $3,570 · Current $3,570

Hazardous substances 04901591BWPB

General-duty citation text

29 CFR 1910.134(h)(2): Storage. The employer shall ensure that respirators are stored as follows:    29 CFR 1910.134(h)(2)(i): All respirators shall be stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and they shall be packed or stored to prevent deformation of the facepiece and exhalation valve.    a.  At the work site, the employer provided employees who used respiratory protection with open, unpainted wooden cubicles where they were to leave their respirators, along with their footwear, gloves, eye protection, sleeves and personal clothing.  The cubicles were located in the same room where the clean coveralls were made available and where contaminated coveralls were removed and placed in bins.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 04901591BWPB

General-duty citation text

29 CFR 1910.134(k): Training and information. This paragraph requires the employer to provide effective training to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary. This paragraph also requires the employer to provide the basic information on respirators in Appendix D of this section to employees who wear respirators when not required by this section or by the employer to do so.    29 CFR 1910.134(k)(1)(v): What the procedures are for maintenance and storage of the respirator;    a.  At the work site, employees who were required to wear respiratory protection left their respirators in open cubicles in the room where contaminated coveralls were removed and placed in open, unpainted wooden cubicles with their other personal protective equipment that included (but was not limited to) boots, gloves, sleeves, coveralls, head coverings and personal clothing.  The employer did not ensure that employees were adequately trained on the proper procedures for maintenance and storage of respirators.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $4,900 · Current $4,900

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1000(a)(2): Table Z-1. An employee's exposure to any substance in Table Z-1, the exposure limit of which is not preceded by a "C", shall not exceed the 8-hour Time Weighted Average given for that substance in any 8-hour work shift of a 40-hour work week.    a.  At the work site located at 1675 Watkins Road, Columbus, Ohio, the employer had not developed and/or implemented a monitoring system for employees who worked in the glass line breaking area and were exposed to lead above the 8 hour TWA PEL of 0.050 mg/m3 as listed in Table Z-1 for lead.  An employee who worked in the glass breaking line area was exposed to lead at 0.1200 mg/m3 during sampling on April 16, 2015.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(e)(1)(i): Where any employee is exposed to lead above the permissible exposure limit for more than 30 days per year, the employer shall 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 below, 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 are not sufficient to reduce employee exposure to or below the permissible exposure limit, the employer shall nonetheless 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.  At the work site, employees who worked in the glass breaking line area were exposed to lead above the Permissible Exposure Limit (PEL).  The employer did not have functioning ventilation and/or work practice controls in place to contain, reduce and/or remove lead from the employee work area(s) in the glass line breaking area.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $4,900 · Current $4,900

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1000(a)(2): Table Z-1. An employee's exposure to any substance in Table Z-1, the exposure limit of which is not preceded by a "C", shall not exceed the 8-hour Time Weighted Average given for that substance in any 8-hour work shift of a 40-hour work week.    a.   At the work site located at 1675 Watkins Road, Columbus, Ohio, the employer had not developed and/or implemented a monitoring system for employees who worked in the glass line breaking area and were exposed to cadmium above the 8 hour TWA PEL of 0.005 mg/m3 as listed in Table Z-1 for cadmium.  An employee who worked in the glass breaking line area was exposed to cadmium at 0.0064 mg/m3 during sampling on April 16, 2015.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1027(f)(1)(i): Except as specified in paragraphs (f)(1)(ii), (iii) and (iv) of this section the employer shall implement engineering and work practice controls to reduce and maintain employee exposure to cadmium at or below the PEL, except to the extent that the employer can demonstrate that such controls are not feasible.    a.     At the work site located at 1675 Watkins Road, Columbus, Ohio, the employer had not developed and/or implemented a monitoring system for employees who worked in the glass line breaking area and were exposed to cadmium above the 8 hour TWA PEL of 0.005 mg/m3 as listed in Table Z-1 for cadmium.  An employee who worked in the glass breaking line area was exposed to cadmium at 0.0064 mg/m3 during sampling on April 16, 2015.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $2,380 · Current $2,380

