OSHA Inspection: BRIDESBURG FOUNDRY COMPANY

Issued

Mar 10, 2017

Abate by

Oct 1, 2018

Penalty

Initial $5,387 · Current $3,368 Reduced

Hazardous substances 1591

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:    a) Furnace Department: An employee, Melter, melting different metals and taking temperatures was exposed to an 8 hour time-weighted average (TWA) of 56 micrograms per cubic meter of air (ug/m3) of lead, which is 1.1 times the permissible exposure limit of 50 ug/m3. This exposure occurred over a 430 minute sampling period on December 14, 2016. A zero exposure is assumed for the time not sampled.      b) Furnance Department: An employee, Ladle Leader, assisting in the pouring operations was exposed to an 8 hour TWA of 86 ug/m3 of lead, which is 1.7 times the permissible exposure limit of 50 ug/m3. This exposure occurred over a 419 minute sampling period on January 17, 2017. A zero exposure is assumed for the time not sampled.    Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photograph or video evidence of abatement or other written records.

Issued

Mar 10, 2017

Abate by

Oct 1, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

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 where engineering and work practice controls (including administrative controls) were feasible but did not reduce the employees' exposure to or below the permissible exposure limit, the employer did not use engineering and/or work practice controls to reduce esposures to the lowest feasible level:    a) Furnace Department: Employees, Melter and Ladle Leader, were exposed to lead at levels greater than the permissible exposure limit (PEL) of 50 ug/m3 and engineering and work practices were not implemented to reduce and maintain the employees exposure below the PEL, on or about January 17, 2017. (See Citation 1.2a for full description)      Feasible abatement methods include but are not limited to:  1. Evaluate the effectiveness of ventilation hoods during the pouring process and install hoods that effectively capture fumes.  2. Determine the effectiveness of metal lids for the pots or insulated blankets to cover the pots while ventilation is not available and install where appropriate.  3. Install effective ventilation for the No Bake pouring process.  4. Evaluate work practices to ensure ventilation is used appropriately during the melting and pouring processes.  5. Evaluate employee exposures to determine work practices and administrative controls employees use to keep their exposures below the permissible exposure limits.    ABATEMENT STEPS ARE AS FOLLOW:      STEP 1  As an interim measure, effective respiratory protection shall be provided to and used by exposed employees until feasible and/or administrative controls can be implemented or whenever such controls fail to reduce employee exposure to within permissible exposure limits.    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 hazardous substances 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.      Note: All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person. Ninety- (90) day progress reports are required during the abatement period.  (The 90 day requirement can be shortened or lengthened by the area director depending on the specific circumstances.)      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.

Issued

Mar 10, 2017

Abate by

Apr 14, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(e)(3)(ii): Written compliance programs for lead did not include the required sections:  a) Furnace Department: Employees, Melter and Ladle Leader, were exposed to lead at levels greater than the permissible exposure limit (PEL) of 50 ug/m3 and the Lead Compliance Program did not include information such as a description of each operation in which lead was admitted, a description of the specific means that would be used to achieve compliance, and a description of work practices including housekeeping and hygiene facilities and practices, on or about January 17, 2017. (See Citation 1.2a for full description)  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 10, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(f)(1): The employer did not ensure that employee(s) required to use a tight-fitting facepiece respirator passed the appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT):  a) Furnace Department: An employee required to wear a Moldex N100 respirator while assisting during the pouring operations was not provided a fit test prior to being required to wear a respirator, on or about January 17, 2017.  No abatement certification or documentation required.

Issued

Mar 10, 2017

Abate by

Apr 14, 2017

Penalty

Initial $5,387 · Current $3,368 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(g)(2)(v): Contaminated protective clothing to be cleaned, laundered, or disposed of, was not placed in a closed container in the change room to prevent dispersion of lead:    a) Loading Dock: The closed container for lead contaminated protective clothing was located on the loading dock allowing the dispersion of lead dust to be spread in the hallway and maintenance shop as employees walked from the locker room to the loading dock, on or about December 15, 2016.    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 10, 2017

Abate by

Mar 30, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(h)(1): All surfaces were not maintained as free as practicable of accumulations of lead:   a) Plant: The water nozzle of the water fountain used by multiple employees throughout a shift contained approximately 20 mg of lead and the facility did not have an adequate housekeeping schedule to ensure that all surfaces were maintained free of accumulations of lead as practicable, on or about December 20, 2016.    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 10, 2017

Abate by

Jun 1, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(i)(4)(iv): Employees entering lunchroom facilities with protective work clothing or equipment were not required to remove surface lead dust by vacuuming, downdraft booth, or other cleaning method(s):     a) Lunch Room: Employees over exposed to lead wore green fire retardant protective clothing during the pouring operations and entered the lunchroom facility with their protective clothing, on or about January 17, 2017.       Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 10, 2017

