OSHA Inspection: PRO ARMAMENT COMPANY LLC.

Issued

May 23, 2016

Abate by

May 27, 2016

Penalty

Initial $2,800 · Current $800 Reduced

General-duty citation text

29 CFR 1910.134(g)(1)(i)(A): Respirators with tight-fitting facepieces were worn by employees who had facial hair that came between the sealing surface of the facepiece and the face or that interfered with valve function:     On or about November 25, 2015, employees who were required to wear half-face tight fitting respirators 3 M Model 5301 while cleaning the shooting range (i.e. sweeping brass, lead dust and paper targets), had facial hair that interfered with the seal between the facepiece and the face.

Issued

May 23, 2016

Abate by

Jun 10, 2016

Penalty

Initial $2,800 · Current $800 Reduced

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.1025(c)(1): Employee(s) were exposed to lead at concentrations greater than fifty micrograms per cubic meter of air averaged over an eight-hour period:    On February 23, 2016, an employee cleaning the gun range was exposed to lead at an 8-hour time-weighted average (TWA) of 0.119 mg/m3, which is approximately 2.38 times the permissible exposure limit (PEL) of 0.05 mg/m3, for 109 minutes. The exposure level is derived from 2 samples collected  for over a 109 minutes period of time, and zero exposure is assumed for the time not sampled.

Issued

May 23, 2016

Abate by

Jul 25, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(e)(1)(i): For any employees exposed to lead above the permissible exposure limit for more than 30 days per year the employer did not implement engineering and work practice controls (including administrative controls) were not implemented to reduce and maintain employee exposure to lead:  On February 23, 2016, an employee cleaning the gun range was exposed to lead at an eight-hour time-weighted average (TWA) of 0.119 mg/m3, which is approximately 2.38 times the permissible exposure limit (PEL) of 0.05 mg/m3. This limit was established to prevent adverse health effects. The exposure level is derived from 2 samples collected over a 109 minute period of time, and assuming zero exposure for the time not sampled.  General methods of control applicable in this circumstance include, but are not limited to the following:  1) Re-evaluate, maintain, upgrade or otherwise install ventilation system(s) to improve air movement/ensure capture lead dust generated while cleaning the range;    2) Clean the gun range and adjacent areas using proper cleaning procedures including, but not limited to, HEPA vacuuming (or other portable dust collection system with local exhaust ventilation) and wet sweeping;     3) Re-evaluate the existing work practices during the cleaning of the range and eliminate dry-sweeping. Use an engineered brass ammunition broom(s) or similar devices to retrieve spent ammunition shells and cartridges; to reduce the worker exposures to the airborne lead dust;  4) Implement adequate decontamination procedures of PPE and Equipment;     5) Provide range employees responsible engaged in housekeeping and range cleaning with showers to wash; lockers to keep separate street and work clothing (which must be cleaned and/or replaced regularly);    6) Designate clean rooms (lunchrooms) to avoid take-home and hand-to-mouth contamination;  7) Limit the length of time employees spend in the range for cleaning activities by rotating assignments and/or changing schedules.  ABATEMENT NOTE:      STEP 1: An effective respiratory protection program shall be implemented and used by the affected employee(s) as an interim measure of protection.     Abatement Date: 5 calendar days from the issuance date    STEP 2: A written detailed plan of abatement shall be submitted to the Area Director outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposures to lead 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 / administrative controls;  (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 evaluated for each particular use by a competent industrial hygienist or other technically qualified person(s). 15-day progress reports to OSHA are required during the abatement period.     Abatement Date: 30 calendar days from the issuance date     STEP 3: Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.     Abatement Date: 60 calendar days from the issuance date

Issued

May 23, 2016

Abate by

May 27, 2016

Penalty

Initial $2,800 · Current $800 Reduced

General-duty citation text

29 CFR 1910.1025(d)(8)(i): Within fifteen working days after the receipt of exposure monitoring results, each employee was not notified in writing or by posting the results in an appropriate location of the results which represented that employee's exposure to lead:    On or about November 25, 2015, the employer did not provide the air sampling results from the previous inspection (990237) that was sent to the employer on October 14, 2014 for employees found to be exposed to lead.

