OSHA Inspection: G. D. ROBERTS & CO., INC.

Issued

Dec 22, 2016

Abate by

Apr 30, 2017

Penalty

Initial $6,236 · Current $6,236

General-duty citation text

29 CFR 1910.95(c)(1): The employer shall administer a continuing, effective hearing conservation program, as described in paragraphs (c) through (o) of this section, whenever employee noise exposures equal or exceed an 8-hour time-weighted average sound level (TWA) of 85 decibels measured on the A scale (slow response) or, equivalently, a dose of fifty percent. For purposes of the hearing conservation program, employee noise exposures shall be computed in accordance with appendix A and Table G-16a, and without regard to any attenuation provided by the use of personal protective equipment.    On or about June 28, 2016, and times prior to and thereafter, the employer did not develop a continuous, effective hearing conservation program, consisting of the following:     a) The development and implementation of a monitoring program   b) The establishment and maintenance of an audiometric training program  c) The training of employees whose exposures t noise are at or above the 8 hour TWA of 85 dBA.

Issued

Dec 22, 2016

Abate by

Apr 30, 2017

Penalty

Initial $6,236 · Current $6,236

General-duty citation text

29 CFR 1910.134(c)(1)(iii): The written program did not contain fit test procedures for tight-fitting respirators:    On or about June 28, 2016, and at times prior to and thereafter, the employer did not establish a written respiratory protection program that contained worksite specific procedures for fit testing for tight-fitting respirators for employees required to wear respirators, including, but not limited, the following employees:    a) Paint booth operators for the Wagner powder paint system.    b) Paint booth operator assigned to the individual paint booth.

Issued

Dec 22, 2016

Abate by

Apr 30, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(c)(1)(vi): The written program did not contain procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators:    On or about June 28, 2016, and at times prior to and thereafter, the employer did not establish a written respiratory protection program that contained worksite specific procedures to ensure adequate air quality, quantity and flow of breathing air for atmosphere-supplying respirator used by the Blast Booth operator.

Issued

Dec 22, 2016

Abate by

Jan 17, 2017

Penalty

Initial $4,988 · Current $0 Reduced

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):    On or about June 28, 2016, and at times prior to and thereafter, the employer did to ensure that the employee required to wear respirators passed a fit test, including the following:    a) Employees wearing tight-fitting respirators on the Wagner paint line.    b) Employees wearing tight-fitting respirators in the individual powder paint booth.

Issued

Dec 22, 2016

Abate by

Jan 9, 2017

Penalty

Initial $0 · Current $4,386

Hazardous substances 9135

General-duty citation text

29 CFR 1910.1000(a)(2): Employee(s) were exposed to an airborne concentration of particulates not otherwise regulated - total dust listed in Table Z-1 in excess of the 8 hour Time Weighted Average concentration of 15 milligrams per cubic meter:    a) On September 23, 2016, the paint booth operator was exposed to 19.15 milligrams per cubic meter of particulates not otherwise regulated- total dust, which is 1.28 times the permissible exposure limit of 15 milligrams per cubic meter.      b) On September 23, 2016, the blast booth operator was exposed to 597.5 milligrams per cubic meter of particulates not otherwise regulated-total dust, which is 39.8 times the permissible exposure limit of 15 milligrams per cubic meter.

Issued

Dec 22, 2016

Abate by

Apr 30, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 9135

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):    The employer did not implement feasible engineering controls to achieve compliance with limits prescribed in 29 CFR 1910.1000(a) through (d).    On September 23, 2016, the paint booth operator and blast booth operator were overexposed to particulates not otherwise regulated- total dust.  General methods of control applicable in these circumstances include, but are not limited to the following:      1. Reevaluate the efficacy of the ventilation provided for the blast booth and paint booth.  Ensure that the ventilation meets or exceeds the most current recommendations outlined in the American National Standard Fundamentals Governing the Design and Operation of Local Exhaust System - ANSI Z9.2, and NFPA 91 Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists and Noncombustible Particulate Solids.    2.  Verify that the blast booth and paint booth are operated and maintained per the manufacturer's instructions.    3.  Review work practices and placement of parts in relation to distance from capture ventilation, determining if placing parts closer to ventilation would reduce exposure levels.    Disclaimers:  1. The employer is not limited to the abatement methods suggested by OSHA;  2. The methods explained are general and may not be effective in all cases; and  3. The employer is responsible for selecting and carrying out an effective abatement.      ABATEMENT SCHEDULE:  STEP 1:  Effective respiratory protection shall be provided and used by exposed employees               as an interim protective measure until feasible engineering controls can be               implemented or whenever such controls fail to reduce employee exposures 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 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 abatement dates required by this citation:                 1. Evaluation of engineering control options;             2. Selection of optimum control methods and completion of design;             3. Procurement, installation, and operation of selected control measures; and             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.      STEP 3:   Abatement shall have been completed by the implementation of feasible                engineering controls upon verification of their effectiveness in achieving                compliance.                 Date by Which Violation Must be Abated:  STEP-1    XX/XX/XXXX                 Date by Which Violation Must be Abated:  STEP-2    30 days from issuance                 Date by Which Violation Must be Abated:  STEP-3    60 days from issuance

Issued

Dec 22, 2016

Abate by

Jan 17, 2017

Penalty

Initial $4,988 · Current $4,988

General-duty citation text

29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee was fit tested or required to use the respirator in the workplace:    On or about June 28, 2016, and at times prior to and thereafter, the employer did not provide a medical evaluation to employees required to wear respiratory protection, including but not limited to, the following employees:    a) Paint booth operators for the Wagner powder paint system.    b) Paint booth operator assigned to the individual paint booth.    c) Blast booth operator.

