OSHA Inspection: COOPER STANDARD AUTOMOTIVE INC.

Issued

Apr 17, 2018

Abate by

Jun 4, 2018

Penalty

Initial $12,675 · Current $7,665 Reduced

Hazardous substances 04600760129020402440

General-duty citation text

29 CFR 1910.132(d): Hazard assessment and equipment selection.      29 CFR 1910.132(d)(1): The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:    29 CFR 1910.132(d)(1)(i): Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;    On or about December 11, 2017, the employer did not assure the use of the personal protective equipment selected by the employer's hazard assessment  for Mill Line operators performing tasks, such as but not limited to, viscosity testing in the "Primer booth" areas. Employees, such as the Mill Line 3 operator, performed this task without the required use of face shields for the eyes and face, goggles for eye protection or protective equipment for the arms for skin protection. "Nylon Primer" was a hazardous chemical contained in the "Primer booth" tank and the manufacturer identified this chemical with a skin corrosivity classification of 1A and an eye corrosivity of 1.

Issued

Apr 17, 2018

Abate by

May 21, 2018

Penalty

Initial $10,163 · Current $0 Reduced

Hazardous substances 1290

General-duty citation text

29 CFR 1910.1048(d): Exposure monitoring -     29 CFR 1910.1048(d)(2): Initial monitoring. The employer shall identify all employees who may be exposed at or above the action level or at or above the STEL and accurately determine the exposure of each employee so identified.    On or about December 11, 2017, the employer failed to perform employee exposure monitoring for formaldehyde for "Mill" employees with workplace exposure from required activities, such as but not limited to, viscosity testing in the "Primer booth" area. Employees, such as the Mill 3 operator, performed this task without having 8-hour time weighted average permissible exposure limit or short term exposure limit (STEL) representative sampling performed by the employer to determine exposure levels. Formaldehyde was a component of a material known as "Nylon Primer" in the manufacturing/coating process.

Issued

Apr 17, 2018

Abate by

Jun 4, 2018

Penalty

Initial $10,163 · Current $6,098 Reduced

Hazardous substances 1290

General-duty citation text

29 CFR 1910.1048(m)(1): Hazard communication--General.    29 CFR 1910.1048(m)(1)(iii): Employers shall include formaldehyde in the hazard communication program established to comply with the HCS (� 1910.1200). Employers shall ensure that each employee has access to labels on containers of formaldehyde and to safety data sheets, and is trained in accordance with the requirements of HCS and paragraph (n) of this section.    On or about December 11, 2017, the employer had not ensured containers of formaldehyde, such as the "Primer booth" tanks in the Mill department Mill Lines, were labeled according to the GHS hazard communication standard requirements. The "Primer booth" tanks on the Mill lines contained "Nylon Primer" which included formaldehyde as a hazardous ingredient. Formaldehyde hazard information included signal words, specific hazard pictograms , hazard statements and precautionary statements for the health hazards associated with potential formaldehyde exposure that include, but were not limited to, carcinogenicity, target organ toxicity, skin corrosivity and eye corrosivity.

Issued

Apr 17, 2018

Abate by

Jun 4, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 1290

General-duty citation text

29 CFR 1910.1048(m)(2)(ii): As a minimum, for all materials listed in paragraph (m)(1)(i) and (iv) of this section capable of releasing formaldehyde at levels of 0.1 ppm to 0.5 ppm, labels shall identify that the product contains formaldehyde; list the name and address of the responsible party; and state that physical and health hazard information is readily available from the employer and from safety data sheets.    On or about December 11, 2017, the employer had not ensured containers of formaldehyde, such as the "Primer booth" tanks in the Mill department Mill Lines, were labeled according to the OSHA formaldehyde standard requirements. The "Primer booth" tanks on the Mill lines contained "Nylon Primer" which included formaldehyde as a hazardous ingredient but were not marked to identify the formaldehyde contents.

Issued

Apr 17, 2018

Abate by

Jun 4, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 04600760129020402440

General-duty citation text

29 CFR 1910.1200(f) Labels and other forms of warning--    29 CFR 1910.1200(f)(6): Workplace labeling. Except as provided in paragraphs (f)(7) and (f)(8) of this section, the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with either:    29 CFR 1910.1200(f)(6)(ii): Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.    On or about December 11, 2017, the employer failed to ensure the "Primer booth" tanks on the Mill lines were labeled with the hazard information required by this part. The "Primer booth" tanks, including but not limited to the Mill line 3 tank, contained "Nylon Primer." "Nylon Primer" contained formaldehyde, cresol, phenol, n-butyl alcohol, PGMEA and titanium dioxide. The safety data sheet provided by the manufacturer of "Nylon Primer" included seven hazard statements, 27 precautionary statements, a signal word and four pictograms in addition to the GHS ratings. Formaldehyde and titanium dioxide were components of "Nylon Primer" listed as carcinogens.

Issued

Apr 17, 2018

Abate by

Jun 4, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 04600760129020402440

General-duty citation text

29 CFR 1910.1200(f) Labels and other forms of warning--    29 CFR 1910.1200(f)(7): The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(6) of this section to be on a label. The employer shall ensure the written materials are readily accessible to the employees in their work area throughout each work shift.    On or about December 11, 2017, the employer failed to ensure the "Primer booth" tanks on the Mill lines were labeled with the hazard information required by this part. Additionally the employer did not use alternative written materials such as signs, placards, batch tickets, process sheets or operating procedures to identify the "Primer booth" tanks hazard information in the work area throughout each shift. The "Primer booth" tanks, including but not limited to the Mill line 3 tank, contained "Nylon Primer." "Nylon Primer" contained formaldehyde, cresol, phenol, n-butyl alcohol, PGMEA and titanium dioxide. The safety data sheet provided by the manufacturer of "Nylon Primer" included seven hazard statements, 27 precautionary statements, a signal word and four pictograms in addition to the GHS ratings. Formaldehyde and titanium dioxide were components of "Nylon Primer" listed as carcinogens.

Issued

Apr 17, 2018

Abate by

May 21, 2018

Penalty

Initial $10,163 · Current $6,098 Reduced

Hazardous substances 1290

General-duty citation text

29 CFR 1910.1048(n): Employee information and training  29 CFR 1910.1048(n)(3): Training program. The training program shall be conducted in a manner which the employee is able to understand and shall include the elements and content contained in 29 CFR 1910.1048(n)(3)(i) through 29 CFR 1910.1048(n)(3)(vii).  On or about December 11, 2017, the employer did not develop a formaldehyde training program and conduct for employees in the Mill department with exposure to formaldehyde during daily coating and mill line operations. Operators performing viscosity testing of "Primer booth" tanks that contain "Nylon Primer." "Nylon Primer" was a hazardous chemical that contained formaldehyde.