OSHA Inspection: CONTAINER LIFE CYCLE MANAGEMENT LLC

Issued

Apr 12, 2017

Abate by

May 30, 2017

Penalty

Initial $12,675 · Current $0 Reduced

General-duty citation text

OSH Act of 1970 Section 5(a)(1):  The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to reactive material/chemical hazards due to the practice of draining and vacuuming chemicals from totes into common containers without implementing means to prevent unwanted chemical reactions capable of causing serious physical harm to employees:    (a)    On or about February 13, 2017 and times previous, in areas such as, but not limited to, the cut and scrape area: Liquid chemicals from 250 gallon totes were drained throughout each shift and collected in a common containers i.e., (250 gallon plastic reservoir collection totes and 55 gallon steel drums) consisting of comingled chemicals.  Similarly, in the cut and scrape area, vacuums were also used to remove residual chemicals from drain totes and the chemicals were comingled in the vacuums collection reservoir.  The potential mixing of reactive materials/chemicals, as well as the mixing/addition of chemical unknowns, exposed employees to reactive chemical hazards (such as, but not limited to, chemical burns, burns from flame, inhalation of toxic gases/vapors, struck-by container fragments, etc.) associated with unwanted byproducts of potential chemical reactions including the generation of heat, the generation of gases/vapors with hazardous properties, and the generation of pressure.

Issued

Apr 12, 2017

Abate by

May 5, 2017

Penalty

Initial $9,959 · Current $0 Reduced

General-duty citation text

29 CFR 1910.95(c)(1): The employer did not administer a continuing, effective hearing conservation program as described in 29 CFR 1910.9(c) through (o) whenever employee noise exposures equaled or exceeded an 8-hour time-weighted average sound level of 85 decibels measured on the A scale, or equivalently a dose of fifty percent:  (a)  On or about January 11, 2017 and times previous, in the tote wash area: The employer had not implemented a hearing conservation program for employees exposed to noise at or above an 8-hour TWA of 85 dBA. An employee sampled working in this area on January 11, 2017 was exposed to continuous noise at 67.21% or an equivalent sound level of 87.1 dBA during the 487 minutes sampled, exceeding the adjusted action level of 84.89 dBA

Issued

Apr 12, 2017

Abate by

May 5, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.95(d)(1): When information indicated that any employee's exposure equaled or exceed the 8-hour time-weighted average of 85 decibels, the employer did not develop and implement a monitoring program:  (a)  On or about January 11, 2017 and times previous throughout the facility: The employer failed to perform any noise monitoring at the facility to identify employees for inclusion in a hearing conservation program such as employees working in the tote wash area.  An employee sampled working in the tote wash area on January 11, 2017 was exposed to continuous noise at 67.21% or an equivalent sound level of 87.1 dBA during the 487 minutes sampled, exceeding the adjusted action level of 84.89 dBA.

Issued

Apr 12, 2017

Abate by

May 5, 2017

Penalty

Initial $0 · Current $0

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 equaled or exceeded an 8-hour time-weighted average of 85 decibels:   (a)  On or about January 11, 2017 and times previous, in the tote wash area: The employer failed to perform or implement audiometric testing for employees exposed to noise at or above an 8-hour TWA of 85 dBA. An employee sampled working in the tote wash area on January 11, 2017 was exposed to continuous noise at 67.21% or an equivalent sound level of 87.1 dBA during the 487 minutes sampled, exceeding the adjusted action level of 84.89 dBA.

Issued

Apr 12, 2017

Abate by

May 5, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.95(k)(1): The employer did not train each employee who was exposed to noise at or above an 8-hour time-weighted average of 85 decibels in accordance with the requirements of 29 CFR 1910.95(k). The employer did not institute a training program and ensure employee participation in the program:   (a)  On or about January 11, 2017 and times previous, in the tote wash area: The employer did not implement or perform training for employees exposed to noise at or above an 8-hour TWA of 85 dBA. An employee sampled working in the tote wash area on January 11, 2017 was exposed to continuous noise at 67.21% or an equivalent sound level of 87.1 dBA during the 487 minutes sampled, exceeding the adjusted action level of 84.89 dBA.

Issued

Apr 12, 2017

Abate by

May 5, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.95(l)(1): The employer did not make available to affected employees or their representatives copies of 29 CFR 1910.95 and did not post a copy in the workplace:  (a)  On or about January 11, 2017 and times previous, in the tote wash area: A copy of 29 CFR 1910.95 was not available or posted in the workplace to provide information to employees exposed to noise at or above an 8-hour TWA of 85 dBA. An employee sampled working in the tote wash area on January 11, 2017, was exposed to continuous noise at 67.21% or an equivalent sound level of 87.1 dBA during the 487 minutes sampled, exceeding the adjusted action level of 84.89 dBA.

Issued

Apr 12, 2017

Abate by

May 8, 2017

Penalty

Initial $9,959 · Current $0 Reduced

General-duty citation text

29 CFR 1910.120(q)(1): The employer did not develop and implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:   (a)  On or about February 13, 2017 and times previous, a written emergency response plan had not been developed and implemented at this location.  Employees performed containment and clean-up of hazardous chemical spills, including unknown chemicals, without protocols and procedures in place to distinguish incidental releases from emergency response situations.  Employees were also allowed back into the cut and scrape area without formal protocols and procedures in place to ensure that the work environment was safe following the release of unknown gases and vapors from unwanted chemical reactions occurring in common collection totes that resulted in the initial evacuation of employees out of the immediate work area.

Issued

Apr 12, 2017

Abate by

May 16, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.120(q)(6): The employer did not provide training in accordance with 29 CFR 1910.120(q)(6)(i) through (q)(6)(v) for employees who participated in or were expected to participate in emergency response:  (a)   On or about February 13, 2017 and times previous, emergency response operations training had not been provided to employees in the facility where employees were expected to participate in emergency responses.  Employees performed containment and clean-up of hazardous chemical spills, including unknown chemicals, without protocols and procedures in place to distinguish incidental releases from emergency response situations.  Employees were also allowed back into the cut and scrape area without formal protocols and procedures in place to ensure that the work environment was safe following the release of unknown gases and vapors from unwanted chemical reactions occurring in common collection totes that resulted in the initial evacuation of employees out of the immediate work area.

Issued

Apr 12, 2017

Penalty

Initial $12,675 · Current $0 Reduced

General-duty citation text

29 CFR 1910.1200(g)(8):   The employer did not maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and did not ensure that they were readily accessible during each work  shift to employees when they were in their work area(s):  (a)  On or about October 27, 2016, the employer had not obtained or maintained safety data sheets (SDS) for chemicals received, stored and utilized in the facility such as, but not limited to: acetone, acetylene, LP gas, caustics, adhesives, paints, lubricants and solvents.

Issued

Apr 12, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(c)(2)(i): Respirator users were not provided with the information contained in Appendix D to 29 CFR 1910.134 when the employer determined that any voluntary respirator use was permissible:   (a)  On or about October 27, 2016, documentation showing that employees had been informed or trained on appendix D of the respirator standard 29 CFR 1910.134, was not available regarding the disposable N-95 dust/mist respirators used on a voluntary basis at the facility.

Issued

Apr 12, 2017

Penalty

Initial $0 · Current $0

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 were acquired by employees:    (a)  On or about October 27, 2016, employees who performed service and maintenance on machinery and equipment such as, but not limited to, the baler and the horizontal band saw, had not received authorized employee level training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available, and the methods and measures necessary for energy isolation and control. Service and maintenance activities performed by employees included such tasks as, but not limited to, lubrication of the baler, horizontal band saw blade replacement, and horizontal band saw blade adjustment.