OSHA Inspection: AIMHI SHOOTING RANGE

Issued

Jul 12, 2016

Abate by

Aug 14, 2016

Penalty

Initial $400 · Current $400

General-duty citation text

29 CFR 1903.19(c)(1): Within ten calendar days after the abatement date, the employer must certify to OSHA (the Agency) that each cited violation has been abated, except as provided in paragraph (c)(2) of this section.  a. In regards to citation 1, item 2a, issued on February 25, 2016, the employer has failed to submit abatement certification within ten days of the abatement date, May 30,, 2016.  The violation read as follows:    29 CFR 1910.1025(c)(1): 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:  a.  At the work site, on December 7, 2015, an employee cleaning out shooting range traps was exposed to airborne lead at an 8-hour time-weighted average (TWA) of 0.089 mg/m3, approximately 1.8 times the permissible exposure limit (PEL) for lead of 0.05 mg/m3.  The exposure was derived from samples collected over a 51 minute period.  Zero exposure was assumed for the unsampled period of 429 minutes.  b.  At the work site, on December 7, 2015, an employee cleaning out shooting range traps was exposed to airborne lead at an 8-hour time-weighted average (TWA) of 0.059 mg/m3, approximately 1.2 times the permissible exposure limit (PEL) for lead of 0.05 mg/m3.  The exposure was derived from samples collected over a 72 minute period.  Zero exposure was assumed for the unsampled period of 408 minutes.  b.  In regards to citation 1, item 2b, issued on February 25, 2016, the employer has failed to submit abatement certification within ten days of the abatement date, May 30,, 2016.  The violation read as follows:     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, on December 7, 2015, an employee cleaning out shooting range traps was exposed to airborne lead at an 8-hour time-weighted average (TWA) of 0.089 mg/m3, approximately 1.8 times the permissible exposure limit (PEL) for lead of 0.05 mg/m3.  The exposure was derived from samples collected over a 51 minute period.  Zero exposure was assumed for the unsampled period of 429 minutes. No engineering or work practice controls were implemented in the workplace to reduce employee exposures to airborne lead.      b.  At the work site, on December 7, 2015, an employee cleaning out shooting range traps was exposed to airborne lead at an 8-hour time-weighted average (TWA) of 0.059 mg/m3, approximately 1.2 times the permissible exposure limit (PEL) for lead of 0.05 mg/m3.  The exposure was derived from samples collected over a 72 minute period.  Zero exposure was assumed for the unsampled period of 408 minutes. No engineering or work practice controls were implemented in the workplace to reduce employee exposures to airborne lead.     ABATEMENT:         Step 1:    Date By Which Violation Must be Abated:   03/30/2016  Effective respiratory protection shall be provided and used by exposed employees as an interim protective measure until feasible engineering and/or administrative controls can be implemented or whenever such controls fail to reduce employee exposure to within permissible exposure limits. Effective respiratory protection involves a written respiratory protection program, medical evaluation, fit testing, and training.          Step 2:    Date By Which Violation Must be Abated:   04/30/2016  Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of engineering and/or administrative controls to control employee exposure to hazardous substances as referenced in this citation. This plan shall include, at the minimum, target dates for the following actions which must be consistent with the abatement dates required by this citation.      1. Evaluation of engineering/administrative control options;     2. Selection of optimum control methods 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 approved for each particular use by a competent industrial hygienist or other technically qualified person. Sixty (60) day progress reports are required during the abatement period.          Step 3:    Date By Which Violation Must be Abated:   05/30/2016  Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.      Feasible engineering and/or administrative control could include, but the employer is not bound by or limited to the following:     1. Equip area with local exhaust ventilation.       2. Use wet methods during cleaning process.      3. Use electric sweepers in place of hand shoveling during cleaning process.      4. Any combination of the above.

Issued

Feb 25, 2016

Abate by

Mar 31, 2016

Penalty

Initial $1,700 · Current $1,700

Hazardous substances 1591

General-duty citation text

29 CFR 1910.134(f)(2): The employer shall ensure that an employee using a tight-fitting facepiece respirator is fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.  a. At the workplace, the employer did not provide an adequate fit test for employees required to wear N95 respirators during shooting range cleaning.

