OSHA Inspection: MIBA BEARINGS US, LLC

Issued

Nov 3, 2015

Abate by

Feb 29, 2016

Penalty

Initial $7,000 · Current $4,200 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(c)(1): Permissible exposure limit.  The employer shall assure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m(3)) averaged over an 8-hour period.    On or about September 11, 2015, the employer failed to control airborne emissions of lead to assure that the permissible exposure limit was not exceeded for the following employee exposures:    a.) An employee working in the Foundry pouring parts was exposed to an 8 hour time weighted average of 104.0 micrograms lead per cubic meter air during a 399 minute sampling period. Zero exposure was assumed for the 81 minutes unsampled. This exposure is 2.08 times the permissible exposure limit for lead.    b.) An employee working in the Salvage room removing excess coating from parts was exposed to an 8 hour time weighted average of 11,225 micrograms lead per cubic meter air during a 450 minute sampling period. Zero exposure was assumed for the 30 minutes unsampled. This exposure is 224.5 times the permissible exposure limit for lead.    Health hazards associated with exposure to lead include impaired kidney function, blood system impacts, carcinogenicity, nervous system effects and teratogenic effects.

Issued

Nov 3, 2015

Abate by

Jun 30, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(1)(i): Methods of compliance - Engineering controls.  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.    On or about September 11, 2015, the employer failed to implement effective engineering controls for employees exposed to lead above the permissible exposure limit:    a.)  for employees performing routine duties in the Foundry department (see citation 3 item 1a instance a for exposure information;) and     b.)  for a Salvage area employee performing routine repair duties (See citation 3 item 1a instance b for exposure information.)     ABATEMENT NOTE       Step 1  Abatement due        Modify the existing respiratory protection program to provide a selection that results in a maximum use concentration not exceeded by the actual exposure levels involved with Salvage repair operations.       Step 2  Abatement due        Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposure to hazardous substances as referenced in this citation. This plan shall include, at a minimum, target dates for following actions, which must be consistent with the abatement dates required by this citation:       1.     Evaluation and listing of engineering control options; to include the evaluation for potential modification of existing controls, handtools and related equipment.   2.     Selection and criteria for selection of optimum control methods and subsequent completion of selected control design;   3.     Procurement of equipment and materials associated with installation, installation and operation of selected control measures;   4.     Testing, and acceptance, or modification/supplementation/redesign of controls;   5.     All proposed control measures shall be approved by a competent industrial hygienist, competent industrial ventilation specialist experienced in complex processes or other technically qualified person.       Step 3  Abatement due       Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.       Feasible administrative and/or engineering controls could include but the employer is not bound by or limited to, the following:       1.     Equip processes with additional local exhaust ventilation such as, but not limited to, downdraft collection tables or collection points, hooded ventilation that is more locally placed in designated worker positions, applying controls to the spincasting machine when in the open position and applying slotted capture ventilation at emission points;   2.     Improve existing local exhaust ventilation systems by increasing efficiency of collection with increased air movement by installation of targeted make-up air systems, by modifying existing ductwork and duct systems, by increasing fan motor/collector capacities and/or by modifying equipment;   3.     Utilizing wet methodology for control of airborne material available for inhalation;      Develop work practices incorporated as standard operating procedures to reduce emissions of airborne material available for inhalation.

Issued

Nov 3, 2015

Abate by

Feb 4, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(f)(2)(i): Respiratory protection.  Respirator program.  The employer must implement a respiratory protection program in accordance with �� 1910.134(b) through (d) (except (d)(1)(iii)), and (f) through (m), which covers each employee required by this section to use a respirator.  On or about September 11, 2015, the employer's respiratory protection program was not compliant with 1910.134. A Salvage employee was exposed in excess of approximately 225 times the permissible exposure limit for lead, thus the assigned protection factor for the loose fitting powered air purifying respirator was exceeded and the maximum use concentration was exceeded in violation of 1910.134(d)(3)(i)(A)(1) and 1910.134(d)(3)(i)(B)(1) respectively.

Issued

Oct 1, 2015

Abate by

Nov 5, 2015

Penalty

Initial $5,500 · Current $3,300 Reduced

Hazardous substances A100

General-duty citation text

29 CFR 1910.132(d)(1): Hazard assessment and equipment selection.  The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:    29 CFR 1910.132(d)(1)(i): Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;    a. On or about July 10, 2015, the employer had not made an appropriate selection and then required use of personal protective equipment appropriate for molten aluminum operations in the Foundry room that involve preparing, handling and pouring molten aluminum metal. Employees use employer identified uniforms made of Indura material for body/torso, upper extremity and lower extremity protection from these exposures which is not appropriate for protection from molten aluminum splash.    b. On or about July 10, 2015, the employer had not made an appropriate selection of personal protective equipment for the hands for molten metal operations in the Foundry room. The employer's selection does not address the potential to "burn" through untreated cloth gloves at the wrist, or prevent/protect against molten metal splashing onto or rolling into the area between uniform sleeve and the glove.

Issued

Oct 1, 2015

Abate by

Nov 30, 2015

Penalty

Initial $5,500 · Current $3,300 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(d)(6): Lead (Pb) Exposure Monitoring - Frequency.    29 CFR 1910.1025(d)(6)(iii): If the initial monitoring reveals that employee exposure is above the permissible exposure limit the employer shall repeat monitoring quarterly. The employer shall continue monitoring at the required frequency until at least two consecutive measurements, taken at least 7 days apart, are below the PEL but at or above the action level at which time the employer shall repeat monitoring for that employee at the frequency specified in paragraph (d)(6)(ii), except as otherwise provided in paragraph (d)(7) of this section.    a. On or about July 10, 2015, the employer failed to perform employee exposure for Lead (Pb) on a quarterly basis for employees with exposure exceeding the permissible exposure limit. Foundry operation employee exposure monitoring had not been performed since May 2011.    b. On or about July 10, 2015, the employer failed to perform employee exposure for Lead (Pb) on a quarterly basis for employees with exposure exceeding the permissible exposure limit. Salvage operation(s) employee exposure had not been performed since September 2014.