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(d)(2): Initial determination. Each employer who has a workplace or work operation covered by this standard shall determine if any employee may be exposed to lead at or above the action level.    a.  At the work site, employees had exposure to lead above the Permissible Exposure Limit (PEL) in the glass line breaking area.  The employer did not perform any initial monitoring to determine exposure levels that included the glass line breaking area.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1027(d)(2)(i): Initial monitoring. Except as provided for in paragraphs (d)(2)(ii) and (d)(2)(iii) of this section, the employer shall monitor employee exposures and shall base initial determinations on the monitoring results.    a.  At the work site, employees had exposure to cadmium above the Permissible Exposure Limit (PEL) in the glass line breaking area.  The employer did not perform any initial monitoring to determine exposure levels that included the glass line breaking area.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $4,900 · Current $4,900

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(e)(3)(iv): Written programs must be revised and updated at least annually to reflect the current status of the program.    a. At the work site, employees who worked in the glass breaking line area were exposed to lead above the 8 hour TWA Permissible Exposure Limit (PEL) of 0.050 mg/m3.  The employer had a written lead program dated 12/01/12 and revised 12/12/12, but the program had not been updated annually to reflect changes in production which included (but were not limited to) changes in the ventilation systems in the glass breaking line area, increased numbers of employees, increased shifts and increase amounts of materials being processed.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1027(f)(2)(iii): The written compliance programs shall be reviewed and updated at least annually, or more often if necessary, to reflect significant changes in the employer's compliance status.    a. At the work site, employees who worked in the glass breaking line area were exposed to cadmium above the 8 hour TWA PEL of 0.005 mg/m3.  The employer had a written cadmium program dated 12/01/12 and revised 12/12/12, but the program had not been updated annually and did not reflect changes in production which included (but were not limited to) changes in the ventilation systems in the glass breaking line area, increased numbers of employees, increased shifts and increase amounts of materials being processed.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $4,900 · Current $100 Reduced

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(g)(1): Provision and use. 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 shall provide at no cost to the employee and assure that the employee uses appropriate protective work clothing and equipment such as, but not limited to:    29 CFR 1910.1025(g)(1)(ii): Gloves, hats, and shoes or disposable shoe coverlets;     a. At the work site, employees who worked in the glass breaking line area wore coveralls, safety glasses, and respirators while breaking glass containing lead.  The employer had not provided employees with head coverings or shoe covers while they were working in the glass line breaking area where employees were exposed to lead levels above the 8 hour TWA Permissible Exposure Limit (PEL).

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1027(i)(1): "Provision and use." If an employee is exposed to airborne cadmium above the PEL or where skin or eye irritation is associated with cadmium exposure at any level, the employer shall provide at no cost to the employee, and assure that the employee uses, appropriate protective work clothing and equipment that prevents contamination of the employee and the employee's garments. Protective work clothing and equipment includes, but is not limited to:    29 CFR 1910.1027(i)(1)(ii): Gloves, head coverings, and boots or foot coverings; and,    a. At the work site, employees who worked in the glass line breaking area were exposed to cadmium levels above the 8 hour TWA Permissible Exposure Limit (PEL ) of 0.005 mg/m3 as listed in Table Z-1 for cadmium.  The employer had not provided employees with head coverings and shoe covers while they were working in the glass line breaking area.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $1,785 · Current $1,785

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(g)(2)(vi): The employer shall inform in writing any person who cleans or launders protective clothing or equipment of the potentially harmful effects of exposure to lead.    a.  At the work site, employee who were exposed to lead above the Permissible Exposure Limit (PEL) in the glass breaking line area placed contaminated uniforms in bins for pick up by a laundry service.  The employer did not have documentation that the uniform service had been notified in writing of the presence of lead on the soiled laundry.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1027(i)(3)(v): The employer shall inform any person who launders or cleans protective clothing or equipment contaminated with cadmium of the potentially harmful effects of exposure to cadmium and that the clothing and equipment should be laundered or cleaned in a manner to effectively prevent the release of airborne cadmium in excess of the PEL.    a.  At the work site, employees who were exposed to cadmium above the Permissible Exposure Limit (PEL)  in the glass breaking line area placed their contaminated uniforms in bins for pick up by a laundry service.  The employer did not have documentation that the uniform service had been notified in writing of the presence of cadmium at the work site.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $2,975 · Current $2,975

