OSHA Inspection: TOTAL WALL, INC.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $2800.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.23(c)(3): Regardless of height, open-sided floors, walkways, platforms, or runways above or adjacent to dangerous equipment, pickling or galvanizing tanks, degreasing units, and similar hazards were not guarded with a standard railing and toe board.    a) Mixing tank R4 was not guarded with a standard railing.    b) Mixing tank R3 was not guarded with a standard railing.    c) Mixing tank R2 was not guarded with a standard railing.    d) Mixing tank R1 was not guarded with a standard railing.    e) Mixing tank L1 was not guarded with a standard railing.    f) Mixing tank L2 was not guarded with a standard railing.    g) Mixing tank L3 was not guarded with a standard railing.    h) Mixing tank L4 was not guarded with a standard railing.    i) Mixing tank L5 was not guarded with a standard railing.    j) Mixing tank L6 was not guarded with a standard railing.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $2800.00 · Current $2800.00

General-duty citation text

29 CFR 1910.24(h): Standard railings were not provided on the open sides of all exposed stairways and stair platforms:    The employer did not ensure that standard railings were provided on each side the fixed stairs leading to the dry bagging platform.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $4900.00 · Current $4900.00

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:    The employer did to establish a written respiratory protection program for employees that are required to wear respirators.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $4900.00 · Current $0.00 Reduced

Hazardous substances 90109135

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer did not identify and evaluate the respiratory hazard(s) in the workplace; including a reasonable estimate of employee exposures to respiratory hazards and identification of the contaminant's chemical state and physical form:    The employer did not evaluate the respiratory hazards in the workplace, including but not, the following:    a) Employee exposure to respirable crystalline silica in the Wet Line and Dry Base areas.    b) Employee exposure to total dust in the Wet Line and Dry Base areas.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $2800.00 · Current $0.00 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:    The employer did not provide a medical evaluation to employees working on the Wet Line and Dry Base areas prior to the employees being required to wear half-mask, tight fitting respirators, on a daily basis in the workplace.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $3500.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.134(f)(1): The employer did not ensure that employee(s) required to use a tight-fitting facepiece respirator passed the appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT):    The employer did not conduct a qualitative or quantitative fit test for employees in the Wet Line and Dry Base areas required to wear a tight-fitting facepiece respirators.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $4900.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.134(k)(3): Training was not provided prior to requiring employees to use a respirator in the workplace:    The employer did not provide training prior to requiring employees in the Wet Line and Dry Base areas to wear a respirator in the workplace.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $3500.00 · Current $3500.00

General-duty citation text

29 CFR 1910.151(c): Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:  The employer did not provide suitable facilities for quick drenching or flushing of the eyes and body where employees were handling corrosive materials, including but not limited to Kathom LX 1.5% Biocide, Dowicil QK-20 Antimicrobial, and Miracle Pressure Hydrated Type S Lime.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $3500.00 · Current $3500.00

General-duty citation text

29 CFR 1910.178(m)(2): Employee(s) stood under or passed under the elevated portion of a powered industrial truck(s)  Wet line mixers were observed working beneath suspended loads of powered industrial trucks.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $3500.00 · Current $3500.00

General-duty citation text

29 CFR 1910.178(q)(1): Any power-operated industrial truck not in safe operating condition was not taken out of service, and/or repairs were not made by authorized personnel:    The powered industrial trucks used in the Wet Line and Dry Base areas did not have operational seat belts and were not taken out of service.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $3500.00 · Current $0.00 Reduced

General-duty citation text

29 CFR 1910.178(a)(6): The employer did not ensure that all nameplates or markings were not maintained in a legible condition    The Toyota sit down LP powered industrial trucks used in the Wet Line and Dry Base areas did not have nameplates maintained in a legible condition.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $4900.00 · Current $3500.00 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 - total dust listed in Table Z-1 in excess of the 8 hour Time Weighted Average concentration of 15 mg/m3.    On April 22, 2015, a Dry Base bagger was exposed to an 8 hour Time Weighted Average concentration of 31.2 mg/m3 of particulates not otherwise regulated - total dust which is 2 times the permissible exposure limit of 15 mg/m3.  The sample was taken over 449 minutes and zero exposure was assumed for the remaining 31 minutes.