Issued

Oct 1, 2015

Abate by

Jan 31, 2016

Penalty

Initial $5,500 · Current $3,300 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(3)(ii)(B): Methods of compliance.  Compliance program. Written plans for these compliance programs shall include at least the following: A description of the specific means that will be employed to achieve compliance, including engineering plans and studies used to determine methods selected for controlling exposure to lead;    a. As of and prior to July 10, 2015, the employer's written compliance programs for lead did not include the engineering plans and studies used for selecting the control measure for controlling exposure to lead in Salvage during grinding operations. Information regarding engineering plans or studies for the downdraft bench has not been documented or developed for the design and has not been included in the program; information provided for the downdraft bench did not include engineering plans, design documents, equipment lists and system specifications; such as the required ventilation rates necessary for capture of lead containing dust generated by the grinding operation. Additionally compliance programs for lead regarding the "spray booth" used to control lead exposure from Salvage "metalizing" operations does not contain any engineering plan and study information (beyond an unidentified air flow rate range.)    b. As of and prior to July 10, 2015, the employer's written compliance programs for lead did not include the engineering plans and studies used for selecting the multiple engineering controls in the Foundry room. The written compliance programs do not address, contain or reference any engineering plans, design documents, equipment lists or system specifications or any studies for the capture/exhaust ventilation style engineering controls utilized to control employee lead exposure in Foundry operations.

Issued

Oct 1, 2015

Abate by

Jan 31, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(3)(ii)(C): Methods of compliance. Compliance program. Written plans for these compliance programs shall include at least the following: A report of the technology considered in meeting the permissible exposure limit;    On or about July 10, 2015, the employer's written compliance program for lead did not include any information or reports on technologies considered in covered areas of the facility, including but not limited to the Foundry room and Salvage operations.

Issued

Oct 1, 2015

Abate by

Jan 31, 2016

Penalty

Initial $3,300 · Current $1,980 Reduced

Hazardous substances 1591

General-duty citation text

1910.1025(e)(4)(i):  Methods of compliance.  Mechanical ventilation.  When ventilation is used to control exposure, measurements which demonstrate the effectiveness of the system in controlling exposure, such as capture velocity, duct velocity, or static pressure shall be made at least every 3 months. Measurements of the system's effectiveness in controlling exposure shall be made within 5 days of any change in production, process, or control which might result in a change in employee exposure to lead.    On or about July 10, 2015, the employer failed to perform mechanical ventilation measurements, to demonstrate system effectiveness in controlling employee exposures to lead, for any of the engineering control systems of the facility including those in the Foundry room, Casting area and the Salvage operation.

Issued

Oct 1, 2015

Abate by

Nov 5, 2015

Penalty

Initial $3,300 · Current $1,980 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(i)(2)(ii): Change rooms.  The employer shall assure that change rooms are equipped with separate storage facilities for protective work clothing and equipment and for street clothes which prevent cross-contamination.    On or about July 10, 2015, the employer's change room did not provide for separate storage facilities to prevent cross-contamination for protective footwear and street clothes. Protective footwear is stored in the same locker as employee personal clothing as an ongoing, accepted practice in the change room.

Issued

Oct 1, 2015

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.24(h): "Railings and handrails." Standard railings shall be provided on the open sides of all exposed stairways and stair platforms. Handrails shall be provided on at least one side of closed stairways preferably on the right side descending. Stair railings and handrails shall be installed in accordance with the provisions of 1910.23.  On or about July 10, 2015, the open side of the stairway used for access to the maintenance mezzanine parts room did not have adequate standard railing. The railing was installed without a midrail.

Issued

Oct 1, 2015

Abate by

Nov 30, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(d)(5): Exposure monitoring.  Negative initial determination. Where a determination, conducted under paragraphs (d)(2) and (3) of this section is made that no employee is exposed to airborne concentrations of lead at or above the action level, the employer shall make a written record of such determination. The record shall include at least the information specified in paragraph (d)(3) of this section and shall also include the date of determination, location within the worksite, and the name and social security number of each employee monitored.    On or about July 10, 2015, the negative initial determination record for Production Cell(s) 1-17 employee lead (Pb) exposure monitoring records did not include the name and social security number of employees monitored.

Issued

Oct 1, 2015

Abate by

Jan 31, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(3)(iv): Methods of compliance.  Compliance program.  Written programs must be revised and updated at least annually to reflect the current status of the program.    On or about July 10, 2015, the employer failed to assure that written compliance programs were revised and updated on an annual basis. The employer's written compliance program, Procedure No. SMP5.9.24, had not been reviewed, revised and updated since April 2012.

Issued

Oct 1, 2015

Abate by

Nov 30, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(n)(1)(ii): Recordkeeping.  Exposure monitoring.  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;     On or about July 10, 2015, the employer does not include names, social security numbers and job classifications of employees, and of other employees the measurement is intended to represent; in lead (Pb) exposure monitoring records.

Issued

Oct 1, 2015

Abate by

Nov 30, 2015

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(n)(1)(ii): Recordkeeping.  Exposure monitoring.  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)(E): The environmental variables that could affect the measurement of employee exposure.    On or about July 10, 2015, the employer does not include environmental variables, such as job task(s)/production process being performed during monitoring, production rates or lead content of material used in the operational task being performed in employee lead (Pb) exposure monitoring records.