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(h)(1): Surfaces. All surfaces shall be maintained as free as practicable of accumulations of lead.    a. At the work site, there was an accumulation of lead-containing material on stored materials throughout the work site which included (but was not limited to) storage boxes of finished product for shipment, received materials for processing, floors, walls, furniture and equipment.  The employer had not kept the work site as free as possible from accumulation of lead and lead-containing materials.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1027(k)(1): All surfaces shall be maintained as free as practicable of accumulations of cadmium.    a. At the work site, there was an accumulation of cadmium-containing material throughout the work site which included (but was not limited to) storage boxes of finished product for shipment, received materials for processing, floors, walls, doors, furniture and equipment.  The employer had not kept the work site as free as possible from accumulation of cadmium.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $3,570 · Current $3,570

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(h)(2)(ii): Shoveling, dry or wet sweeping, and brushing may be used only where vacuuming or other equally effective methods have been tried and found not to be effective.    a. At the work site, employees who were exposed to lead above the PEL in the glass breaking line area cleaned up during and after their shifts by methods that included using brooms to sweep contaminated debris into piles that were placed in trash bins.  The employer had not provided other means of cleaning the lead that included (but were not limited to) wet methods of sweeping, and/or vacuuming with appropriate HEPA filters.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1027(k)(5): Shoveling, dry or wet sweeping, and brushing may be used only where vacuuming or other methods that minimize the likelihood of cadmium becoming airborne have been tried and found not to be effective.    a. At the work site, employees who worked in the glass breaking line area cleaned up during and after their shifts by methods that included using brooms to sweep cadmium-containing debris into piles that were placed in trash bins.  The employer had not provided other means of cleaning that included (but were not limited to) wet methods of sweeping, and/or vacuuming with appropriate HEPA filters.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $3,570 · Current $3,570

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(i)(3)(i): The employer shall 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.  At the work site, employees who worked in the glass breaking line area were exposed to lead above the Permissible Exposure Limit (PEL).  The employer did not ensure that employees who worked in the glass breaking area showered at the end of their work shift.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0490C141C142

General-duty citation text

29 CFR 1910.1027(j)(3)(i): The employer shall assure that employees who are exposed to cadmium above the PEL shower during the end of the work shift.      a.  At the work site, employees who worked in the glass breaking line area were overexposed to cadmium.  The employer did not ensure that employees with airborne exposure to cadmium above the Permissible Exposure Limit (PEL) showered at the end of their work shift.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $2,380 · Current $2,380

