OSHA Inspection: CONVERTING TECHNOLOGY, INC.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $4,183 · Current $2,719 Reduced

General-duty citation text

29 CFR 1910.134(c)(2)(ii): The employer did not establish and implement those elements of a written program necessary to ensure that any employee using a respirator voluntarily was medically able to use that respirator, and that the respirator was cleaned, stored, and maintained so that its use does not present a health hazard to the user.    (a)   On or about December 14, 2016, in the Converting Room, a Press Man voluntarily used a full-face elastomeric respirator equipped with chemical cartridges when adding solvent and ink to Converting Machines.  No medical evaluation had been provided to verify that this worker was medically able to use this respirator.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $6,971 · Current $4,531 Reduced

General-duty citation text

29 CFR 1910.147(c)(4)(ii): 29 CFR 1910.147(c)(4)(ii): The procedures did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, 29 CFR 1910.147(c)(4)(ii)(A-D):    (a) The energy control procedure number "LOTO-RB26", which the employer had developed for Converting Machines RB126, RB426, and RB536, was deficient in that it did not address techniques to be utilized for control of  pneumatic energy.    (b) The  energy control procedure number "LOTO-RB26B", which the employer had developed for Converting Machines RB226 and RB326, was deficient in that it did not address techniques to be utilized for control of pneumatic energy.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(6)(i): The employer did not conduct an annual or more frequent inspection of the energy control procedure to ensure that the procedure and requirements of this standard were followed:  (a)  The employer did not conduct a periodic inspection of the energy control (lockout/tagout) procedure(s) for equipment, including but not limited to Converting Machines, Wizard Machines, and other equipment in the Converting Room.

Issued

Mar 24, 2017

Penalty

Initial $3,555 · Current $2,311 Reduced

General-duty citation text

29 CFR 1910.176(b): Storage of material created a hazard:    (a)    On or about December 14, 2016, in the Warehouse area and adjacent to the Converting Room, multiple used containers of C-287 solvent, which contained residues of that solvent, were unsafely stored in that some of the containers were uncapped and were stacked in an unstable manner.  This condition exposed workers in the adjacent aisle way to a potential struck-by and trip/fall injury.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $9,760 · Current $6,344 Reduced

General-duty citation text

29 CFR 1910.212(a)(1): One or more methods of machine guarding was not provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks:    (a)    In the Converting Room, Converting Machine #1 had no interlock for the hinged plexiglass guard, that covered the zingers, to protect Machine Operators from the hazard of ingoing nip points.  This condition exposed workers to amputation injury.    (b)    In the Converting Room, Converting Machine #2 had no interlock for the hinged plexiglass guard, that covered the zingers, to protect Machine Operators from the hazard of ingoing nip points.  This condition exposed workers to amputation injury.    (c)    In the Converting Room, Converting Machine #3 had no interlock for the hinged plexiglass guard, that covered the zingers, to protect Machine Operators from the hazard of ingoing nip points.  This condition exposed workers to amputation injury.    (d)    In the Converting Room, Converting Machine #5 had no interlock for the hinged plexiglass guard, that covered the zingers, to protect Machine Operators from the hazard of ingoing nip points.  This condition exposed workers to amputation injury.    (e)    In the Converting Room, the Wizard Machine adjacent to Converting Machine #1 had no guarding in place for rotating parts, such as the seal bar, on the south side of the machine to protect Machine Operators from the hazard of ingoing nip points.  This condition exposed workers to amputation injury.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $9,760 · Current $0 Reduced

General-duty citation text

29 CFR 1910.219(a)(2): Vertical and inclined belts (paragraphs (e) (3) and (4) of this section) if not more than two and one-half (2 1/2) inches wide and running at a speed of less than one thousand (1,000) feet per minute, and if free from metal lacings or fastenings were not guarded with a nip-point belt and pulley guard.    (a)     In the Converting Room, the Wizard Machine (located adjacent to and north of Converting Machine #1) had no interlock for the hinged plexiglass door(s) on its north side to protect machine operators from the hazard of ingoing nip-point associated with an inclined belt and pulley.  This condition exposed workers to amputation injury.    (b)    In the Converting Room, drive belts on Converting Machine #1 were not guarded. This condition exposed workers to amputation injury.    (c)    In the Converting Room, drive belts on Converting Machine #2 were not guarded.  This condition exposed workers to amputation injury.    (d)    In the Converting Room, drive belts on Converting Machine #3 were not guarded.  This condition exposed workers to amputation injury.    (e)    In the Converting Room, drive belts on Converting Machine #4 were not guarded.  This condition exposed workers to amputation injury.    (f)    In the Converting Room, drive belts on Converting Machine #5 were not guarded.  This condition exposed workers to amputation injury.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $4,183 · Current $2,719 Reduced

