OSHA Inspection: CASTWELL PRODUCTS, LLC

Issued

Jul 22, 2016

Abate by

Sep 8, 2016

Penalty

Initial $13,860 · Current $5,000 Reduced

Hazardous substances 9010

General-duty citation text

29 CFR 1910.134(k)(1)(i): The employer did not ensure that each employee could demonstrate knowledge of why the respirator was necessary and how improper fit, usage, or maintenance could compromise the protective effect of the respirator:     a) Castwell Products, LLC, Skokie, IL- On March 2, 2016, an employee on the Central/105 (Hunter) shakeout line, where the use of respiratory protection is required and exposures to respirable crystalline quartz silica, a carcinogen, were documented to be several times over the OSHA established Permissible Exposure Limit, was observed improperly wearing his disposable particulate respirator.      b) Castwell Products, LLC, Skokie, IL- On March 2, 2016, employees working on the DISA shakeout line, where the use of respiratory protection is required and exposures to respirable crystalline quartz silica, a carcinogen, were documented to be several times over the OSHA established Permissible Exposure Limit, were observed improperly wearing their disposable particulate respirators.      Castwell Products, LLC was previously cited for a violation of this Occupational Safety and Health Standard, 29 CFR 1910.134(k)(1)(i), which was contained in OSHA inspection Number 961300, citation number 1, item number 1a, and was affirmed as a final order on July 1, 2014, with respect to a workplace located at 7800 N. Austin Avenue in Skokie, Illinois.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Jul 22, 2016

Abate by

Sep 8, 2016

Penalty

Initial $0 · Current $0

Hazardous substances 9010

General-duty citation text

29 CFR 1910.134(k)(5)(ii): Retraining was not conducted when inadequacies in the employees' knowledge or use of the respirator indicated that the employee did not retain the necessary training or skill:     a) Castwell Products, LLC, Skokie, IL- On March 2, 2016, the employer had not conducted retraining when an employee on the Central/105 (Hunter) shakeout line, where the use of respiratory protection is required and exposures to respirable crystalline quartz silica, a carcinogen, were documented to be several times over the OSHA established Permissible Exposure Limit, was observed improperly wearing his disposable particulate respirator.     b) Castwell Products, LLC, Skokie, IL- On March 2, 2016, the employer had not conducted retraining when employees on the DISA shakeout line, where the use of respiratory protection is required and exposures to respirable crystalline quartz silica, a carcinogen, were documented to be several times over the OSHA established Permissible Exposure Limit, were observed improperly wearing their disposable particulate respirators.    Castwell Products, LLC was previously cited for a violation of this Occupational Safety and Health Standard, 29 CFR 1910.134(k)(5)(ii), which was contained in OSHA inspection Number 961300, citation number 1, item number 1b, and was affirmed as a final order on July 1, 2014, with respect to a workplace located at 7800 N. Austin Avenue in Skokie, Illinois.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Jul 22, 2016