Issued

Feb 25, 2016

Abate by

Mar 31, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 1591

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 workplace, the employer did not provide a medical evaluation to employees who are required to wear N95 respirators during shooting range cleaning.

Issued

Feb 25, 2016

Abate by

May 30, 2016

Penalty

Initial $1,700 · Current $1,700

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(c)(1): 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:  a.  At the work site, on December 7, 2015, an employee cleaning out shooting range traps was exposed to airborne lead at an 8-hour time-weighted average (TWA) of 0.089 mg/m3, approximately 1.8 times the permissible exposure limit (PEL) for lead of 0.05 mg/m3.  The exposure was derived from samples collected over a 51 minute period.  Zero exposure was assumed for the unsampled period of 429 minutes.  b.  At the work site, on December 7, 2015, an employee cleaning out shooting range traps was exposed to airborne lead at an 8-hour time-weighted average (TWA) of 0.059 mg/m3, approximately 1.2 times the permissible exposure limit (PEL) for lead of 0.05 mg/m3.  The exposure was derived from samples collected over a 72 minute period.  Zero exposure was assumed for the unsampled period of 408 minutes.

Issued

Feb 25, 2016

Abate by

May 30, 2016

Penalty

Initial $0 · Current $0

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, on December 7, 2015, an employee cleaning out shooting range traps was exposed to airborne lead at an 8-hour time-weighted average (TWA) of 0.089 mg/m3, approximately 1.8 times the permissible exposure limit (PEL) for lead of 0.05 mg/m3.  The exposure was derived from samples collected over a 51 minute period.  Zero exposure was assumed for the unsampled period of 429 minutes. No engineering or work practice controls were implemented in the workplace to reduce employee exposures to airborne lead.   b.  At the work site, on December 7, 2015, an employee cleaning out shooting range traps was exposed to airborne lead at an 8-hour time-weighted average (TWA) of 0.059 mg/m3, approximately 1.2 times the permissible exposure limit (PEL) for lead of 0.05 mg/m3.  The exposure was derived from samples collected over a 72 minute period.  Zero exposure was assumed for the unsampled period of 408 minutes. No engineering or work practice controls were implemented in the workplace to reduce employee exposures to airborne lead.

Issued

Feb 25, 2016

Penalty

Initial $1,020 · Current $1,020

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 workplace, the employer did not conduct an initial determination of lead exposure for employees cleaning the shooting ranges.

Issued

Feb 25, 2016

Abate by

Mar 15, 2016

Penalty

Initial $1,020 · Current $1,020

Hazardous substances 1591

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. In the training room/employee break area, the coffee pot table and training tables were not maintained free of lead accumulations.

Issued

Feb 25, 2016

Abate by

Mar 31, 2016

Penalty

Initial $1,020 · Current $1,020

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)(A): At least every 6 months to each employee covered under paragraph (j)(1)(i) of this section;  a. At the workplace, employees exposed to lead above the permissible exposure limit were not provided with biological monitoring at least every 6 months.

Issued

Feb 25, 2016

Abate by

Mar 31, 2016

Penalty

Initial $1,020 · Current $1,020

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(l)(1)(v): The employer shall assure that each employee is informed of the following:  29 CFR 1910.1025(l)(1)(v)(D): The purpose and a description of the medical surveillance program, and the medical removal protection program including information concerning the adverse health effects associated with excessive exposure to lead (with particular attention to the adverse reproductive effects on both males and females);  a. At the workplace, the employer did not include information concerning adverse health effects related to lead exposure in the employee training program.

Issued

Feb 25, 2016

Abate by

Mar 31, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(m)(2)(i): The employer shall post the following warning signs in each work area where the PEL is exceeded:    DANGER  LEAD  MAY DAMAGE FERTILITY OR THE UNBORN CHILD  CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM  DO NOT EAT, DRINK OR SMOKE IN THIS AREA  a. At the workplace, the employer did not post warning signs in areas where employees were exposed to lead above the permissible exposure limit.