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(n)(1)(i): The employer shall establish and maintain an accurate record of all monitoring required in paragraph (d) of this section.  This record shall include:    29 CFR 1910.1025(n)(1)(ii)(C): The type of respiratory protective devices worn, if any;    a.  At the work site, employees had exposure to lead above the Permissible Exposure Limit (PEL) in the glass line breaking area.  The employer did not maintain complete records of the monitoring in that sampling to determine exposure levels did not include the type(s) of respiratory protection worn by employees in the glass line breaking area which included (but was not limited to) tight-fitting half face respirators and full face respirators.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(n)(1)(i): The employer shall establish and maintain an accurate record of all monitoring required in paragraph (d) of this section.  This record shall include:    29 CFR 1910.1025(n)(1)(ii)(D): Name, social security number, and job classification of the employee monitored and of all other employees whose exposure the measurement is intended to represent;     a.  At the work site, employees with exposure to lead above the Permissible Exposure Limit (PEL) in the glass line breaking area were required by the employer to have blood lead levels drawn at specific intervals.  The employer did not maintain complete records of the monitoring in that the records did not contain details that included (but were not limited to) job classification and other employees exposed that the monitoring was also designed to represent.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1025(n)(1)(i): The employer shall establish and maintain an accurate record of all monitoring required in paragraph (d) of this section.  This record shall include:    29 CFR 1910.1027(n)(1)(ii)(B): The name, social security number, and job classification of the employees monitored and of all other employees whose exposures the monitoring is intended to represent;    a.  At the work site, employees had exposure to cadmium above the Permissible Exposure Limit (PEL) in the glass line breaking area.  The employer did not maintain complete records of the monitoring, in that sampling to determine cadmium exposure levels did not include the glass line breaking area.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1027(n)(1)(i): The employer shall establish and maintain an accurate record of all monitoring required in paragraph (d) of this section.  This record shall include:    2929 CFR 1910.1027(n)(1)(ii)(D): The type of respiratory protective device, if any, worn by the monitored employee;    a.  At the work site, employees had exposure to cadmium above the Permissible Exposure Limit (PEL) in the glass line breaking area.  The employer did not maintain complete records of the monitoring in that there was no record of what respiratory protection was worn by sampled employees or other employees who worked in areas with the same exposure.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $2,380 · Current $2,380

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1027(l)(2)(i): The employer shall provide an initial (preplacement) examination to all employees covered by the medical surveillance program required in paragraph (l)(1)(i) of this section. The examination shall be provided to those employees within 30 days after initial assignment to a job with exposure to cadmium or no later than 90 days after the effective date of this section, whichever date is later.    29 CFR 1910.1027(l)(1)(i)(A): Currently exposed - The employer shall institute a medical surveillance program for all employees who are or may be exposed to cadmium at or above the action level unless the employer demonstrates that the employee is not, and will not be, exposed at or above the action level on 30 or more days per year (twelve consecutive months); and,    a. At the work site, employees working in the glass breaking room were exposed to cadmium above the Permissible Exposure Limit (PEL) while breaking glass for recycling.  The employer did not perform initial medical surveillance for employees with cadmium exposure above the PEL.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(j)(2)(i): Blood lead and ZPP level sampling and analysis. The employer shall make available biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels to each employee covered under paragraph (j)(1)(i) of this section on the following schedule:    29 CFR 1910.1025(j)(2)(i)(B): At least every two months for each employee whose last blood sampling and analysis indicated a blood lead level at or above 40 ug/100 g of whole blood. This frequency shall continue until two consecutive blood samples and analyses indicate a blood lead level below 40 ug/100 g of whole blood; and    a.  For an employee with two blood lead levels above the action level of 40 micrograms per liter, the employer did not have repeat blood levels drawn.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 15911592BWPB

General-duty citation text

29 CFR 1910.1025(j)(3)(i): Frequency. The employer shall make available medical examinations and consultations to each employee covered under paragraph (j)(1)(i) of this section on the following schedule:    29 CFR 1910.1025(j)(3)(i)(B): Prior to assignment for each employee being assigned for the first time to an area in which airborne concentrations of lead are at or above the action level;    a. Employees who worked in the glass line breaking area were exposed to lead above the Permissible Exposure Limit (PEL).  The employer did not have baseline blood lead levels drawn on seven employees prior to assigning them to the glass line breaking area where the airborne lead levels were known to be at or above the PEL.

Issued

Aug 14, 2015

Abate by

Mar 27, 2017

Penalty

Initial $1,785 · Current $1,785

Hazardous substances 0490C141C142SLT3

General-duty citation text

29 CFR 1910.1027(m)(2)(i): Warning signs shall be provided and displayed in regulated areas. In addition, warning signs shall be posted at all approaches to regulated areas so that an employee may read the signs and take necessary protective steps before entering the area.    a. At the work site, employees were exposed to cadmium above the Permissible Exposure Limit (PEL) in the glass breaking line area. The employer had not provided warning signs at entrances to the glass breaking room about the cadmium hazard(s) inside.