OSHA Inspection: TSV ADHESIVE SYSTEMS LLC

Issued

Jul 25, 2018

Abate by

Aug 6, 2018

Penalty

Initial $12,934 · Current $8,000 Reduced

General-duty citation text

29 CFR 1910.106(e)(6)(i): Adequate precautions were not taken to prevent the ignition of flammable vapors:    a.   On or about January 31, 2018 through February 16, 2018, in the production room, employees transferred Category 2 flammable liquids, including methyl methacrylate (MMA), at temperatures elevated above the flash point of the materials, without means to prevent the accumulation (and subsequent discharge) of static electric charge from the operators such as through conductive or static dissipative flooring and footwear, personnel-grounding devices, and/or antistatic or conductive clothing.

Issued

Jul 25, 2018

Abate by

Aug 6, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.106(e)(6)(ii): Class I flammable liquid(s) were dispensed into containers without electrically interconnecting the nozzle and the container:    a.  On or about January 31, 2018 through February 16, 2018, in the production room, employees transferred Category 2 flammable liquids, including methyl methacrylate (MMA), at temperatures elevated above the flash point of the materials from metal mixing containers and into plastic pails.  The flammable liquids were not transferred in a manner during which the two vessels were interconnected due to the non-conductive nature of the plastic pails and subsequent lack of bonding.

Issued

Jul 25, 2018

Abate by

Jul 31, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.106(e)(7)(i)(a): All electrical wiring and equipment was not installed according to the requirements of Subpart S of this part:  a.  On or about January 31, 2018 through February 16, 2018, in the production room, two Patterson 30 H30B-CS high velocity fans were used where flammable vapors were present and were not intrinsically safe, approved for a Class I hazardous location, or safe for a Class I hazardous location.

Issued

Jul 25, 2018

Abate by

Jul 31, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.307(c): Equipment, wiring methods, and installations of equipment in hazardous (classified) locations were not intrinsically safe, approved for the hazardous (classified) location, or safe for the hazardous (classified) location:  a.  On or about January 31, 2018 through February 16, 2018, in the production room, two Patterson 30 H30B-CS high velocity fans were used where flammable vapors were present and were not intrinsically safe, approved for a Class I hazardous location, or safe for a Class I hazardous location.

Issued

Jul 25, 2018

Abate by

Aug 6, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.106(h)(4)(iii)(a):  The transfer of large quantities of flammable liquids was not through piping by means of pumps or water displacement.  The employer did not ensure that, except as required in process equipment, gravity flow was not used:  a.  On or about January 31, 2018 through February 16, 2018, in the production room, employees transferred Category 2 flammable liquids, including methyl methacrylate (MMA), at temperatures elevated above the flash point of the materials, by a gravity flow splash filling method.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $12,934 · Current $8,000 Reduced

General-duty citation text

29 CFR 1910.38(a): An employer must have an emergency action plan whenever an OSHA standard in this part requires one. The requirements in this section apply to each such emergency action plan.    a. On or about January 31, 2018, throughout the facility, employees worked in area with hazardous materials such as, but not limited to, acetone, methyl methacrylate, ethyl-2 cyanoacrylate, and nitromethane. The employer had neither developed an exposure response plan (ERP) in accordance with 1910.120(q)(l) nor developed an emergency action plan (EAP) that was compliant with all elements of 1910.38 and which required all employee to evacuate from a danger area when an emergency occurs.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $12,934 · Current $8,000 Reduced

General-duty citation text

29 CFR 1910.132(d)(1): The employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE):    a.  On or about January 31, 2018, throughout the facility, the employer had not completed personal protective equipment assessments to identify the potential hazards for job tasks that may necessitate the use of personal protective equipment.  Employees were exposed to chemicals such as, but not limited to, methylene chloride, methyl methacrylate, ethyl 2-cyanoacrylate, and nitromethane.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.132(f)(1):   The employer did not provide training to each employee who was required by this section to use personal protective equipment.  Each such employee was not trained to know at least the elements outlined in 1910.132(f)(1)(i)-(v):  a.  On or about January 31, 2018, throughout the facility, employees were not trained to know at least the following:       1.  What PPE is necessary.       2.  When PPE is necessary.       3.  How to properly don, doff, adjust and wear the PPE.       4. The limitations of PPE.       5.  The proper care, maintenance useful life and disposal of the PPE.    Employee chemical exposures included, but were not limted to: acetone, methylene chloride, methyl methacrylate, ethy 2-cyanoacrylate and nitromethane.