General-duty citation text

29 CFR 1910.303(g)(2)(i): Live parts of electric equipment operating at 50 volts or more were not guarded against accidental contact by approved cabinets or other forms of approved enclosures, or other means listed under this provision:    (a)    On or about December 14, 2016, in the Converting Room, wiring connecting 240 volts AC to the Slit Seal Knives on Converting Machine #5 had frayed insulation, exposing workers to an electrical shock hazard.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $9,760 · Current $6,344 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(c)(2): The employer did not ensure that no employee was exposed to an airborne concentration of methylene chloride in excess of 125 parts per million as determined over a sampling period of 15 minutes:    (a) In the Converting Room, on or about December 14, 2016, a machine operator using C-287 solvent to clean ink off of zingers and rollers on Converting Machine #1 was exposed during a 15 minute sampling period to an airborne methylene chloride concentration of 161.3 parts per million, approximately 1.29 times the short term exposure limit of 125 parts per million.  This short term exposure limit has been established to protect workers from the acute toxic effects of methylene chloride and its metabolites, which can include adverse effects on the central nervous system, metabolic conversion of methylene chloride to carbon monoxide resulting in adverse cardiac effects, and potential carcinogenic effects.

Issued

Mar 24, 2017

Abate by

Jun 1, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(f)(1): The employer did not institute and maintain the effectiveness of engineering controls and work practices to reduce employee exposure to or below the permissible exposure limits and wherever the feasible engineering controls and work practices which can be instituted were not sufficient to reduce employee exposure to or below the 8-hour time weighted average permissible exposure limit or short term exposure limit, the employer did not use them to reduce employee exposure to the lowest levels achievable and did not supplement them by the use of respiratory protection that complied with the requirements of 29 CFR 1910.1052(g):  (a) In the Converting Room, on or about December 14, 2016, a machine operator using C-287 solvent to clean ink off of zingers and rollers on Converting Machine #1 was exposed during a 15 minute sampling period to an airborne methylene chloride concentration of 161.3 parts per million, approximately 1.29 times the short term exposure limit of 125 parts per million.  Control measures, including engineering controls and work practice controls, had not  been implemented to limit employee exposure to methylene chloride to or below the  short term exposure limit.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(g)(1)(i): Respirators were not used during periods when an employee's exposure to methylene chloride exceeds the 8-hour time weighted average permissible exposure limit or short term exposure limit:  (a) In the Converting Room, on or about December 14, 2016, a machine operator using C-287 solvent to clean ink off of zingers and rollers on Converting Machine #1 was exposed during a 15 minute sampling period to an airborne methylene chloride concentration of 161.3 parts per million, approximately 1.29 times the short term exposure limit of 125 parts per million.  This short term exposure limit has been established to protect workers from the acute toxic effects of methylene chloride and its metabolites, which can include adverse effects on the central nervous system, metabolic conversion of methylene chloride to carbon monoxide resulting in adverse cardiac effects, and potential carcinogenic effects.  Appropriate respiratory protection (e.g., supplied air respirator) was not provided, in accordance, with the provisions of the Respiratory Protection standard 29 CFR 1910.134 to protect machine operator(s) performing cleaning with C-287 solvent.