Abate by

Aug 17, 2017

Penalty

Initial $9,900 · Current $9,900

Hazardous substances 9010

General-duty citation text

29 CFR 1910.1000(c): An employee(s) was exposed to respirable crystalline quartz silica in excess of the 8-hour time weighted average limits as calculated using the formula listed in Table Z-3:     a) Castwell Products, LLC, Skokie, IL- On March 2, 2016, an employee working at the foundry?s Central/105 (Hunter)shakeout was exposed to airborne concentrations of respirable crystalline silica (quartz), a carcinogen, at 3.1 mg/M3, approximately 3.27 times the OSHA Permissible Exposure Limit (PEL) of 0.949 mg/M3 as an 8-hour time-weighted average. The PEL was established to prevent silicosis and lung cancer.  The exposure level was derived from a sample taken over a 431 minute period during the third shift starting on March 2, 2016. Zero exposure was assumed for the unsampled period of 49 minutes.    b) Castwell Products, LLC, Skokie, IL- On March 2, 2016, an employee working at the foundry's Central/105 (Hunter) shakeout was exposed to airborne concentrations of respirable crystalline silica (quartz), a carcinogen, at 3.2 mg/M3, approximately 3.28 times the OSHA Permissible Exposure Limit (PEL) of 0.968 mg/M3 as an 8-hour time-weighted average. The PEL was established to prevent silicosis and lung cancer.  The exposure level was derived from a sample taken over a 437 minute period during the third shift starting on March 2, 2016. Zero exposure was assumed for the unsampled period of 43 minutes.      c) Castwell Products, LLC, Skokie, IL- On March 2, 2016, an employee working at the foundry?s DISA shakeout was exposed to airborne concentrations of respirable crystalline silica (quartz), a carcinogen, at 1.0 mg/M3, approximately 1.29 times the OSHA Permissible Exposure Limit (PEL) of 0.773 mg/M3 as an 8-hour time-weighted average.  The PEL was established to prevent silicosis and lung cancer. The exposure level was derived from a sample taken over a 419 minute period during the third shift starting on March 2, 2016. Zero exposure was assumed for the unsampled period of 61 minutes.     d) Castwell Products, LLC, Skokie, IL- On March 2, 2016, an employee working at the foundry?s DISA shakeout was exposed to airborne concentrations of respirable crystalline silica (quartz), a carcinogen, at 1.8 mg/M3, approximately 1.75 times the OSHA Permissible Exposure Limit (PEL) of 1.047 mg/M3 as an 8-hour time-weighted average. The PEL was established to prevent silicosis and lung cancer.  The exposure level was derived from a sample taken over a 414 minute period during the third shift starting on March 2, 2016. Zero exposure was assumed for the unsampled period of 66 minutes.    e) Castwell Products, LLC, Skokie, IL- On March 2, 2016, an employee working adjacent to the foundry?s Central/105 (Hunter) shakeout at the muller was exposed to airborne concentrations of respirable crystalline silica (quartz), a carcinogen, at 2.18 mg/M3, approximately 2.28 times the OSHA Permissible Exposure Limit (PEL) of 0.956 mg/M3 as an 8-hour time-weighted average. The PEL was established to prevent silicosis and lung cancer. The exposure level was derived from a sample taken over a 336 minute period during the third shift starting on March 2, 2016.  Zero exposure was assumed for the unsampled period of 144 minutes.       f) Castwell Products, LLC, Skokie, IL- On March 2, 2016, an employee operating a powered industrial vehicle in the foundry was exposed to airborne concentrations of respirable crystalline silica (quartz), a carcinogen, at 1.20 mg/M3, approximately 1.24 times the OSHA Permissible Exposure Limit (PEL) of 0.969 mg/M3 as an 8-hour time-weighted average. The PEL was established to prevent silicosis and lung cancer. The exposure level was derived from a sample taken over a 198 minute period during the third shift starting on March 2, 2016.  Zero exposure was assumed for the unsampled period of 282 minutes.    Castwell Products, LLC was previously cited for a violation of this Occupational Safety and Health Standard, 29 CFR 1910.1000(c), which was contained in OSHA inspection Number 961300, citation number 1, item number 2a, and was affirmed as a final order on July 1, 2014, with respect to a workplace located at 7800 N. Austin Avenue in Skokie, Illinois.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Jul 22, 2016

