OSHA Inspection: SCOT CHRISTOPHER RULE LLC

Issued

Mar 28, 2018

Penalty

Initial $3,880 · Current $1,940 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(d)(1)(i): Each employer who had a workplace or operation covered by 29 CFR 1926.62 did not initially determine if any employee was exposed to lead at or above the action level of 30 micrograms per cubic meter of air (30 ug/m3) calculated as an 8-hour time-weighted average (TWA):  a) Building L, Rooms 218 through 221: Employees were manually scraping lead paint from the exterior walls and beams and the employer did not make an initial determination of the employees exposure to lead, on or about November 28, 2017.  No abatement certification or documentation required.

Issued

Mar 28, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(d)(2)(i): Until the employer performed an employee exposure assessment, as required in 29 CFR 1926.62(d), and documented that the employee(s) performing any of the listed tasks was not exposed above the Permissible Exposure Limit (PEL), the employer did not treat affected employee(s) as if they were exposed above the PEL, and not in excess of ten times the PEL, and did not implement employee protective measures prescribed in 29 CFR 1926.62(d)(2)(v):  a) Building L, Rooms 218 through 221: Employees were manually scraping lead paint from the exterior walls and beams and the employer did not implement interim employee protective measures as described in 29 CFR 1926.62(d)(2)(v) when the employees were assumed to be exposed above the PEL, on or about November 28, 2017.  No abatement certification or documentation required.

Issued

Mar 28, 2018

Abate by

Jun 15, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(e)(2)(i): The employer did not establish and implement a written compliance program to achieve compliance with 29 CFR 1926.62(c) prior to commencement of the job:    a) Building L, Rooms 218 through 220: Employees were assumed to be exposed to lead at levels greater than the permissible exposure limits while manually scraping lead paint off the exterior walls and beams and the employer did not establish a written compliance program, on or about November 28, 2017.     Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement.  Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photograph or video evidence of abatement or other written records.

Issued

Mar 28, 2018

Penalty

Initial $3,880 · Current $1,940 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(f)(1)(iv): Respirators were not used during periods when respirators were required to provide interim protection for employees while they performed the operations specified in 29 CFR 1926.62(d)(2):  a) Building L Rooms 218 through 221: Employees were manually scraping lead paint from the exterior walls and beams and the employer did not ensure employees were wearing appropriate respirators, on or about November 28, 2017.  No abatement certification or documentation required.

Issued

Mar 28, 2018

Abate by

Jun 15, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.134(c)(1): A written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented for required respirator use: (Construction Reference 1926.103)     a) Building L, Rooms 218 through 221: Employees were required to wear 3M N95 respirators while manually scraping lead paint from the exterior walls and beams and the employer did not establish a Respiratory Protection Program, on or about November 28, 2017.    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 28, 2018

Abate by

Jun 15, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.134(f)(2): Employee(s) using tight-fitting facepiece respirators were not fit tested prior to initial use of the respirator: (Construction Reference 1926.103)     a) Building L, Rooms 218 through 221: Employees were required to wear 3M N95 respirators while manually scraping lead paint from the exterior walls and beams and the employer did not provide the employees with a fit test, on or about November 28, 2017.    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 28, 2018

Abate by

Jun 15, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.134(k)(1): The employer did not provide respirator training that ensured that each employee could demonstrate knowledge of at least the following elements: Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator; What the limitations and capabilities of the respirator are; How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions; How to inspect, put on and remove, use, and check the seals of the respirator; What the procedures are for maintenance and storage of the respirator; and How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators:    a) Building L, Rooms 218 through 221: Employees were required to wear 3M N95 respirators while manually scraping lead paint from the exterior walls and beams and the employer did not provide employees with information about how to inspect, check the seals of the respirator, proper maintenance and storage of the respirator, and how to recognize medical signs and symptoms that may prevent the effective use of respirators, on or about November 28, 2017.    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 28, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(g)(1): Where employees were exposed to lead above the permissible exposure limit, without regard to the use of respirators; where employees were exposed to lead compounds which may cause skin or eye irritation (e.g. lead arsenate, lead azide); and as interim protection for employees performing tasks as specified in 29 CFR 1926.62(d)(2), the employer did not ensure that each employee used appropriate protective work clothing and equipment that prevented contamination of the employee and the employee's garments:  a) Building L, Rooms 218 through 221: Employees manually scraping lead paint from the exterior walls and beams were required to have interim protections and the employer did not ensure that each employee wore appropriate protective work clothing and equipment, on or about November 28, 2017.  No abatement certification or documentation required.