Issued

Mar 24, 2017

Penalty

Initial $6,971 · Current $4,531 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(d)(2): The employer did not perform initial monitoring to determine each employee's exposure to methylene chloride:    (a) In the Converting Room, Machine Operators periodically used the solvent C-287, which contained approximately 50% methylene chloride,  to clean ink and other residue from machine parts on Converting Machines and Wizard Machines.  No air monitoring had been done to determine each worker's full shift and short term exposure to methylene chloride.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $6,971 · Current $4,531 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(e)(1): The employer did not establish a regulated area wherever an employee's exposure to airborne concentrations of methylene chloride exceeded or could reasonably be expected to exceed either the 8-hour Time Weighted Average Permissible Exposure Limit or the Short Term Exposure Limit:     (a) In the Converting Room, on or about December 14, 2016, a machine operator using C-287 solvent to clean ink off of zingers and rollers on Converting Machine #1 was exposed during a 15 minute sampling period to an airborne methylene chloride concentration of 161.3 parts per million, approximately 1.29 times the short term exposure limit of 125 parts per million.  This short term exposure limit has been established to protect workers from the acute toxic effects of methylene chloride and its metabolites, which can include adverse effects on the central nervous system, metabolic conversion of methylene chloride to carbon monoxide resulting in adverse cardiac effects, and potential carcinogenic effects.  No regulated area had been established to the vicinity of Converting Machine #1 (and other Converting Machines) during the cleaning operation involving use of C-287 solvent containing methylene chloride, to limit access to authorized employee(s), having adequate training, and equipped with adequate personal protective equipment, including supplied air respiratory protection.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $5,578 · Current $3,626 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(i)(2): It was reasonably foreseeable that an employee's eyes may contact solutions containing 0.1 percent or greater methylene chloride and the employer did not provide appropriate eyewash facilities within the immediate work area for emergency use:    (a)    In the Converting Department, machine operators' eyes were potentially exposed to C-287 solvent, a liquid mixture containing approximately 50% methylene chloride.  Appropriate eyewash facilities were not provided within the immediate work area for emergency use.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $6,971 · Current $4,531 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1052(j)(1)(i): The employer did not make medical surveillance available for employees who were or potentially were  exposed to methylene chloride at or above the action level on 30 or more days per year, or above the 8-hour time weighted average permissible exposure limit or the short term exposure limit on 10 or more days per year:     (a) In the Converting Room, on or about December 14, 2016, a machine operator using C-287 solvent to clean ink off of zingers and rollers on Converting Machine #1 was exposed during a 15 minute sampling period to an airborne methylene chloride concentration of 161.3 parts per million, approximately 1.29 times the short term exposure limit (STEL) of 125 parts per million.  This short term exposure limit has been established to protect workers from the acute toxic effects of methylene chloride and its metabolites, which can include adverse effects on the central nervous system, metabolic conversion of methylene chloride to carbon monoxide resulting in adverse cardiac effects, and potential carcinogenic effects.  Medical surveillance was not made available for machine operators who may have exposure above the STEL.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $6,971 · Current $4,531 Reduced

General-duty citation text

29 CFR 1910.1052(l)(3)(i): The employer did not inform each affected employee of the requirements of 29 CFR 1910.1052 and the information available in its appendices and/or how to access or obtain a copy of it in the workplace:    (a) In the Converting Department, Machine Operators on a daily basis used rags soaked with C-287 solvent, containing approximately 50% methylene chloride, to clean off ink and other residue from zingers and other Converting Machine parts.  Machine Operators, Supervisors, Set-up and Maintenance workers periodically dispensed C-287 solvent from five (5) gallon stock containers to safety cans.  However, these employees were not provided with an overview or summary of OSHA's  Methylene Chloride standard, the information available in its appendices, and were not informed of how to access or obtain a copy of it in the workplace.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h)(3)(iv):   The details of the hazard communication program developed by the employer, did not include an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employee could obtain and use the appropriate hazard information:  (a) Workers were not provided training on the GHS (Globally Harmonized System) label format (including pictograms, signal word, hazard statements, and precautionary statements) received on shipped containers.  Also, training was not provided regarding the order of information in safety data sheets (SDS).  Hazardous chemicals used at this workplace included, but were not limited to, C-287 solvent.

Issued

Mar 24, 2017

Abate by

Apr 19, 2017

Penalty

Initial $8,365 · Current $5,437 Reduced

Hazardous substances 1730

General-duty citation text

29 CFR 1910.1200(f)(6)(ii): Except as provided in 29 CFR 1910.1200(f)(7) and 29 CFR 1910.1200(f)(8), the employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked with the product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals and which, in conjunction with the other information immediately available to employees under the hazard communication program, would provide employees with the specific information regarding the physical and health hazards of the hazardous chemical:    (a) In the Converting Department, the employer did not ensure the red safety plunger can containing "C287" solvent was labeled, tagged or marked with information such as but not limited to the chemical identity and associated hazard warnings.    The Converting Technology, Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.1200(f)(6), which was contained in OSHA inspection number 959717, citation number 1, item number 4b and was affirmed as a final order on  5/1/2014, with respect to a workplace located at N57 W13282 Carmen Ave., Menomonee Falls, WI 53051.