OSHA Inspection: AS AMERICA INC.

Issued

Nov 19, 2015

Abate by

Nov 29, 2015

Penalty

Initial $7,000 · Current $3,500 Reduced

Hazardous substances 9010

General-duty citation text

29 CFR 1910.134(a)(2): A respirator was not provided by the employer to each employee when such equipment was necessary to protect the health of the employee and the employer did not establish and maintain a respiratory protection program which included the requirements outlined in 29 CFR 1910.134(c):    a) An employee working as a Spotter in the Finish Coat booth, on 10/19/2015, touching up the finish coat, was exposed to respirable dust containing 3.1% Silica at an 8-hour time-weighted average level of 2.307 milligrams per cubic meter of air (mg/m3). This level is approximately 1.18 times the PEL of 1.961 mg/m3.  This exposure was derived from one sample collected over a 477 minute sample period, a zero increment was added for the 3 minutes not sampled. This employee did not wear a respirator.    b) a) An employee working in the Robot Ground Coat booth, on 10/19/2015, monitoring the operation and cleaning the booth, was exposed to respirable dust containing 22 % Silica at an 8-hour time-weighted average level of 1.096 milligrams per cubic meter of air (mg/m3). This level is approximately 2.33 times the PEL of 0.471 mg/m3.  This exposure was derived from one sample collected over a 471 minute sample period, a zero increment was added for the 9 minutes not sampled. This employee wore a respirator for a part of the shift.

Issued

Nov 19, 2015

Abate by

Mar 23, 2016

Penalty

Initial $7,000 · Current $3,500 Reduced

Hazardous substances 9010

General-duty citation text

29 CFR 1910.1000(c): Employees were exposed to respirable silica in excess of the 8-hour time weighted average calculated limit listed in Table Z-3:    a) An employee working as a Spotter in the Finish Coat booth, on 10/19/2015, touching up the finish coat, was exposed to respirable dust containing 3.1% Silica at an 8-hour time-weighted average level of 2.307 milligrams per cubic meter of air (mg/m3). This level is approximately 1.18 times the PEL of 1.961 mg/m3.  This exposure was derived from one sample collected over a 477 minute sample period, a zero increment was added for the 3 minutes not sampled.    b) An employee working in the Robot Ground Coat booth, on 10/19/2015, monitoring the operation and cleaning the booth, was exposed to respirable dust containing 22 % Silica at an 8-hour time-weighted average level of 1.096 milligrams per cubic meter of air (mg/m3). This level is approximately 2.33 times the PEL of 0.471 mg/m3.  This exposure was derived from one sample collected over a 471 minute sample period, a zero increment was added for the 9 minutes not sampled.

Issued

Nov 19, 2015

Abate by

Mar 23, 2016

Penalty

Initial $0 · Current $0

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):    a) An employee working as a Spotter in the Finish Coat booth, on 10/19/2015, touching up the finish coat, was exposed to respirable dust containing 3.1% Silica at an 8-hour time-weighted average level of 2.307 milligrams per cubic meter of air (mg/m3). This level is approximately 1.18 times the PEL of 1.961 mg/m3.  This exposure was derived from one sample collected over a 477 minute sample period, a zero increment was added for the 3 minutes not sampled.    b) An employee working in the Robot Ground Coat booth, on 10/19/2015, monitoring the operation and cleaning the booth, was exposed to respirable dust containing 22 % Silica at an 8-hour time-weighted average level of 1.096 milligrams per cubic meter of air (mg/m3). This level is approximately 2.33 times the PEL of 0.471 mg/m3.  This exposure was derived from one sample collected over a 471 minute sample period, a zero increment was added for the 9 minutes not sampled.     Abatement methods usually applicable in these circumstances include, but are not limited to, the following:        1. Eliminate the use of compressed air for cleaning purposes or provide exhaust system to collect the dust as it is generated.    2. Monitor the ventilation systems installed in the booths and assure that the are correctly designed.    3. Review maintenance procedures for the booths and assure that they are working properly.        Abatement steps:       STEP 1:  Effective respiratory protection shall be provided and used by all exposed employees as an interim protection measure and when administrative or engineering controls fail to reduce exposures to below the PEL.  In addition, an effective respiratory protection program in accordance with 29 CFR 1910.134 shall be maintained.  Abatement must be completed by ***5 days***.        STEP 2:  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 levels below the PEL as referenced in this citation.  This plan shall include, at a minimum, target dates for the following actions which must be consistent with the dates required by this citation.       1)  Evaluation of engineering control options.       2)  Selection of optimum control method 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 evaluated for each particular use by a competent Industrial Hygienist or other technically qualified person.  Thirty (30) day progress reports are required during the abatement period.  Abatement must be completed by ***30 days***.       STEP 3:  Abatement should have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.  This verification should include air monitoring results showing levels below the permissible exposure limit. Abatement must be completed by ***60 DAYS***.