OSHA Inspection: VALOR TECHNOLOGIES, INC.

Issued

Dec 22, 2017

Abate by

Sep 12, 2019

Penalty

Initial $7,334 · Current $7,000 Reduced

Hazardous substances 1591C141

General-duty citation text

NOTE: Construction Reference: 1926.103  The requirements applicable to construction work under this section are identical to those set forth at � 1910.134 of this chapter.    29 CFR 1910.134(h)(2)(i): Respirators were not stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals or  were not packed or stored to prevent deformation of the facepiece and exhalation valve:     a) On July 6, 2017, the employer did not ensure that employee(s) wearing respiratory protection, stored their respirators in a manner that protected them from contamination and dust.        (1) Two Clemco Apollo 600 Series Supplied Air Respirators (SARs), issued for common use during lead removal activities, were stored on top of Axxiom Manufacturing Inc. abrasive blasting pots outside a lead containment located on the 2nd floor.  Wipe samples confirmed lead and cadmium contamination on the inside visor of the two SARs.      (2) A visibly contaminated North 7700 Series Silicone Half Mask Respirator was stored, in proximity to clean clothes of employees, inside the clean change area on the 3rd floor (located between the lunchroom and the shower area).  Wipe samples of the inside of the respirator confirmed lead and cadmium contamination.     In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Dec 22, 2017

Abate by

Sep 12, 2019

Penalty

Initial $7,334 · Current $0 Reduced

Hazardous substances 05601591C141

General-duty citation text

NOTE: Construction Reference: 1926.103  The requirements applicable to construction work under this section are identical to those set forth at � 1910.134 of this chapter.  29 CFR 1910.134(l)(1): Evaluations of the workplace were not conducted to ensure the written respiratory protection program was being effectively implemented:      a) On July 6, 2017 and on July 18, 2017, the employer did not evaluate the workplace conditions to ensure that the respiratory protection provisions were effectively implemented and continued to protect the employees:    (1) The employer did not evaluate the cleaning and storage of Clemco Apollo 600 Series Supplied Air Respirators (SARs) used by sandblasters, to ensure that they were cleaned and maintained free of lead and cadmium contamination.  On July 6, 2017, the contaminated SARs were stored on top of sandblasting equipment outside the lead containment enclosure on the 2nd floor.    (2) The employer did not evaluate the cleaning and storage of ½ mask respirators used by employees assigned to lead abatement tasks.  On July 6th, 2017, a lead and cadmium-contaminated North 7700 Series Silicone Half Mask Respirator was found in the clean change area on the 3rd floor.    (3) The employer did not evaluate the carbon monoxide (CO) monitors used on site to ensure that they alerted CO content higher than 10 parts per million (ppm).  On July 18th, 2017, the BW Technologies Gas Alert Clip Model GA-24XT-M CO detectors were found to be calibrated at 35 ppm.    In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Dec 22, 2017

Abate by

Sep 12, 2019

Penalty

Initial $7,334 · Current $7,000 Reduced

Hazardous substances 0560

General-duty citation text

NOTE: Construction Reference: 1926.103  The requirements applicable to construction work under this section are identical to those set forth at � 1910.134 of this chapter.    29 CFR 1910.134(i)(7): Oil lubricated compressor(s) used to supply breathing air did not have a high-temperature or carbon monoxide alarm(s) or both:  Note:  If only a high-temperature alarm is used, the air supply should be monitored to prevent carbon monoxide in the breathing air to exceed 10 ppm.    a) On July 18, 2017, the employer did not use a properly calibrated Carbon Monoxide (CO) detector to monitor the breathing air quality and alert to the presence of CO in excess of 10 parts per million (PPM) in the air supplied to Clemco Apollo 600 Series Supplied Air Respirators (SAR) used by employees during sandblasting activities.  The BW Technologies Gas Alert Clip Model GA-24XT-M CO detectors used by the employer were calibrated to alert at 35 ppm and were not a manufacturer-approved accessory for use with the Clemco SARs.    In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Dec 22, 2017

Abate by

Sep 12, 2019

Penalty

Initial $0 · Current $7,000

Hazardous substances 1591C141

General-duty citation text

NOTE: Construction Reference: 1926.103  The requirements applicable to construction work under this section are identical to those set forth at � 1910.134 of this chapter.    29 CFR 1910.134(k)(1)(v): The employer did not ensure that each user could demonstrate knowledge of the procedures for respirator maintenance and storage:    a) On July 6, 2017, the employer did not ensure that employee(s) demonstrated knowledge on respiratory protection procedures for cleaning, maintenance and storage:      (1) Clemco Apollo 600 Series Supplied Air Respirators (SARs) used by sandblasters, were not cleaned and maintained free of lead and cadmium contamination.  On July 6, 2017, these contaminated SARs were stored on top of sandblasting equipment outside the lead containment enclosure on the 2nd floor.    (2) On July 6th, 2017, a lead and cadmium-contaminated North 7700 Series Silicone Half Mask Respirator was found in the clean change area on the 3rd floor in proximity to employees' street clothes.    In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Dec 22, 2017