Issued

2015-09-11 00:00:00

Abate by

2016-02-17 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):    On April 22, 2015, a Dry Base bagger was exposed to an 8 hour Time Weighted Average concentration of 31.2 mg/m3 of particulates not otherwise regulated - total dust which is 2 times the permissible exposure limit of 15 mg/m3.  The sample was taken over 449 minutes and zero exposure was assumed for the remaining 31 minutes.  General methods of control applicable in these circumstances include, but are not limited to the following:    1. Installation of localized ventilation at the Dry Base bagging operation.  Ensure that the ventilation meets or exceeds the most current recommendations outlined in the Handbook of the American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE).     2. Research administrative controls to reduce the amount of Particulates Not Otherwise Regulated - Total Dust released into the work environment.  This may include body positioning, employee rotation, and handling of finished product.     Disclaimers:  1. The employer is not limited to the abatement methods suggested by OSHA;  2. The methods explained are general and may not be effective in all cases; and  3. The employer is responsible for selecting and carrying out an effective abatement.    Abatement Schedule:   STEP 1:   Effective respiratory protection shall be provided and used by exposed employees               as an interim protective measure until feasible engineering controls can be               implemented or whenever such controls fail to reduce employee exposures 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 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 abatement dates required by this citation:                 1. Evaluation of engineering control options;             2. Selection of optimum control methods and completion of design;             3. Procurement, installation, and operation of selected control measures; and             4. Testing and acceptance or modification/redesign of controls.                 NOTE: 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 controls upon verification of their effectiveness in achieving             compliance.                   Date by Which Violation Must be Abated:  STEP-1    XX/XX/2015              Date by Which Violation Must be Abated:  STEP-2    XX/XX/2015              Date by Which Violation Must be Abated:  STEP-3    XX/XX/2015

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $4900.00 · Current $3500.00 Reduced

Hazardous substances 9010

General-duty citation text

29 CFR 1910.1000(c): An employee(s) was exposed to respirable quartz crystalline silica in excess of the 8-hour time weighted average limits listed in Table Z-3:    On April 22, 2015, a wet line mixing operator was exposed to an 8-hour time weighted average of 1.02 mg/m3 of respirable quartz crystalline silica, which was 1.5 times the permissible exposure limit of 0.67 mg/m3.  The sample was taken over 470 minutes and zero exposure was assumed for the remaining 10 minutes.    On April 22, 2015, a dry line bagger was exposed to an 8-hour time weighted average of 4.04 mg/m3 of respirable quartz crystalline silica, which was 2.0 times the permissible exposure limit of 2 mg/m3.  The sample was taken over 454 minutes and zero exposure was assumed for the remaining 26 minutes.

Issued

2015-09-11 00:00:00

Abate by

2016-02-17 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 9010

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):    On April 22, 2015, a wet line mixing operator was exposed to an 8-hour time weighted average of 1.02 mg/m3 of respirable quartz crystalline silica, which was 1.5 times the permissible exposure limit of 0.67 mg/m3.  The sample was taken over 470 minutes and zero exposure was assumed for the remaining 10 minutes.    On April 22, 2015, a dry line bagger was exposed to an 8-hour time weighted average of 4.04 mg/m3 of respirable quartz crystalline silica, which was 2.0 times the permissible exposure limit of 2 mg/m3.  The sample was taken over 454 minutes and zero exposure was assumed for the remaining 26 minutes.    1. Consider product substitution of additives which do not contain crystalline silica.    2. Installation of localized ventilation at the Dry Base bagging operation.  Ensure that the ventilation meets or exceeds the most current recommendations outlined in the Handbook of the American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE).     3. Installation of localized ventilation in the Wet Line mixing area.  Ensure that the ventilation meets or exceeds the most current recommendations outlined in the Handbook of the American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE).    4. Research administrative controls to reduce the amount of crystalline silica released into the work environment.  This may include task procedures, such as not shaking bags/containers to reduce the amount of dust released.    Disclaimers:  1. The employer is not limited to the abatement methods suggested by OSHA;  2. The methods explained are general and may not be effective in all cases; and  3. The employer is responsible for selecting and carrying out an effective abatement.    Abatement Schedule:   STEP 1:   Effective respiratory protection shall be provided and used by exposed employees               as an interim protective measure until feasible engineering controls can be               implemented or whenever such controls fail to reduce employee exposures 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 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 abatement dates required by this citation:                 1. Evaluation of engineering control options;             2. Selection of optimum control methods and completion of design;             3. Procurement, installation, and operation of selected control measures; and             4. Testing and acceptance or modification/redesign of controls.                 NOTE: 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 controls upon verification of their effectiveness in achieving             compliance.                   Date by Which Violation Must be Abated:  STEP-1    XX/XX/2015              Date by Which Violation Must be Abated:  STEP-2    XX/XX/2015              Date by Which Violation Must be Abated:  STEP-3    XX/XX/2015

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $4900.00 · Current $4900.00

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:    The employer did not develop a written hazard communication program for Wet Line and Dry Base employees working with hazardous materials, including, but not limited to, crystalline silica.

Issued

2015-09-11 00:00:00

Abate by

2015-10-02 00:00:00

Penalty

Initial $4900.00 · Current $0.00 Reduced

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:    The employer did not train Wet Line and Dry Base employees on the hazardous chemicals in their work area, including, but not limited to, crystalline silica, Portland cement and Hexavalent Chromium.