Issued

Jul 25, 2018

Abate by

Aug 20, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.138(a): The employer did not select and require employees to use appropriate hand protection when employees' hands were exposed to hazards such as those from skin absorption of harmful substances, chemical burns, thermal burns and harmful temperature extremes:  On or about January 31, 2018 through February 16, 2018, throughout the facility, employees were required to work with hazardous chemicals, including but not limited to methylene chloride, methyl methacrylate, ethyl 2-cyanoacrylate and nitromethane.  The employer failed to provide and require the use of gloves to ensure adequate protection and durability upon both initial contact and prolonged contact with hazardous chemicals.      I. On or about January 31, 2018 through February 16, 2018, in the production room, employees were required to work with chemicals including, but not limited to methyl methacrylate and were provided with ordinary latex gloves.  The latex gloves provided were not rated for chemical resistance against hazardous chemicals used in the production room.  The latex gloves were also not rated for use with high temperature materials.    II. On or about January 31, 2018 through February 16, 2018, in the epoxy room, employees were required to work with chemicals including, but not limited to nitromethane and were provided with ordinary latex gloves. The latex gloves provided were not rated for chemical resistance against nitromethane and hazardous chemicals used in the epoxy room.    III. On or about January 31, 2018 through February 16, 2018, in the activator room, employees were required to work with chemicals including, but not limited to methylene chloride and were provided with ordinary latex gloves.  The latex gloves provided were not rated for chemical resistance against methylene chloride and hazardous chemicals used in the activator room.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $12,934 · Current $8,000 Reduced

General-duty citation text

29 CFR 1910.134(k)(1): The employer did not ensure that each employee could demonstrate knowledge of at least the required training elements under 1910.134(k)(1)(i) - (vii):    a.  On or about January 31, 2018 through February 16, 2018, in the production and packaging rooms, employees were provided with and required to wear full and half face tight fitting air-purifying respirators for exposure to chemicals including organic vapors.  The employer did not ensure that each employee could demonstrate knowledge of the required training elements of the standard, including but not limited to why respiratory protection is necessary, factors that compromise protection, proper fit, proper use, limitations and capabilities including in an IDLH atmosphere, change schedules, emergency use, inspection, maintenance and/or storage, general requirements of 29 CFR 1910.134, and how to recognize medical signs and symptoms.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(k)(3): Training was not provided prior to requiring employees to use a respirator in the workplace:  a.  On or about January 31, 2018 through February 16, 2018, in the production and packaging rooms, employees were provided with and required to wear full and half face tight fitting air-purifying respirators for exposure to chemicals including organic vapors.  The employer did not ensure that each employee was provided training on the proper use of respiratory protection prior to requiring employees to use a respirator in the workplace. The employer did not have a procedure in place to ensure that employees required to use respirators in the workplace were provided the necessary training prior to use.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $12,934 · Current $0 Reduced

General-duty citation text

29 CFR 1910.134(c)(1)(i): The written respiratory protection program did not include the applicable provisions of this section relating to procedures for selecting respirators for use in the workplace:    a.  On or about January 31, 2018 through February 16, 2018, throughout the facility, employees were required to wear air-purifying respirators during specific tasks involving chemicals such as, but not limited to, methyl methacrylate, ethyl 2-cyanoacrylate, and methyl ethyl ketone.  The written respiratory protection program did not include procedures for selecting respirators in the workplace to include such principles as respirator types, respirator limitations, exposure monitoring, assigned protection factors (APFs), maximum use concentrations (MUCs), immediately dangerous to life or health (IDLH) atmospheres, NIOSH certification, service lives, filter selection, working environment, employee workload, etc.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $10,163 · Current $0 Reduced

