OSHA Inspection: R. STRESAU LABORATORY, INC.

Issued

Sep 23, 2016

Abate by

Nov 15, 2016

Penalty

Initial $7,482 · Current $3,741 Reduced

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer did not identify and evaluate the respiratory hazard(s) in the workplace; including a reasonable estimate of employee exposures to respiratory hazards and identification of the contaminant's chemical state and physical form:    (a) Throughout building # 4; The employer did not identify and evaluate the respiratory hazards associated with RDX, including a reasonable estimate of employee exposure while manufacturing energetic devices.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $6,236 · Current $5,300 Reduced

General-duty citation text

29 CFR 1910.1025(e)(3)(ii): The written compliance program for lead did not include the required sections listed in (A, B, C, E, & F) of the standard:      (a) Throughout the facility; Employees were exposed to lead above the OSHA permissible exposure limit; the employer had an inadequate lead compliance program which did not implement the above required sections to address the reduction of lead exposure for employees that manufactured energetic devices.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(e)(3)(iv): Written compliance programs for lead were not revised and updated annually to reflect the current status of the program:    (a) Throughout the facility; The provided written compliance program for lead had not been updated since April 16, 2008.

Issued

Sep 23, 2016

Abate by

Nov 15, 2016

Penalty

Initial $6,236 · Current $5,300 Reduced

General-duty citation text

29 CFR 1910.1025(e)(4)(i): When ventilation was used to control exposure to lead, measurements which demonstrate the effectiveness of the system in controlling exposure were not made at least every three months:    (a) Throughout buildings # 4, 5, 7; The employer did not provide documentation to show that the effectiveness of the ventilation systems used to control lead exposures were checked at least every three months.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $7,482 · Current $6,360 Reduced

General-duty citation text

29 CFR 1910.134(f)(2): Employee(s) using tight-fitting facepiece respirators were not fit tested prior to initial use of the respirator:    (a) On or about March 30, 2016, building # 17; Employees utilizing filtering facepiece respirators for protection against hazardous chemicals, including but not limited to, lead monoxide, were not fit tested prior to initial use.     (b) Throughout the facility; Employees utilizing filtering facepiece respirators for protection against hazardous chemicals, including but not limited to, lead azide and lead styphnate, were not fit tested prior to initial use.

Issued

Sep 23, 2016

Abate by

Nov 15, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(f)(1)(i): Respirators required  for protection against lead were not used during the time period necessary to install and implement engineering or work practice controls:  (a) Prior to March 24, 2016, building # 17; Respirators required for protection against lead monoxide were not utilized and mandatory, prior to installation of engineering controls.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(f)(2)(i): The employer did not implement a respiratory protection program in accordance with 29 CFR 1910.134(b) through (d) (except (d)(1)(iii)), and (f) through (m) for each employee required by 29 CFR 1910.1025 to use a respirator:    (a) Throughout the facility; The employer did not ensure the elements of the respiratory protection program were being implemented for each affected employee exposed to lead. Employees were exposed to lead over the permissible exposure limit (PEL) and the action level while manufacturing energetic devices.

Issued

Sep 23, 2016

Abate by

Nov 15, 2016

Penalty

Initial $7,482 · Current $3,741 Reduced

General-duty citation text

29 CFR 1910.138(a): The employer did not select and require employee(s) to use appropriate hand protection when employees' hands were exposed to hazards such as those from skin absorption of harmful substances:    (a) Throughout building #4; The employer did not require employees to use appropriate hand protection when employees where using hazardous substances including, but not limited to, RDX.

Issued

Sep 23, 2016

Abate by

Nov 15, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(g)(1)(ii): Appropriate protective work clothing and equipment was not required and utilized at all times when employee(s) were exposed to lead above the permissible exposure limit (PEL), or where the possibility of skin or eye irritation exists, such as disposable shoe coverlets and gloves:       (a)  Prior to March 31, 2016, building #17; Appropriate protective work clothing and equipment including, but not limited to, disposable shoe coverlets and gloves were not required and utilized by employees exposed to lead over the permissible exposure limit while manufacturing energetic devices.   (b) Throughout building #4; Appropriate protective work clothing and equipment including, but not limited to, disposable shoe coverlets and gloves were not required and utilized by employees exposed to lead over the permissible while manufacturing energetic devices.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $7,482 · Current $6,360 Reduced

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:    (a) Throughout buildings #4 & 17; Employees that manufactured energetic devices, exposed to lead in excess of the permissible exposure limit, were not provided change rooms.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $0 · Current $0

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:      (a) Throughout buildings #4 & 17; Employees that manufactured energetic devices, exposed to lead in excess of the permissible exposure limit, were not required to shower at the end of their work shift.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $7,482 · Current $6,360 Reduced

