OSHA Inspection: VIRTUAL POLYMER COMPOUNDS, LLC

Issued

May 17, 2016

Abate by

Jun 17, 2016

Penalty

Initial $3,500 · Current $1,033 Reduced

General-duty citation text

29 CFR 1910.106(d)(4)(i): Opening(s) from inside flammable and combustible storage room(s) into other rooms or buildings were not provided with noncombustible liquid tight raised seal or ramp at least 4 inches in height. Opening(s) from inside flammable and combustible storage room(s) were not provided with approved self-closing fire doors. The inside flammable and combustible storage room(s) were not liquid-tight where the walls joined the floor:    a) Flammable storage room - On or about 11/19/15, the flammable storage room where 55 gallon drums of resins having flash points ranging from 84 deg F to 89 deg F, and 5-gallon buckets of coatings with flash points ranging from 68.5 deg F to 82 deg F were stored was a room off of the manufacturing area having a floor the same height as the rest of the building.  It was not provided with an self-closing door, nor was the room liquid-tight where the walls joined the floor.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 1, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.106(d)(4)(iv): The ventilating equipment and any lighting fixtures were not operated by the same switch located outside of the door. A pilot light was not installed adjacent to the switch when Category 1 or 2 flammable liquids, or Category 3 flammable liquids with a flashpoint below 100 °F (37.8 °C), were dispensed within the room.     a) Flammable Storage Room - On or about 11/19/15, the mechanical ventilation and the lighting fixtures were operated from separate switches.     ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 1, 2016

Penalty

Initial $3,500 · Current $1,033 Reduced

General-duty citation text

29 CFR 1910.107(b)(3): The floor surface of a spray booth and operator's working area was not covered with noncombustible material:    a) Spray Booth Area - On or about 11/19/15, the floors and walls of the spray booth area were covered with cardboard, a combustible material.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 8, 2016

Penalty

Initial $2,800 · Current $823 Reduced

General-duty citation text

29 CFR 1910.107(b)(5)(iv): Space within the spray booth on the downstream and upstream sides of filters were not protected with approved automatic sprinklers:    a) Warehouse area - On or about 1/30/15, the space inside the spray booth was not equipped with approved automatic sprinklers.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 8, 2016

Penalty

Initial $2,800 · Current $823 Reduced

General-duty citation text

29 CFR 1910.107(b)(10): Transparent panels used for illumination of spray booth(s) did not effectively isolate the spraying area from the area in which the lighting unit(s) were located:    a) Spray Booth/Spray Area - On or about 11/19/15 and continuing, transparent panels were missing from the light fixtures in the spray booth exposing the lighting units to overspray and flammable vapors.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 17, 2016

Penalty

Initial $3,500 · Current $1,033 Reduced

General-duty citation text

29 CFR 1910.107(c)(5): Electrical Equipment not approved for locations containing both deposits of readily ignitable residues and explosive vapors was present in spraying area(s):    a) Spray Area - On or about 11/19/15, electrical outlets and associated wiring, portable lamps, and pedestal fans not approved for locations containing both deposits of readily ignitable residues, were all located in the spraying area and were coated with deposits of readily ignitable residues.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 1, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.107(c)(8): Portable lamp(s) were used in the spraying area(s) during spraying operations:    a) Spray Area - On or about 11/19/15, portable work lights were hung in the spray area and used during spraying operations.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 17, 2016

Penalty

Initial $3,500 · Current $1,033 Reduced

General-duty citation text

1910.107(d)(2): Spraying area(s) were not provided with mechanical ventilation adequate to remove flammable vapors, mists or powders to a safe location and to confine and control combustible residues:    a) Spray Area - On or about 11/19/15, the ventilation system for the spray area was not adequate to confine and control combustible residues.  Throughout the spray area the walls, floor, electrical conduit and outlets, portable fans, and any other stationary items were coated with deposits of combustible residues.  Employees spray resins having flash points ranging from 84 deg F to 89 deg F, and coatings with flash points ranging from 68.5 deg F to 82 deg F     ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 17, 2016

Penalty

Initial $2,800 · Current $0 Reduced

General-duty citation text

29 CFR 1910.107(d)(4): The fan-rotating element was not nonferrous or non-sparking or such material did not comprise or line the casing:    a) Spray Area - On or about 11/19/15, the fan-rotating element, one which was located inside the spray booth and one on the wall, was carbon steel.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 17, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.107(d)(5): Electric motor(s) driving exhaust fan(s) for spray booth(s) were located inside the booth(s):    a) Spray Area - On or about 11/19/15, the exhaust fan, and the electric motor driving it, were both located inside the spray booth where flammable materials are sprayed.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

May 25, 2016

Penalty

Initial $2,800 · Current $823 Reduced

General-duty citation text

29 CFR 1910.107(e)(2): The quantity of flammable or combustible liquids kept in the vicinity of spraying operation(s) exceeded the minimum required for operation:    a)  Spray Area - On or about 11/19/15, there was approximately 215 gallons of flammable liquids stored in the spray area.  This amount exceeded the minimum required for the operation.    THE MINIMUM REQUIRED SHOULD ORDINARILY NOT EXCEED A SUPPLY FOR ONE DAY OR ONE SHIFT.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