Issued

Mar 28, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(i)(2)(i): The employer did not provide clean change areas as an interim protection for employees performing tasks as specified in 29 CFR 1926.62(d)(2), without regard to the use of respirators:   a) Building L, Rooms 218 through 221: Employees manually scraping lead paint from the exterior walls and beams were required to have interim protections and the employer did not provide employees with change rooms, on or about November 28, 2017.   No abatement certification or documentation required.

Issued

Mar 28, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(h)(1): All surfaces were not maintained as free as practicable of accumulations of lead:   a) Building L Room 218: Employees were manually scraping lead paint from the exterior walls and beams and lead paint chips were present on the tops of electrical outlets and windowsills, on or about November 28, 2017.    b) Building L Room 220: Employees were manually scraping lead paint from the exterior walls and beams and lead dust and paint chips were present on the windowsills and the floor, on or about November 28, 2017.    c) Building L Room 221: Employees were manually scraping lead paint from the exterior walls and beams and lead dust and paint chips were present on the floors, on or about November 28, 2017.  No abatement certification or documentation required.

Issued

Mar 28, 2018

Abate by

Jun 15, 2018

Penalty

Initial $3,880 · Current $1,940 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) Building L, Rooms 218 thourgh 221: Employees assumed to be exposed to lead at levels greater than the permissible exposure limit while manually scraping lead paint were not provided initial medical surveillance, on or about November 28, 2017.    Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement.  Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photograph or video evidence of abatement or other written records.

Issued

Mar 28, 2018

Abate by

Jun 15, 2018

Penalty

Initial $3,880 · Current $1,940 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(l)(1)(i): The employer did not ensure that at least the following Lead hazards were communicated to employee(s): reproductive/developmental toxicity; central nervous system effects; kidney effects; blood effects; and acute toxicity effects.    a) Building L, Rooms 218 through 221: Employees were manually scraping lead paint from the exterior walls and beams and employees were not effectively provided the information on the hazards of lead, on or about November 28, 2017.     Abatement certification and documentation required within 10 days after abatement date. The certification shall include a statement that abatement is complete, the date and method of abatement, and state that employees and their representatives were informed of this abatement.  Abatement documentation shall include documents demonstrating that abatement is complete, such as evidence of the purchase or repair of equipment, photograph or video evidence of abatement or other written records.

Issued

Mar 28, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(m)(2)(i): The employer did not post the following warning signs in each work area where an employee exposure to lead was above the permissible exposure limit:   a) Building L, Rooms 218 through 221: Employees were manually scraping lead paint from the exterior walls and beams and a sign warning of exposure to lead was not posted, on or about November 28, 2017.  No abatement certification or documentation required.

Issued

Mar 28, 2018

Abate by

Jun 15, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

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: (Construction Reference: 1926.59):     a) Building L, Rooms 218 through 221: Employees were manually scraping lead paint from the exterior walls and beams and using Sherwin Williams ProBlock Primer to seal the walls. The employer did not have a written hazard communication program, on or about November 28, 2017.    Abatement certification required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 28, 2018

Abate by

Jun 15, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(g)(1): The employer did not have a material safety data sheet for each hazardous chemical which they used: (Construction Reference: 1926.59)    a) Building L, Rooms 220: Employees were using Sherwin Williams ProBlock Primer to seal the walls and exposed to lead during paint removal.  The employer did not have safety data sheets available for employees, on or about November 28, 2017.    Abatement certification required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 28, 2018

Abate by

Jun 15, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.1200(h)(1): Employees were not provided effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard that the employees had not been previously trained about was introduced into their work area: (Construction Reference: 1926.59)     a) Building L, Rooms 218 through 221: Employees were manually scraping lead paint from the exterior walls and beams and using Sherwin Williams ProBlock Primer to seal the walls. The employer did not provide employees with training on the hazard communication program, hazards of chemicals used, and the information on the safety data sheets, on or about November 28, 2017.     Abatement certification required within 10 days after abatement date.  The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.