Issued

May 23, 2016

Abate by

Jun 10, 2016

Penalty

Initial $2,800 · Current $800 Reduced

General-duty citation text

29 CFR 1910.1025(h)(2)(ii): Shoveling, sweeping or brushing methods were used to remove lead accumulations where vacuuming or other equally effective methods were available and feasible:    On or about November 25, 2015, the employer did not ensure that staff employee(s) did not clean the gun range of spent ammunition shells, casings and paper targets using dry-sweeping methods. Employee(s) dry-swept lead contaminated gun range of brass, casings and paper targets using brooms or squeegees.

Issued

May 23, 2016

Abate by

Jun 10, 2016

Penalty

Initial $2,800 · Current $800 Reduced

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.1025(i)(2)(i): Clean change rooms were not provided for employees exposed to lead in excess of the permissible exposure limit (PEL), without regard to the use of respirators:    On February 23, 2016, an employee cleaning the gun range was exposed to lead at at an 8-hour time-weighted average (TWA) of 0.119 mg/m3, which is approximately 2.38 times the permissible exposure limit (PEL) of 0.05 mg/m3, for 109 minutes. The exposure level is derived from 2 samples collected  for over a 109 minutes period of time, and zero exposure is assumed for the time not sampled. The employer did not provide a clean change room.

Issued

May 23, 2016

Abate by

Jun 10, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.1025(i)(3)(i): Employee(s) exposed to lead in excess of the permissible exposure limit (PEL), without regard to the use of respirators, were not required to shower at the end of the work shift:  On February 23, 2016, an employee cleaning the gun range was exposed to lead at at an 8-hour time-weighted average (TWA) of 0.119 mg/m3, which is approximately 2.38 times the permissible exposure limit (PEL) of 0.05 mg/m3, for 109 minutes. The exposure level is derived from 2 samples collected  for over a 109 minutes period of time,  and zero exposure is assumed for the time not sampled. The employee did not shower at the end of the work shift before leaving the site.

Issued

May 23, 2016

Abate by

Jun 10, 2016

Penalty

Initial $2,800 · Current $800 Reduced

Hazardous substances 15911592

General-duty citation text

29 CFR 1910.1025(j)(1)(i): A medical surveillance program was not instituted for all employee(s) who were, or could be exposed to lead above the action level for more that thirty days per year:    On or about November 25, 2015, the employer did not institute a medical surveillance program for employees who were exposed to lead above the action level when cleaning the front of the range and trap.

Issued

May 23, 2016

Penalty

Initial $5,600 · Current $1,600 Reduced

General-duty citation text

29 CFR 1910.1025(d)(2): An initial determination was not made to determine if any employee may be exposed to lead at or above the action level:    On or about November 25, 2015, the employer did not do an initial determination to determine if gun range employees were exposed at or above the action level for lead when performing tasks including but not limited cleaning up the trap, range, when instructing a concealed weapons course, or providing assistance to customers using the range.    Pro Armament Company LL., was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.1025(d)(2), which was contained in OSHA inspection number 990237, citation number 1, item number 2(a) and was affirmed as a final order on November 4, 2014, with respect to a workplace located at 2427 Front St. Cuyahoga Falls, Ohio 44221.

Issued

May 23, 2016

Penalty

Initial $4,000 · Current $1,130 Reduced

General-duty citation text

29 CFR 1910.1025(h)(1): All surfaces were not maintained as free as practicable of accumulations of lead:    On or about Novemeber 25, 2015, wipe samples collected from area including but not limited to were taken from surfaces in the gun range and cash register area. Analytical results indicated the presence of lead, as follows:      Cash Register: 180.7 ug/ft2    Surfaces were not maintained as free as practicable from accumulations of lead.    Pro Armament Company LLC., was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.1025(h)(1), which was contained in OSHA inspection number 990237, citation number 1, item number 2(b) and was affirmed as a final order on November 4, 2014, with respect to a workplace located at 2427 Front St. Cuyahoga Falls, Ohio 44221.