Penalty

Initial $7,334 · Current $3,500 Reduced

Hazardous substances 0260

General-duty citation text

NOTE: Construction Reference: 1926.1118  The requirements applicable to construction work under this section are identical to those set forth at � 1910.1018 of this chapter.    29 CFR 1910.1018(e)(2): Initial monitoring was not performed for each workplace, or work operation covered by 29 CFR 1910.1018 to accurately determine the airborne concentration of inorganic arsenic to which employees may be exposed:     a) On July 6, 2017, the employer did not determine the airborne concentration of inorganic arsenic (via personal air monitoring) to which its employee(s) were exposed.  Employee(s) were exposed to arsenic when conducting lead-based paint abatement via manual scraping or sandblasting methods.  Air monitoring conducted on August 22, 2017, indicated that abatement workers, were exposed to an 8-hour time weighted average level of arsenic up to  0.0003 mg/m3.      No abatement certification or documentation is required for this item.

Issued

Dec 22, 2017

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR 1926.1127(d)(2)(i): The employer failed to conduct exposure monitoring as soon as practicable that was representative of the exposure for each employee in the workplace who was or potentially was exposed to cadmium at or above the action level:    a) On July 6, 2017, the employer did not perform an initial determination to assess the presence of cadmium in the workplace and to evaluate the possibility of employee exposure at or above the action level.  Employee(s) were exposed to cadmium when conducting lead-based paint abatement via manual scraping or sandblasting methods.  Air monitoring conducted on August 22, 2017, indicated that abatement workers, were exposed to an 8-hour time weighted average level of cadmium up to 0.0004 mg/m3.      No abatement certification or documentation is required for this item.

Issued

Dec 22, 2017

Abate by

Sep 12, 2019

Penalty

Initial $0 · Current $3,500

Hazardous substances 0260

General-duty citation text

NOTE: Construction Reference: 1926.1118  The requirements applicable to construction work under this section are identical to those set forth at � 1910.1018 of this chapter.    29 CFR 1910.1018(o)(1)(ii): Training was not provided for employee(s) at the time of initial assignment to an area where employees are subject to inorganic arsenic exposure above the action level, or for whom there is a possibility of skin or eye irritation from inorganic arsenic:     a) On July 6, 2017, the employer did not provide information on arsenic to each affected employee, covering the elements listed in paragraphs (A) through (F) of this section.  Worker(s) did not receive information on arsenic, including but not limited to the quantity, location, manner of use and nature of operations that could result in arsenic exposure; the use and limitations of respirators; the applicable engineering controls and work practices.  Employee(s) were exposed to arsenic when conducting lead-based paint abatement via manual scraping or sandblasting methods.  Air monitoring conducted on August, 22 2017, indicated that abatement workers, were exposed to an 8-hour time weighted average level of arsenic up to  0.0003 mg/m3.      In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Dec 22, 2017

Abate by

Sep 12, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 0260

General-duty citation text

NOTE: Construction Reference: 1926.1118 The requirements applicable to construction work under this section are identical to those set forth at � 1910.1018 of this chapter.    29 CFR 1910.1018(p)(1)(ii): The employer did not communicate to employee(s) the hazards of inorganic arsenic, addressing at least the following: cancer; liver effects; skin effects; respiratory irritation; nervous system effects; and acute toxicity effects.    a) On July 6, 2017, the employer did not provide employees with training and information which addressed the health hazards of inorganic arsenic, including but not limited to cancer and adverse health effects to liver, dermal, respiratory and nervous systems as well as acute toxicity effects.  Employee(s) were exposed to arsenic when conducting lead-based paint abatement via manual scraping or sandblasting methods.  Air monitoring conducted on  August 22, 2017, indicated that abatement workers, were exposed to an 8-hour time weighted average level of arsenic up to  0.0003 mg/m3.      In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Dec 22, 2017

Abate by

Sep 12, 2019

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR 1926.1127(m)(1): The employer did not provide information to employee(s) on at least the following Cadmium hazards: cancer; lung effects; kidney effects; and acute toxicity effects.    a) On July 6, 2017, the employer did not provide employees with training and information which addressed the health hazards of cadmium, including but not limited to cancer and adverse effects to renal and respiratory systems as well as acute toxicity effects.  Employee(s) were exposed to cadmium when conducting lead-based paint abatement via manual scraping or sandblasting methods.  Air monitoring conducted on August 22, 2017, indicated that abatement workers, were exposed to an 8-hour time weighted average level of cadmium up to 0.0004 mg/m3.     In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Dec 22, 2017