Issued

Dec 22, 2016

Abate by

Jan 17, 2017

Penalty

Initial $6,236 · Current $0 Reduced

General-duty citation text

29 CFR 1910.134(k)(3): Training was not provided prior to requiring employees to use a respirator in the workplace:    On or about June 28, 2016, and at times prior to and thereafter, the employer did not provide a training to employees required to wear respirator in the workplace:    a) Paint booth operators for the Wagner powder paint system.    b) Paint booth operator assigned to the individual paint booth.    d) Blast booth operator.

Issued

Dec 22, 2016

Abate by

Jan 26, 2018

Penalty

Initial $12,471 · Current $12,471

General-duty citation text

29 CFR 1910.147(c)(1): The employer did not establish a program consisting of an energy control procedure, employee training and periodic inspections to ensure that before any employee performed any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative:    On or about June 27, 2016, and at times prior to and thereafter, the employer's written program did not consist of employee training and periodic inspections to ensure that before servicing or maintenance was performed on machinery or equipment, such as but not limited to, the Amada laser cutting system, the equipment was isolated from the energy source and rendered inoperative.

Issued

Dec 22, 2016

Abate by

Jan 26, 2018

Penalty

Initial $12,471 · Current $0 Reduced

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:    On or about June 27, 2016, and at times prior to and thereafter, procedures were not developed, documented or utilized to control the potential hazardous energy when employees are performing maintenance and cleaning on the Amada laser cutting system.

Issued

Dec 22, 2016

Abate by

Jan 17, 2017

Penalty

Initial $12,471 · Current $12,471

General-duty citation text

29 CFR 1910.147(c)(7)(i): The employer did not provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees:    On or about June 27, 2016, and at times prior to and thereafter, the employer did not provide training to employees, including but not limited to the Amada Laser Cutter operator,  to ensure that the knowledge and skills required for safe application and usage of the energy controls were acquired.

Issued

Dec 22, 2016

Abate by

Jan 17, 2017

Penalty

Initial $12,471 · Current $12,471

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:    On or about June 27, 2016, and at times prior to and thereafter, lockout or tagout devices were not affixed to each energy isolating device on the Amada laser cutting system when employees performed cleaning procedures.

Issued

Dec 22, 2016

Abate by

Apr 30, 2017

Penalty

Initial $3,741 · Current $3,741

General-duty citation text

29 CFR 1910.178(a)(4): Modifications or additions which affect capacity and safe operation of powered industrial truck were performed by the employer without the manufacturer's prior written approval:    On September 23, 2016, and at times prior to and thereafter, the employer was using a Daewoo sit down rider, propane forklift modified with a hole drilled through one the tines, without obtaining the manufacturer's written approval prior to use.

Issued

Dec 22, 2016

Abate by

Apr 30, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.178(a)(5): The powered industrial truck was equipped with front-end attachments other than factory installed attachments, however the employer did not request that the truck be marked to identify the attachments and show the approximate weight of the truck and attachment combination at maximum elevation with load laterally centered:    On or about September 23, 2016, and at times prior to and thereafter, the employer was using a Daewoo sit down rider, propane forklift modified with a hole drilled through one the tines, and a trailer ball hitch attached without the truck being marked to identify the attachment.

Issued

Dec 22, 2016

Abate by

Jan 17, 2017

Penalty

Initial $6,236 · Current $0 Reduced

General-duty citation text

29 CFR 1910.178(l)(1)(i): The employer did not ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (l):    On or about July 28, 2016, and at times prior to and thereafter, the employer did not ensure that each powered industrial truck operator had successfully completed the training specified in paragraph (l).

Issued

Dec 22, 2016

Abate by

Jan 17, 2017

Penalty

Initial $6,236 · Current $5,000 Reduced

General-duty citation text

29 CFR 1910.1200(e)(1)(i): The employer did not compile a list of the hazardous chemicals known to be present using a product identifier that was referenced on the appropriate safety data sheet.    On or about June 28, 2016, and at times prior to and thereafter, the employer did not compile a list of hazardous chemicals known to be present in the workplace, including but not limited to: TCI Powder Coatings - FC SD RAL 6018 Yellow Green 25; Hentzen Ford White Powder Coating; Tiger Drylac RAL 6021; Radnor ER70S-6; Prismatic Powders P-series.

Issued

Dec 22, 2016

Abate by

Jan 17, 2017

Penalty

Initial $6,236 · Current $0 Reduced

General-duty citation text

29 CFR 1910.1200(h)(1): Employees were not provided effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard that the employees had not been previously trained about was introduced into their work area:    On or about June 28, 2016, and at times prior to and thereafter, the employer did not train employees in the hazardous chemicals in their work areas, including but not limited to, the combustible dust explosion hazards created by the powder paints and the skin sensitization and genetic defects cause by the powder paints.