OSHA Inspection: BUCKHORN RUBBER PRODUCTS, INC.

Issued

Mar 16, 2016

Abate by

May 9, 2016

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:  a. The energy control procedure (VA13-001) was not utilized by all operators and/or helpers for cleaning hanger bolts.  (Note: Although the procedure provided some protection during cleaning by isolating two energy sources, it was deficient in that lockout was not performed.)  Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Mar 16, 2016

Abate by

May 9, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(d)(3): All energy isolating devices that were needed to control the energy to the machine or equipment were not physically located and operated in such a manner as to isolate the machine or equipment from the energy source(s):  a. During cleaning of hanger bolts on an injection molding machine, Desma 3, on 1-22-16, a wooden block used to isolate machine energy, was not placed in a manner (or was insufficient in number) to prevent closing of the mold on the operator's hand.  Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Mar 16, 2016

Abate by

May 9, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(d)(4)(i): Lockout or tagout devices were not affixed to each energy isolating device by authorized employees:  a. Injection molding machines were not locked out during cleaning of hanger bolts when machines were in hand/set-up mode, when operator's hands or other body parts were within the mold or in any other hazardous area of the machine.  (Note: other machine servicing or maintenance would require lockout according to OSHA standard 1910.l47.)  Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Mar 16, 2016

Abate by

May 9, 2016

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

29 CFR 1910.147(c)(7)(i)(A): Authorized employee(s) did not receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation:  a. Injection molding machine operators and helpers, who performed energy isolation (lockout work by definition) during cleaning of mold/die hanger bolts (lockout work by definition) when the machines were in hand/set-up mode, were not provided training for lockout authorized employees.  Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Mar 16, 2016

Abate by

May 9, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(7)(iii)(A): Retraining was not provided for authorized and affected employees when there was a change in their job assignments, a change in machines, equipment or processes that presented a new hazard, or when there was a change in the energy control procedures:  a. Injection molding machine operators, helpers, and group leaders who performed energy isolation during cleaning of mold/die hanger bolts and who had supervisory duties of operators who cleaned hanger bolts, were not provided re-training on energy isolation cleaning procedure, VA13-001, sometime after a cleaning injury on 2-6-13 and up to the time of a second cleaning injury on 1-22-16.  (Note: initial training on VA13-001 was provided for employees immediately after the 2-6-13 injury, but that training was not continued for new hires afterwards.  Although VA13-001 provided for energy isolation it did not provide for lockout.  See citation 1, item 1.)  Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Mar 16, 2016

Abate by

May 9, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(7)(i)(B): Affected employees were not instructed in the purpose and use of the energy control procedure:  a. Affected employees, such as, but not limited to, injection molding machine operators and helpers that do not perform lockout work, such as cleaning of hanger bolts and set-up, were not trained on the purpose and use of energy isolation and the control of hazardous energy.   (Note: affected employee training is more than instruction about the prohibition to start, restart, or operate machines which are locked out, which is training required for "all other employees" as stated at 1910.147(c)(7)(i)(C).)  Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Mar 16, 2016

Abate by

May 9, 2016

Penalty

Initial $5,000 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.147(f)(3)(ii)(D): Each authorized employee did not affix a personal lockout or tagout device to the group lockout device before working on the machine or equipment:    a.  During servicing/maintenance where one or more employees performed lockout work, the "community" combination lock, with the combination known by maintenance employees, was used without a personal lock being applied to the equipment.    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Mar 16, 2016

Abate by

May 9, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(6)(ii): The periodic inspection certification of energy control procedures did not contain the required documentation on identification of the machine or equipment, inspection date, employees included, and the person performing the inspection:  a. Documentation was not made for the lockout annual inspection since approximately April, 2014, which included the requirement for a review between the inspector and each authorized employee, whether maintenance or other lockout authorized employee.  (Note: the lockout annual inspection should include the identification of deficiencies existing in lockout performance, such as the OSHA and company violation for exclusively using the "community" lock during control of hazardous energy.  Certification of the lockout annual inspection also indicates that written procedures have been reviewed and updated or corrected as needed, that lockout equipment is available and used, and that lockout is being performed as required.)    Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).

Issued

Mar 16, 2016

Abate by

May 9, 2016

Penalty

Initial $15,000 · Current $7,000 Reduced

General-duty citation text

29 CFR 1910.22(a)(2): Floor(s) of workroom(s) were not maintained in a clean and, so far as possible, a dry condition:    a. On the working platforms of and around the injection molding machines, machines leaked hydraulic fluid and occasionally cooling water resulting in actual and potential slips and falls.  Although barriers had been placed around the machines, fluid also leaked onto work platforms.  In addition, the oil leaks around machines were not always cleaned adequately to prevent slips because of the frequency of machine leaks.    Buckhorn Rubber Products was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.22(a)(2) which was contained in OSHA inspection number #855444 , citation number 1, item number 1a and was affirmed as a final order on 3/5/2013, with respect to a workplace located at 5151 Industrial Dr., Hannibal, MO 63401.      Abatement certification and abatement documentation is required for this violation.  The documentation should include written verification of abatement, applicable measurements or monitoring results, and photographs or videos which you believe will be helpful.  The abatement certification sheet is enclosed with the citation(s).