OSHA Inspection: AMERICAN POWDER COATINGS, INC.

Issued

Sep 27, 2017

Abate by

Nov 17, 2017

Penalty

Initial $3,802 · Current $2,000 Reduced

Hazardous substances 04309130

General-duty citation text

29 CFR 1910.134(c)(1): Where employee use of respiratory protection is required, the employer must develop and implement a written respiratory protection program that includes the provisions in 29 CFR 1910.134(c)(1)(i)-(ix).    On or about March 27, 2017, employees were exposed to respiratory stressors when required to wear a 3M half-mask, tight fitting respirators and ULINE filtering facepieces (dust mask) while performing parts cleaning with MEK and while working in dusty areas containing powder coating mixtures (paint). The employer did not develop and implement a written respiratory program that included medical evaluations, annual fit testing, and training.       Abatement certification is required of this item in accordance with the requirements of 29 CFR 1903.19(c).

Issued

Sep 27, 2017

Abate by

Jun 1, 2018

Penalty

Initial $6,338 · Current $3,000 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 March 27, 2017, employees were exposed to amputation hazards while performing cleaning, servicing and maintenancing on Grinders/Mills and Extruders and the employer did not develop and/or document adequate procedures for the control of hazardous energy when employees were assigned servicing, cleaning, and maintenancing tasks.       Abatement certification is required of this item in accordance with the requirements of 29 CFR 1903.19(c).

Issued

Sep 27, 2017

Abate by

Jun 1, 2018

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 are acquired by employees.  On or about March 27, 2017, employees were exposed to amputation hazards while cleaning, servicing, and performing repairs on Grinders/Mill and Extruders. The employer did not ensure that training was provided to all authorized and affected employees who were assigned such tasks to ensure the purpose and function and energy control program was understood by employees and that the knowledge and skills required for the safe application, usage and removal of energy controls were acquired by employees.       Abatement certification is required of this item in accordance with the requirements of 29 CFR 1903.19(c).

Issued

Sep 27, 2017

Abate by

Jun 1, 2018

Penalty

Initial $8,873 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.147(d): The established procedure for the application of energy control (the lockout or tagout procedures) did not cover the actions listed in and was not done in sequence as required by 29 CFR 1910.147(d)(1)-(6).    On or about March 27, 2017, employees were exposed to amputation hazards while cleaning, servicing and performing repairs on Grinders/Mills and Extruders.  The employees were not required to apply energy controls and perform the following sequence prior to starting work:     (a) prepare for shut down by recognizing energy hazards and its controls,  (b) turn off and shut down the machines,  (c) physically locate and operate energy isolating devices in such a manner as to isolate the machine or equipment from the energy source,  (d) affix lockout or tagout devices to each energy isolating device,  (e) render safe all potentially hazardous stored or residual energy,  (f) verify that isolation and deenergization of the machine or equipment have been accomplished.    Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).

Issued

Sep 27, 2017

Abate by

Nov 17, 2017

Penalty

Initial $3,802 · Current $2,000 Reduced

Hazardous substances 04309130M102M103

General-duty citation text

29 CFR 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met.    On or about March 27, 2017, employees were exposed to respiratory and skin irritants while working with powder coating paints and cleaning machine parts with MEK and the employer did not develop, implement and/maintain a written hazard communication program.        Abatement certification is required of this item in accordance with the requirements of 29 CFR 1903.19(c).

Issued

Sep 27, 2017

Abate by

Jun 1, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 04309130E200M102M104

General-duty citation text

29 CFR 1910.1200(h)(1): The employer did not provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard that the employees had not previously been trained about was introduced into their work area. Information and training was not designed to cover all applicable categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals.   On or about March 27, 2017, employees were exposed to respiratory and skin irritants while working with powder coating paint and cleaning machine parts with MEK and the employer did not provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment.    Abatement certification is required of this item in accordance with the requirements of 29 CFR 1903.19(c).