Abate by

Jun 1, 2017

Penalty

Initial $5,387 · Current $3,368 Reduced

Hazardous substances C141

General-duty citation text

29 CFR 1910.1027(d)(1)(i): The employer did not determine whether any employee was exposed to cadmium at or above the action level:    a) Furnace Department: An employee, Ladle Leader, assisting during the pouring operations was exposed to cadmium at an 8 hour time weighted average (TWA) concentration of 10.21 micrograms per cubic meter of air (ug/m3), which is 2.04 times the PEL of 5.0 ug/m3, and the employer did not implement a monitoring program to determine whether employees were exposed to cadmium above the action level, on or about January 17, 2017. (See Citation 1.4a for full description)    b) Furnace Department: An employee, Pourer, conducting pouring operations was exposed to cadmium at an 8 hour TWA concentration of 4.1 ug/m3, which is 1.6 times the action level of 2.5 ug/m3. This exposure occurred over a 408 minute sampling period on or about January 17, 2017.  A zero exposure was assumed for the time not sampled. The employer did not implement a monitoring program to determine whether employees were exposed to cadmium above the action level, on or about January 17, 2017.    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 10, 2017

Abate by

Apr 2, 2018

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR 1910.1027(c): The employer did not ensure that no employee was exposed to an airborne concentration of cadmium in excess of five micrograms per cubic meter of air (5ug/m3), calculated as an eight-hour time-weighted average (TWA):    a) Furnace Department: An employee, Ladle Leader, assisting in the pouring operations was exposed to cadmium at an 8 hour TWA concentration of 10.21 ug/m3, which is 2.04 times the permissible exposure limit (PEL) of 5.0 ug/m3. This exposure occurred over a 419 minute sampling period on or about January 17, 2017.  A zero exposure was assumed for the time not sampled.    Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement. Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photograph or video evidence of abatement or other written records.

Issued

Mar 10, 2017

Abate by

Jun 1, 2017

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR 1910.1027(e)(1): The employer did not establish a regulated area wherever an employee's exposure to airborne concentrations of cadmium was, or could reasonably have been expected to be, in excess of the permissible exposure limit (PEL):    a) Furnace Department: An employee, Ladle Leader, assisting during the pouring operations was exposed to cadmium at an 8 hour time weighted average (TWA) concentration of 10.21 micrograms per cubic meter of air (ug/m3), which is 2.04 times the PEL of 5.0 ug/m3, and the employer did not determine and establish a regulated area where employees would be exposed to cadmium in excess of the PEL, on or about January 17, 2017. (See Citation 1.4a for further detail)    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 10, 2017

Abate by

Apr 2, 2018

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR 1910.1027(f)(1)(i): The employer did not implement engineering and work practice controls to reduce and maintain employee exposure to cadmium at or below the permissible exposure limit (PEL):    a) Furnace Department: An employee, Ladle Leader, assisting during the pouring operations was exposed to cadmium at an 8 hour time weighted average (TWA) concentration of 10.21 micrograms per cubic meter of air (ug/m3), which is 2.04 times the PEL of 5.0 ug/m3, and the employer did not implement feasible engineering or administrative controls on or about January 17, 2017. (See Citation 1.4a for further detail)      Feasible abatement methods include but are not limited to:    1. Evaluate the effectiveness of ventilation hoods during the pouring process and install hoods that effectively capture fumes.  2. Determine the effectiveness of metal lids for the pots or insulated blankets to cover the pots while ventilation is not available and install where appropriate.  3. Install effective ventilation for the No Bake pouring process.  4. Evaluate work practices to ensure ventilation is used appropriately during the melting and pouring processes.  5. Evaluate employee exposures to determine work practices and administrative controls employees use to keep their exposures below the permissible exposure limits.    ABATEMENT STEPS ARE AS FOLLOW:  STEP 1 - As an interim measure, effective respiratory protection shall be provided to and used by exposed employees until feasible and/or administrative controls can be implemented or whenever such controls fail to reduce employee exposure to within permissible exposure limits.    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 hazardous substances 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.    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.