Abate by

Aug 17, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 9010

General-duty citation text

29 CFR 1910.1000(e): Feasible administrative or engineering controls were not determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):    a) Castwell Products, LLC, Skokie, IL- Effective engineering and administrative controls were not instituted and maintained by the employer in the DISA shakeout and in Department 20, the Central/105 (Hunter) shakeout of the foundry to reduce employee exposure to crystalline silica (quartz), a carcinogen, below the OSHA Permissible Exposure Limits (PELs). Employees working at the foundry's DISA shakeout, Central/105 (Hunter) shakeout area(s), the muller and the employee operating a powered industrial vehicle were exposed to respirable crystalline silica (quartz) in excess of the PEL.     See instance descriptions in item 2(a) of this citation.    Methods of engineering, administrative and work practice controls under these circumstances include but are not limited to:    1) Enforce the proper use of respirators. Ensure that an effective respiratory protection program in accordance with 1910.134 is being followed where employees are trained and respiratory protection is used correctly.       2) Implement the following recommendations proposed as a result of the ventilation/engineering survey conducted at the worksite on March 2, 2016, which are based on prudent practices established through the experience of the site visit team and publications from consensus groups, such as the ACGIH (Ventilation Manual) and the American Foundry Society (Foundry Ventilation Manual):        A.  Reduce muller fugitive emissions. Reduce significant background silica along the Central/ 105 (Hunter) shakeout line by eliminating the fugitive emissions from the nearby muller operation.  Effective control can be accomplished by local exhaust ventilation. Hood inlet velocity should be approximately 1000-1500 ft/min in order to overcome the velocities that are created when the sand falls from the weigh-hopper into the muller.         B.  Convert existing side-draft hoods on the Central/105 (Hunter) and DISA vibratory shakeout degating lines to enclosing hoods.  Benefits include (1) a significant reduction in localized silica emissions from the vibratory conveyor, (2) the "push" component of the ventilation system could be dramatically reduced resulting in less, powered make-up air and associated fan horsepower, (3) the capture efficiency of the enclosing hood is better than the side-draft hood, and (4) the conversion could be easily reversed if higher production returns.         C.  Modify the "push" system  that complements the Central/105 (Hunter) and DISA shakeout side-draft exhaust hoods by (1) tempering the outside air so the system is not shut down during cold weather, (2) repairing the damaged directional vanes in the louvered diffusers. Once repaired, adjust the diffuser vanes to direct the "push" air at the side-draft exhaust hood, and (3) volumetrically balancing the flow rates apportioned to each louvered diffuser.        D.  Continue with and improve housekeeping efforts on paths where industrial trucks travel to reduce exposures for (1) Central/105 (Hunter) shakeout workers who are proximate to the main east-west path for industrial trucks, (2) DISA shakeout workers who are proximate to the main north-south path for industrial trucks, and (3) Drivers of industrial trucks.        E.  Investigate using longer mold cooling times and rotating shakeouts to reduce the significant quantities of mold sand adhering to the castings and gates at the Hunters shakeout vibratory conveyer line.        F. Provide supplied air islands for both the Central/105 (Hunter) and DISA vibratory shakeout work positions where employees stand to degate, sort, clean, or throw gates and castings into hoppers. The intent of this engineering control is to have clean air flow down over the worker(s), which normally keeps contaminated air from entering the breathing zone. Design the supply air island to provide a laminar flow of fresh air through the employee's breathing zone at a low enough velocity so that additional airborne contaminated dust is not entrained. Implement work practices to require employees to stand under the islands as much as possible. These islands are feasible as there is no interference with any casting hoists. This control would be more feasible for the two wedger workers along the Hunters line than providing local exhaust ventilation.        G.  Equip the DISA line discharge chute to the vibratory shakeout conveyor with local exhaust ventilation.        H.  Use a Bobcat that has a filtered environmental system for the cabin.  Operate the system in the recirculating mode only.  Aggressively clean the cabin regularly to reduce dust accumulation.  Install an independent, fan-powered, HEPA filtration unit on the roof if the "factory" ventilation system fails to reduce exposures below OSHA's PEL.        I.  Implement a more aggressive administrative control program including housekeeping of floors and other horizontal surfaces where deposited silica can be re-introduced into the general workplace air. Use dustless methods of cleaning such as vacuuming. General housekeeping should be intensified to mitigate dust accumulation that contain respirable particulates.    3) Seek expertise of a competent individual who regularly provides independent consulting service, such as a ventilation expert or ventilation engineer for this or similar industries, to conduct their own assessment or use the above-mentioned recommendations as guidance for recommending and prioritizing improvements, preparing design documentation and/or for conducting additional assessments of the engineering control systems to improve the ventilation to reduce employee exposures.      4) Perform periodic maintenance checks/inspections of the local exhaust ventilation system to ensure that the capture velocity is effective, and that the system is functioning as designed.    ABATEMENT NOTE:    Step 1: Continue to enforce the utilization of respiratory protection as an interim measure of protection for affected employees.  Ensure employees are trained and respiratory protection is worn correctly.     Abatement date: 30 days    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 measure to control employee exposures to crystalline silica (quartz) as referenced in the citation.  This plan shall include, at a minimum, target dates for the following action, which must be consistent with the dates required by this citation:         (1)  Evaluation of engineering/administrative controls;    (2)  Selection of the 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 measure shall be evaluated for each particular use by a competent industrial hygienist or other technically qualified persons(s).  30-day progress reports to OSHA are required during the abatement period.       Abatement date: 60 days       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: 90 days      Castwell Products, LLC was previously cited for a violation of this Occupational Safety and Health Standard, 29 CFR 1910.1000(e), which was contained in OSHA inspection Number 961300, citation number 1, item number 2b, and was affirmed as a final order on July 1, 2014, with respect to a workplace located at 7800 N. Austin Avenue in Skokie, Illinois.     In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation demonstrating that abatement is complete must be included with your certification.  This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.