Issued

Sep 27, 2017

Abate by

Aug 1, 2018

Penalty

Initial $6,338 · Current $4,000 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 was free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees inside and outside of the facility were exposed to potential combustible powder coating dust explosion, deflagration, and other fire hazards resulting from any internal dust collector deflagration or fire event within one of the six outdoor dust collectors:       On or about March 27, 2017, the following deficiencies were noted on the outdoor dust collectors responsible for collecting a combustible powder coating dust:      a)  The Torit and Dust Hog cartridge filter collectors lacked a means of 1) explosion protection and 2) deflagration propagation protection (isolation) for upstream and downstream processes /workstations and the discharge drums.  The two dust collectors also returned exhaust air directly back into the building without a means to prevent the transmission of hazardous byproducts of a fire (smoke, toxic gases, flame, embers, etc.) back into the facility.       b) Baghouse filter collectors #1, #2, #3, and #4 lacked documented means of explosion protection so as to ensure that each vent area was sufficient to prevent deflagration pressure from exceeding the enclosure strength.  The deflagration venting provided also discharged directly to potentially occupied areas.  In addition, a means of deflagration propagation protection (isolation) protection for upstream processes/workstations was not provided.       (c) Non-conductive flex hose was used dust collection systems.      In the event of an internal deflagration within any of the dust collectors and the venting area is insufficient, any employees outside of the building and in proximity to the dust collectors may be exposed to explosion hazards resulting from vessel failure from over pressurization such as a resulting pressure wave, expanding flame front (fire ball), and missile fragments.       In the event of an internal deflagration within any of the dust collectors and the venting area is sufficient, any employees outside of the building and in proximity to the dust collectors may be exposed to burn hazards from the vented fire ball.      In the event of an internal deflagration within any of the  dust collectors, employees both inside and outside of the building may be exposed to propagating flame front hazards (such as through dirty air inlet ducting, return air exhaust ducting, and/or the material discharge opening of the collector itself).        In the event of an internal fire within the Torit and Dust Hog dust collectors, employees inside of the building may be exposed to the hazardous byproducts of an internal fire such as smoke, toxic gases, embers, and flames.      Abatement documentation is required for this item in accordance with the requirements of 29 CFR 1903.19(d).      Among other methods, feasible methods to correct this hazard would be to follow the applicable sections of the following National Fire Protection Association (NFPA) Standards:   Standard 654 ?Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids?, 2017 ed. Sections 7.1.4.1(2) (explosion venting design), 7.1.6 (equipment isolation), 7.13.1.2 (equipment protection) , 7.13.1.6 (clean air exhaust) , 7.6 (conductive duct work and allowable use of flex hose), and  9.3.2.1 (conductive components)   Standard 68 ?Explosion Protection by Deflagration?, 2013 ed. Section 5.2.3 (deflagration vent discharge), 6.6.1 (deflagration consequences), 8.9 (fire ball dimension), and 11.2 (explosion venting design parameters and documentation).   Standard 69 ?Standard Explosion Prevention Systems?, 2014 ed. Sections 11.1.3 (active isolation techniques), 12.2 (passive isolation techniques), and 15.2.1.1 (explosion isolation design parameters and documentation).     Specifically, these methods may include, but are not limited to the following:

Issued

Sep 27, 2017

Penalty

Initial $1,268 · Current $1,000 Reduced

General-duty citation text

29 CFR 1904.29(a): A log of all Work-Related Injury and Illnesses (OSHA Form 300), and/or the Summary of Work-Related Injury and Illnesses, (OSHA Form 300-A), and/or the Injury and Illness Report (OSHA Form 301) or equivalent forms were not kept by the establishment.    On or about March 27, 2017, the employer did not maintain OSHA 300 logs, OSHA 300A summaries, and Incident Reports (OSHA 301s or equivalent) for work-related injuries and illnesses that occurred within the past three years.        There is no abatement certification or documentation required for this item.

Issued

Sep 27, 2017

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1904.32(a)(4): At the end of each calendar year, the employer did not post the annual summary of injuries and illnesses from February 1 to April 30.     On or about March 27, 2017, the employer did not post the annual summary of injuries and illnesses that occurred in the calendar year 2016, between February 1st and April 30th of the following year (2017).      There is no abatement certification or documentation required for this item.