OSHA Inspection: CONTAINER LIFE CYCLE MANAGEMENT, LLC

Issued

Jan 19, 2018

Penalty

Initial $6,912 · Current $5,184 Reduced

Hazardous substances 1290

General-duty citation text

29 CFR 1910.1048(n)(1):  The employer shall assure that all employees who are assigned to workplaces where there is exposure to formaldehyde participate in a training program, except that where the employer can show, using objective data, that employees are not exposed to formaldehyde at or above 0.1 ppm, the employer is not required to provide training:    The employer did not assure that all employees assigned to workplaces where there were exposures to formaldehyde above 0.1 ppm participated in a formaldehyde training program when:    a)  At the Poly Line Bung Removal, a Bung Removal employee was exposed to formaldehyde at a level of 0.48 ppm as an 8-hour TWA on September 12, 2017. This exposure was determined by air sampling conducted over 463 minutes during one shift with zero exposure being assumed for the unsampled 17 minutes of an 8-hour work shift.    b)  At the Steel Inspection, an Inspection employee was exposed to formaldehyde at a level of 0.29 ppm as an 8-hour TWA on September 12, 2017. This exposure was determined by air sampling conducted over 464 minutes during one shift with zero exposure being assumed for the unsampled 16 minutes of an 8-hour work shift.    All provisions of 29 CFR 1910.1048 (n)(3)(i) through (n)(3)(vii) must be covered in a formaldehyde training program. Key elements include, but are not limited to the following:    1)  Contents of SDS  2)  Description of potential health hazards  3)  Operations where formaldehyde is present  4)  Purpose, use and limitations of PPE  5)  Importance of engineering controls and work practices  6)  Emergency procedures

Issued

Jan 19, 2018

Penalty

Initial $8,638 · Current $6,479 Reduced

General-duty citation text

29 CFR 1910.1200(h)(1):  Employers shall 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 the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets:    On or about August 3, 2017, the employer did not provide employees with effective information and training on the hazardous chemicals in their work area. Employees who spoke Spanish as their first language did not receive training in a language that they understood and were therefore not effectively trained in the requirements of this section.    All provisions of 29 CFR 1910.1200(h)(1) through (h)(3) must be covered in hazard communication training. Key elements include, but are not limited to the following:    1)  Requirements of this section  2)  Location of SDS and Hazard Communication Program  3)  Hazard of chemicals in work areas  4)  Measures to protect from hazards of chemicals

Issued

Jan 19, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h)(2)(iii):  Employees shall be informed of the location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and safety data sheets required by this section:  On or about August 3, 2017, the employer did not inform employees of the location and availability of the safety data sheets. Employees who spoke Spanish as their first language did not receive training in a language that they understood and were therefore unaware of the location of the SDS.

Issued

Jan 19, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h)(3)(ii):  Employee training shall include the physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area:  On or about August 3, 2017, the employer did not provide employees with effective information and training on the hazardous chemicals in their work area. The employer did not provide employees with information and training on the health hazards associated with exposure to mercury.

Issued

Jan 19, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h)(3)(iii): Employee training shall including the measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used:  On or about August 3, 2017, the employer did not provide employees with effective information and training on the hazardous chemicals in their work area. The employer did not provide employees with information and training on the measures employees could take to protect themselves from mercury exposure.