Abate by

Sep 12, 2019

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR 1926.1127(m)(4)(iii): The employer did not ensure that each employee was informed of elements listed in paragraphs (A) through (H) of this section:    a) On July 6, 2017, the employer did not provide information and training regarding Cadmium, covering the elements listed in paragraphs (A) through (H) of this section; including but not limited to the quantity, location, and nature of operations that could result in cadmium exposure; applicable engineering controls and work practices; specific measures to protect against exposures; aspects of respiratory protection; the medical surveillance program and access to related records.  Employee(s) were exposed to cadmium when conducting lead-based paint abatement via manual scraping or sandblasting methods.  Air monitoring conducted on August, 22, 2017, indicated that abatement workers, were exposed to an 8-hour time weighted average level of cadmium up to 0.0004 mg/m3.     In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Dec 22, 2017

Abate by

Sep 12, 2019

Penalty

Initial $4,400 · Current $3,500 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(i)(4)(ii): The employer did not ensure that lunchroom facilities or eating areas were as free as practicable from lead contamination:    a) On July 6, 2017 and July 10, 2017, the employer did not ensure that the joint-use 3rd floor lunchroom was as free as practicable of lead contamination.  Samples collected in the lunchroom area revealed lead contamination of up to 13.32 µg on the microwave keypad(s) and up to 24.29 µg on the common-use beverage cooler.       In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Dec 22, 2017

Abate by

Sep 12, 2019

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR 1926.1127(k)(1): All surfaces were not maintained as free as practical of accumulations of cadmium:(a)(LOCATION)(SPECIFIC OPERATIONS AND/OR CONDITIONS)    a) On July 6, 2017 and July 10, 2017, the employer did not ensure that the joint-use 3rd floor lunchroom was as free as practicable of cadmium contamination.  Samples collected in the lunchroom area revealed cadmium contamination of up to 0.4 µg on the common-use beverage cooler.        In accordance with 29 CFR 1903.19(c), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET).

Issued

Dec 22, 2017

Penalty

Initial $7,334 · Current $7,000 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(j)(1)(i): The employer did not make available initial medical surveillance, consisting of biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels, to employees occupationally exposed on any day to lead at or above the action level:    a) On July 6, 2017, the employer did not make available initial medical surveillance in the form of blood sampling and analysis for lead and zinc protoporphyrin when employees were exposed to lead at or above the action level when performing lead abatement tasks, using manual scraping or sandblasting methods. Employees received their initial monitoring weeks or months after their first assignment to the Old Main Post Office worksite.     1) An employee assigned to the worksite on May 17, 2017, was not provided biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels until July 8, 2017, approximately 7 weeks after initial assignment.     2) An employee assigned to the worksite May 1st, 2017, was not provided biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels until July 8, 2017, approximately 9 weeks after initial assignment.      3) An employee was assigned to the worksite on October 12, 2016, was not provided biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels until July 11, 2017, approximately 9 months after initial assignment.      No abatement certification or documentation required for this item.

Issued

Dec 22, 2017

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(j)(2)(i)(A): The employer did not make available biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels to each employee covered under 29 CFR 1926.62(j)(1)(ii), at least every 2 months for the first 6 months and every 6 months thereafter:  a) on July 6, 2017, the employer did not ensure that employees exposed to lead at or above the action level, when performing lead abatement tasks using manual scraping or sandblasting methods, received biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin at least every 2 months for the first 6 months and every 6 months thereafter.        1) An employee assigned to the worksite on December 27th, 2016, did not receive follow-up biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels  every 2 months for the first 6 months and every 6 months thereafter.  The employee was provided follow-up biological monitoring on July 11, 2017, approximately 10 months after initial testing.    2) An employee assigned to the worksite on January 19, 2017, did not receive follow-up biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels  every 2 months for the first 6 months and every 6 months thereafter.  The employee was provided follow-up biological monitoring on July 11, 2017.    3) An employee assigned to the worksite on October 12, 2016, did not receive follow-up biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels  every 2 months for the first 6 months and every 6 months thereafter.  The employee was provided follow-up biological monitoring on July 11, 2017, approximately 9 months after initial testing.  No abatement certification or documentation required for this item.

Issued

Dec 22, 2017

Abate by

Sep 12, 2019

Penalty

Initial $4,400 · Current $3,500 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(n)(1)(ii): 29 CFR 1926.62(n)(1)(ii): The employer did not include on the employee exposure monitoring records the information listed in paragraphs (A) through (E) of this section.      a) On July 6, 2017, the employer did not ensure that exposure monitoring records contained information, including but not limited to the type of respiratory protection; the names of all employees monitored or for whom the exposure measurement is intended to represent, and any environmental variables that could affect the exposure assessment.    In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the CERTIFICATION OF CORRECTIVE ACTION WORKSHEET)