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 than thirty days per year:    (a) Throughout the facility; A medical surveillance program was not instituted for employees who were, or could have been, exposed to lead above the action level while manufacturing energetic devices.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(j)(3)(i)(B): Medical examinations and consultations for lead were not performed prior to assignment for each employee being assigned for the first time to an area in which airborne concentrations of lead are at or above the action level:    (a) Throughout the facility; Medical examinations and consultations for lead were not performed prior to assignment for each employee exposed to lead at or above the action level while manufacturing energetic devices.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(k)(1)(ii)(A): An employee was not removed from work having an exposure to lead at or above the action level on each occasion that a final medical determination resulted in a medical finding, determination, or opinion that the employee had a detected medical condition which places the employee at increased risk of material impairment to health from exposure to lead:    (a) On or about March 31, 2016, building #4 & 17;  The employer did not follow the doctors determination to remove employee(s) from work areas where exposure to lead was present during the manufacturing of energetic devices.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $7,482 · Current $6,360 Reduced

General-duty citation text

29 CFR 1910.1025(l)(1)(i): Employee(s) working in an area where there is potential exposure to airborne lead at any level were not informed of the content of Appendices A and B of 29 CFR 1910.1025:    (a) Throughout the facility; Employees were exposed to lead hazards while manufacturing energetic devices and were not informed of Appendices A and B of 29 CFR 1910.1025.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(l)(1)(ii): The employer did not train each employee who is subject to exposure to lead at or above the action level, or for whom the possibility of skin or eye irritation exists, in accordance with the requirements of 29 CFR 1910.1025, specifically 1910.1025 (l)(1)(v)(A) thru (G):    (a) Throughout the facility; Employees exposed to lead at or above the action level while manufacturing energetic devices were not trained on the requirements specified in 29 CFR 1910.1025(l)(1).

Issued

Sep 23, 2016

Abate by

Nov 15, 2016

Penalty

Initial $85,512 · Current $72,685 Reduced

General-duty citation text

29 CFR 1910.1025(c)(1): Employee(s) were exposed to lead for more than eight hours during the work day in excess of the reduced permissible exposure limit:    (a) Building #17, Mark 20 Line; The employer did not ensure that employee(s) exposure to lead did not exceed 40 micrograms per cubic meter (ug/m3) of air, as a reduced 10-hour time weighted average (TWA) for the extended work shift. This violation occurred on April 5, 2016 when an employee manufacturing energetic devices was exposed to lead at a 10-hour TWA of 100.8 ug/m3 of air, approximately 2.52 times the permissible exposure limit of 40 ug/m3. Sampling was performed for 543 minutes during one shift. Zero exposure was assumed for the 57 minute period not sampled.    (b) Building #17, Mark 20 Line; The employer did not ensure that employee(s) exposure to lead did not exceed 40 micrograms per cubic meter (ug/m3) of air, as a reduced 10-hour time weighted average (TWA) for the extended work shift. This violation occurred on April 5, 2016 when an employee manufacturing energetic devices was exposed to lead at a 10-hour TWA of 53.6 ug/m3 of air, approximately 1.34 times the permissible exposure limit of 40 ug/m3. Sampling was performed for 543 minutes during one shift. Zero exposure was assumed for the 57 minute period not sampled.

Issued

Sep 23, 2016

Abate by

Dec 30, 2016

Penalty

Initial $0 · Current $0

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:    (a) Building #17, Mark 20 Line; Initial monitoring was not performed to quantify employees exposure to lead while manufacturing energetic devices. Air sampling performed on April 5, 2016 indicated four employee exposures to lead at or above the action level.    (b) Throughout the facility; Initial monitoring was not performed to quantify employees exposure to lead while performing cleaning and maintenance activities such as, but not limited to, sweeping and changing of filters.

Issued

Sep 23, 2016

Abate by

Dec 30, 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) to reduce and maintain employee exposure to lead:    (a) Building #17, Mark 20 Line; The employer failed to implement an effective combination of engineering, work practice, and respiratory controls to reduce and maintain employee(s) exposures to or below 40 micrograms per cubic meter or less. An employee was overexposed to lead on April 5, 2016  (exposure to lead at a 10-hour TWA of 100.8 ug/m3 of air, approximately 2.52 times the permissible exposure limit of 40 ug/m3) while manufacturing energetic devices.    (b) Building #17, Mark 20 Line; The employer failed to implement an effective combination of engineering, work practice, and respiratory controls to reduce and maintain employee(s) exposures to or below 40 micrograms per cubic meter or less. An employee was overexposed to lead on April 5, 2016  (exposure to lead at a 10-hour TWA of  53.6 ug/m3 of air, approximately 1.34 times the permissible exposure limit of 40 ug/m3) while manufacturing energetic devices.

Issued

Sep 23, 2016

Abate by

Nov 15, 2016

Penalty

Initial $700 · Current $595 Reduced

General-duty citation text

29 CFR 1904.4(a): The employer did not record each work-related fatality, injury or illness case that resulted in the general recording criteria on the OSHA Form 300 or equivalent:     (a) On or about March 31, 2016; The employer did not record workplace illnesses related to lead on the OSHA Form 300 or equivalent for the calendar year 2016 in which employee(s) received days away and/or work transfer/restrictions.