May 25, 2016

Penalty

Initial $3,500 · Current $1,033 Reduced

General-duty citation text

1910.107(g)(2): All spraying areas were not kept as free from the accumulation of deposits of combustible residues as practical, with cleaning conducted daily if necessary:    a) Spray Area - On or about 11/19/15, throughout the spray area the walls, floor, electrical conduit and outlets, portable fans, and any other stationary items were coated with deposits of combustible residues (fiberglass mixed with flammable resins and having flash points ranging from 68.5 deg F to 89 deg F).  Cleaning was not conducted as necessary in order to keep the area free of the accumulation of deposits of combustible residue.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 1, 2016

Penalty

Initial $3,500 · Current $1,033 Reduced

General-duty citation text

29 CFR 1910.107(g)(3):  Approved metal waste cans were not provided wherever rags or waste were impregnated with finishing material; and all such rags or waste were not deposited therein immediately after use.     a) Spray Room - On or about 1/22/16, rags, mixing cups, and other waste which was impregnated with flammable resins and coatings (with flash points ranging from 68.5 deg F to 89 deg F) was thrown in the regular trash.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Penalty

Initial $3,500 · Current $1,033 Reduced

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 implemented for required respirator use:    a) Throughout facility - On or about 11/19/15, the employer had not implemented the written respiratory protection program in the workplace for employees who are required to wear full-face air-purifying respirators while performing chop spraying and spray painting.    NO ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Penalty

Initial $3,500 · Current $1,033 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:    a) Throughout Facility - On or about 11/19/15, the employer did not provide a medical evaluation to employees who are required to wear full-face air-purifying respirators while performing chop spraying and spray painting.    NO ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Penalty

Initial $3,500 · Current $1,033 Reduced

General-duty citation text

29 CFR 1910.134(f)(2): Employee(s) using tight-fitting facepiece respirators were not fit tested prior to initial use of the respirator and at least annually thereafter:    a) Throughout Facility - On or about 11/19/15, employee who were required to wear full-face air-purifying respirators while performing chop spraying and spray painting were no fit-tested prior to initial use of the respirator and annually thereafter.    NO ABATEMENT CERTIFICATIN REQUIRED

Issued

May 17, 2016

Penalty

Initial $3,500 · Current $1,033 Reduced

General-duty citation text

29 CFR 1910.134(k)(1): The employer did not provide effective training to employees who were required to use respirators and ensure that they could demonstrate knowledge of the requirements contained in 29m CFR 1910.134(k)(1)(I) through (vii):    a) Throughout Facility - On or about 11/19/15, the employer did not provide training to employees who are required to wear full-face air-purifying respirators while performing chop spraying and paint spraying.  The employees could not demonstrate knowledge of at least the following:    1)     Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect          of the respirator;  2)    What the limitations and capabilities of the respirator are;  3)    How to inspect, put on and remove, use, and check the seals of the respirator;  4)    What the procedures are for maintenance and storage of the respirator;  5)     How to recognize medical signs and symptoms that may limit or prevent the effective use of the respirator;  6)     AND the general requirements of this section.    NO ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 17, 2016

Penalty

Initial $3,500 · Current $1,033 Reduced

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 paragraphs (f), (g), and (h) will be met:    a) Throughout Facility - On or about 11/19/15, the employer had a written hazard communication program, but did not implement it in the workplace for employees who work daily with materials such as, but not limited to, Ashland Aropol 7241 T-15 Resin, FRP A 101 T-15, and Maxguard Virtual Yellow Gelcoat  (all containing styrene), Polycor ANSI 61 Gray (containing methyl methacrylate and styrene), and Lupreox DDM-9 (containing methyle ethyl ketone peroxides, hexylene glycol, and MEK).  The program was not implemented in that employee information and training was not conducted.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

Jun 17, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

Employees were not provided effective information and training as specified in 29 CFR 1910.1200(h)(1) and (2) on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard was introduced into their work area:    a) Throughout Facility - On or about 11/19/15, employees working with materials such as, but not limited to, Ashland Aropol 7241 T-15 Resin, FRP A 101 T-15, and Maxguard Virtual Yellow Gelcoat  (all containing styrene), Polycor ANSI 61 Gray (containing methyl methacrylate and styrene), and Lupreox DDM-9 (containing methyl ethyl ketone peroxides, hexylene glycol, and MEK) were not provided with information and training on the hazardous materials that they work with.    Employees shall be informed of:    1)    The requirements of this section;  2)    Any operations where hazardous chemicals are present; AND  3)    The location and availability of the written Hazard Communication Program, list(s) of hazardous chemicals, and          Material Safety data Sheets.    Employee training shall include at least:    1)    Methods and observations that may be used to detect the presence or release of a hazardous chemical in the           work area.  2)    The physical and health hazards of the chemicals in the work area.  3)    The measures employees can take to protect themselves such as specific procedures, appropriate work practices,          emergency procedures and personal protective equipment to be used.  4)    The details of the employers Hazard Communication Program including an explanation of labeling systems, MSDSs,          and how employees can obtain and use the appropriate hazard information.    ABATEMENT CERTIFICATION REQUIRED

Issued

May 17, 2016

Abate by

May 25, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.107(g)(7): "NO SMOKING" sign(s) in large letters on contrasting color backgrounds were not conspicuously posted at spraying area(s) and paint storage room(s):  a) Spray Area - On or about 11/19/15, "NO SMOKING" signs were not posted in spray painting area or in paint storage areas.  ABATEMENT CERTIFICATION REQUIRED