OSHA Inspection: RECYCLING COMPLIANCE SPECIALISTS LLC

Issued

Dec 20, 2016

Penalty

Initial $2,138 · Current $1,069 Reduced

General-duty citation text

29 CFR 1910.23(d)(1)(ii): Stairway(s) less than 44 inches wide having one side open, did not have at least one stair railing on the open side:    On or about September 2, 2016, the employer did not ensure that the stairways to the storage area had at least one stair railing on the open side.

Issued

Dec 20, 2016

Abate by

Jan 12, 2017

Penalty

Initial $2,673 · Current $1,336 Reduced

General-duty citation text

29 CFR 1910.95(g)(1): The employer did not establish and maintain an audiometric testing program as provided by 29 CFR 1910.95(g) by making audiometric testing available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 decibels:    On or about September 2, 2016, and at times prior to and thereafter, the employer did not establish an audiometric testing program to all employees whose exposures exceed an 8-hour time-weighted average of 85 decibels.    a) On September 8, 2016, the bulb processor was exposed to 87.9 decibels on the A scale, 8-hour time-weighted average.

Issued

Dec 20, 2016

Abate by

Jan 12, 2017

Penalty

Initial $3,741 · Current $1,870 Reduced

Hazardous substances 1631

General-duty citation text

29 CFR 1910.134(c)(1): A written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented for required respirator use:    On or about September 2, 2016, and at times prior to and thereafter, the employer did not establish a written respiratory protection program for employees required to wear respirators, including but not limited to, the following:    a) On September 8, 2016, the bulb processor was exposed to 0.1473 milligrams per cubic meter, which is 1.4 times the OSHA PEL of 0.1 milligrams per cubic meter.  The sampling took place over 193 minutes, and zero exposure was assumed for the remaining 287 minutes.

Issued

Dec 20, 2016

Abate by

Jan 12, 2017

Penalty

Initial $3,741 · Current $1,870 Reduced

Hazardous substances 1631

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:    On or about September 2, 2016, and at times prior to and thereafter, the employer did not evaluate the respiratory hazards in the workplace, including an estimate of employee exposures to mercury vapor:    a) On September 8, 2016, the bulb processor was exposed to 0.1473 milligrams per cubic meter, which is 1.4 times the OSHA PEL of 0.1 milligrams per cubic meter.  The sampling took place over 193 minutes, and zero exposure was assumed for the remaining 287 minutes.

Issued

Dec 20, 2016

Abate by

Jan 12, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1631

General-duty citation text

29 CFR 1910.1000(b)(2): Employee(s) were exposed to an airborne concentration of mercury listed in Table Z-2 in excess of the ceiling concentration of 0.1 milligrams per cubic meter as an 8 hour time weighted average.  On or about September 2, 2016, and at times prior to and thereafter, employees were overexposed to mercury:  a) On September 8, 2016, the bulb processor was exposed to 0.1473 milligrams per cubic meter as an 8-hour time weighted average, which is 1.4 times the OSHA PEL of 0.1 milligrams per cubic meter.  The sampling took place over 193 minutes, and zero exposure was assumed for the remaining 287 minutes.

Issued

Dec 20, 2016

Abate by

Sep 22, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1631

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):  On or about September 2, 2016, and at times prior to and thereafter, the employer did not implement feasible administrative or engineering controls to reduce employee exposures to mercury listed in Table Z-2 in excess of the ceiling concentration of 0.1 milligrams per cubic meter as an 8-hour time-weighted average.  a) On September 8, 2016, the bulb processor was exposed to 0.1473 milligrams per cubic meter as an 8-hour time weighted average, which is 1.4 times the OSHA PEL of 0.1 milligrams per cubic meter.  The sampling took place over 193 minutes, and zero exposure was assumed for the remaining 287 minutes. General methods of control applicable in these circumstances include, but are not limited to the following:    1. Reevaluate the efficacy of the particle and vapor air filtration system designed to capture and remove mercury vapor.  Assess the off-gassing of the broken bulbs stored inside the processing area awaiting disposal, and alternative storage areas.    2. Research administrative and engineering controls to reduce the amount of mercury vapor exposures, especially during filter changes.  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 (1 day from issuance)               Date by Which Violation Must be Abated:  STEP-2    XX/XX/XXXX (30 days from issuance)               Date by Which Violation Must be Abated:  STEP-3    XX/XX/XXXX (60 days from issuance)

Issued

Dec 20, 2016

Abate by

Jan 12, 2017

Penalty

Initial $2,673 · Current $1,336 Reduced

General-duty citation text

29 CFR 1910.141(g)(2): Employees were permitted to consume food or beverage in area(s) exposed to toxic materials:    On or about September 2, 2016, and at times prior to and thereafter, employees were allowed to consume food and beverages in areas with surface contamination of mercury.    a) Employees were allowed to eat lunch in the office area where the desktop was found contaminated with 6.54 micrograms per square foot of mercury.    b) The refrigerator handle where employees store food and drink was contaminated with 4.74 micrograms per square foot of mercury.    c)  The microwave where employees heat and cook food for consumption was contaminated with 2.44 micrograms per square foot of mercury.    d)  The drinking fountain was contaminated with 8.45 micrograms per square foot of mercury.

Issued

Dec 20, 2016

Abate by

Sep 22, 2017

Penalty

Initial $2,673 · Current $1,336 Reduced

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 September 2, 2016, and at times prior to and thereafter, the employer did not establish a program to ensure that before employees unjam the augers associated with the bulb processing, they isolate the energy source and render it inoperative.

Issued

Dec 20, 2016

Abate by

Sep 22, 2017

Penalty

Initial $2,673 · 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 September 2, 2016, and at times prior to and thereafter, the employer did not develop procedures to be used to control of potentially hazardous energy when employees unjam the augers associate with the bulb processing.

Issued

Dec 20, 2016

Abate by

Jan 12, 2017

Penalty

Initial $2,673 · Current $1,336 Reduced

General-duty citation text

29 CFR 1910.147(c)(5)(i): Locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other hardware were not provided by the employer for isolating, securing, or blocking of machines or equipment from energy sources:    On or about September 2, 2016, and at times prior to and thereafter, the employer did not provide hardware for isolating energy before employees unjam the augers associate with the bulb processing, they isolate the energy source and render it inoperative.

Issued

Dec 20, 2016

Abate by

Jan 12, 2017

Penalty

Initial $2,672 · Current $1,336 Reduced

General-duty citation text

29 CFR 1910.147(c)(7)(i): The employer did not provide adequate training to ensure that employees acquired the knowledge and skills required for the safe application, usage and removal of energy control devices:    On or about September 2, 2016, and at times prior to and thereafter, the employer did not provide training to ensure that before employees unjam the augers associated with the bulb processing, they have the knowledge and skills required to safely isolate the energy source and render it inoperative.

Issued

Dec 20, 2016

Abate by

Jan 12, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.178(l)(6): The employer did not certify that each operator has been trained and evaluated as required by this paragraph (l):  On or about September 2, 2016, and at times prior to and thereafter, the employer did not certify that each operator of the powered pallet jacks had been trained and evaluated.