Issued

Mar 10, 2017

Abate by

Jun 1, 2017

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR 1910.1027(f)(2)(i): When the permissible exposure limit (PEL) was exceeded, the employer did not establish and implement a written compliance program to reduce employee exposure to cadmium to or below the PEL by means of engineering and work practice controls:    a) Furnace Department: An employee, Ladle Leader, assisting during the pouring operations was exposed to cadmium at an 8 hour time weighted average (TWA) concentration of 10.21 micrograms per cubic meter of air (ug/m3), which is 2.04 times the PEL of 5.0 ug/m3, and the employer did not establish or implement a written compliance program, on or about January 17, 2017. (See Citation 1.4a for further detail)      Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 10, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 0491C141C142

General-duty citation text

29 CFR 1910.134(f)(1): The employer did not ensure that employee(s) required to use a tight-fitting facepiece respirator passed the appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT):  a) a) Furnace Department: An employee, Ladle Leader, assisting in the pouring operations was exposed to cadmium at an 8 hour TWA concentration of 10.21 ug/m3, which is 2.04 times the permissible exposure limit (PEL) of 5.0 ug/m3. This exposure occurred over a 419 minute sampling period on or about January 17, 2017.  A zero exposure was assumed for the time not sampled.  Employee was required to wear a Moldex N100 respirator while assisting during the pouring operations and was not provided a fit test prior to being required to wear a respirator, on or about January 17, 2017.  No abatement certification or documentation required.

Issued

Mar 10, 2017

Abate by

Jun 1, 2017

Penalty

Initial $5,387 · Current $3,368 Reduced

Hazardous substances C141

General-duty citation text

29 CFR 1910.1027(l)(1)(i)(A): The employer did not institute a medical surveillance program for all employees who were or potentially were exposed to cadmium at or above the action level on 30 or more days per year (twelve consecutive months):    a) Furnace Department: An employee, Ladle Leader, assisting during the pouring operations was exposed to cadmium at an 8 hour time weighted average (TWA) concentration of 10.21 micrograms per cubic meter of air (ug/m3), which is 2.04 times the permissible exposure limit (PEL) of 5.0 ug/m3, and the employer did not institute a medical surveillance program, on or about January 17, 2017. (See Citation 1.4a for further detail)    b) Furnace Department: An employee, Pourer, conducting pouring operations was exposed to cadmium at an 8 hour TWA concentration of 4.1 ug/m3, which is 1.6 times the PEL of 2.5 ug/m3, and the employer did not institute a medical surveillance program, on or about January 17, 2017.(See Citation 1.5a for further detail)    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 10, 2017

Abate by

Apr 28, 2017

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR 1910.1027(m)(4)(i): The employer did not institute a training program for all employees who were potentially exposed to cadmium, ensure employee participation in the program, and maintain a record of the contents of such program:    a) Furnace Department  Employees, Melter, Pourer, and Ladle Leader, were exposed to levels of cadmium ranging from 2.0 micrograms per cubic meter of air (ug/m3) to 10.21 ug/m3 and the employer did not establish a training program informing the employees of the required information in the standard, on or about January 17, 2017.      b) Molding Department  Employees, Dumpers, placing weights on the molds after molten metal is poured and dumping hot pieces were exposed to levels of cadmium at 1.7 ug/m3 and 1.98 ug/m3 and the employer did not establish a training program informing the employees of the required information in the standard, on or about January 17, 2017.    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 10, 2017

Abate by

Mar 30, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025 (g) (2) (vii) (A): Containers of contaminated protective clothing and equipment required by paragraph (g)(2)(v) were not labeled as follows: DANGER: CLOTHING AND EQUIPMENT CONTAMINATED WITH LEAD. MAY DAMAGE FERTILITY OR THE UNBORN CHILD. CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM. DO NOT EAT, DRINK OR SMOKE WHEN HANDLING. DO NOT REMOVE DUST BY BLOWING OR SHAKING. DISPOSE OF LEAD CONTAMINATED WASH WATER IN ACCORDANCE WITH APPLICABLE LOCAL, STATE, OR FEDERAL REGULATIONS:  a) Loading Dock: The container to place lead contaminated protective clothing did not contain the appropriate label per the standard, on or about December 15, 2016.  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 10, 2017

Abate by

Mar 30, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1025(m)(2)(i): The employer did not 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) Furnace Department: The sign marking the regulated area did not contain the required information for the standard, on or about December 15, 2016.   Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 10, 2017

Abate by

Apr 5, 2017

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR 1910.1027(m)(3)(ii): Containers of contaminated protective clothing, equipment, waste, scrap, or debris shall include the following warning label: DANGER, CONTAINS CADMIUM, MAY CAUSE CANCER, CAUSES DAMAGE TO LUNGS AND KIDNEYS, AVOID CREATING DUST:  a) Furnace Department: An employee, Ladle Leader, assisting during the pouring operations was exposed to cadmium at an 8 hour time weighted average (TWA) concentration of 10.21 micrograms per cubic meter of air (ug/m3), which is 2.04 times the permissible exposure limit (PEL) of 5.0 ug/m3, and the employer did not appropriately label the contaminated protective clothing container, on or about January 17, 2017. (See Citation 1.4a for further detail)  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.