General-duty citation text

29 CFR 1910.141(g)(2): Employees were allowed to consume food or beverage in area(s) exposed to toxic materials:    a.  On or about  January 31, 2018, in the packaging room, employees were exposed to hazardous materials including, but not limited to acetone, methyl ethyl ketone, methyl methacrylate, ethyl 2-cyanoacrylate and nitrobenzene.  Employees were permitted to eat and drink in the work area where hazardous chemicals were present.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $12,934 · Current $8,000 Reduced

General-duty citation text

29 CFR 1910.1020(g)(1): The employer did not inform current employees upon first entering into employment, and at least annually thereafter, of the elements listed in 1910.1020(g)(1)(i)-(iii):     a.   On or about January, 31, 2018 through February 16, 2018, throughout the facility, the employer failed to inform employees of the existence, location and availability of employee medical records and exposure records to toxic substances (including, but not limited to, methyl methacrylate, methyl ethyl ketone, methylene chloride, tetrahydrofuran, acetone, and toluene), the person responsible for maintaining and providing access to the records, and each employees' rights of access to these records.   The employer did not have a method to notify employees of this information at least annually and had not provided this information to recently hired employees upon hire.

Issued

Jul 25, 2018

Abate by

Aug 20, 2018

Penalty

Initial $13,260 · Current $8,000 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.    Production Room - On or about May 10, 2018, an energy control procedure was not utilized while employees cleaned and serviced mixers, thereby exposing employees to amputations and struck by hazards.    In accordance with 29CFR 1903.19(d), abatement certification is required for this violation (using CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement or other written records.

Issued

Jul 25, 2018

Abate by

Aug 20, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(4)(ii): The energy control procedures did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, including, but not limited to items of this section.    Production Room - On or about May 10, 2018, energy control procedure(s) did not clearly identify the specific techniques to control electrical, pneumatic, and gravity energy sources for the 200, 100, and 50 gallon mixers.     In accordance with 29CFR 1903.19(d), abatement certification is required for this violation (using CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement or other written records.

Issued

Jul 25, 2018

Penalty

Initial $13,260 · Current $8,000 Reduced

General-duty citation text

29 CFR 1910.147(c)(7)(i): The employer did not provide adequate training to ensure that the purpose and function of the energy control program was understood by employees.     Production Room - On or about May 10, 2018, employees cleaning and servicing the mixers were not provided training on lock out and energy control, thereby exposing employees to amputation and moving machine part hazards.     No abatement certification or documentation is required for this item.

Issued

Jul 25, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.178(l)(1)(i): The employer did not ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (l):     Production Room: On or about May 14, 2018,  an employee operated a crown forklift truck (sit down) without the employer ensuring the employee was competent to do so by successfully completing training and evaluation exposing the employee to struck  by and crushing hazards.     In accordance with 29CFR 1903.19(d), abatement certification is required for this violation (using CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement or other written records.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $129,336 · Current $40,416 Reduced

General-duty citation text

29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee was fit tested or required to use the respirator in the workplace:          a.  On or about January 31, 2018 through February 16, 2018, the employer had not ensured that each employee working in the production room with full and/or half face tight fitting air-purifying respirators had been provided with a medical evaluation.    b.  On or about January 31, 2018, the employer had not ensured that each employee working in the epoxy room with half  face tight fitting air-purifying respirators had been provided with a medical evaluation.     c.  On or about January 31, 2018, the employer had not ensured that each employee working in the packaging room with half  face tight fitting air-purifying respirators had been provided with a medical evaluation.    H.B. Fuller Company dba Wisdom Adhesives LLC was previously cited for a violation of this Occupational Safety and Health Standard 1910.134(e)(1), which was contained in OSHA Inspection #1214688, Citation #1, Item 3b,  and was affirmed as a final order on September 20, 2017, with respect to a workplace located at 1575 Executive Drive, Elgin, Illinois, 60123.     H.B. Fuller Construction Products, Inc. was previously cited for a violation of this Occupational Safety and Health Standard 1910.134(e)(1), which was contained in OSHA Inspection #1055771, Citation #1, Item 1,  and was affirmed as a final order on October 26, 2015, with respect to a workplace located at 315 S. Hicks Rd., Palatine, Illinois, 60067.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $129,336 · Current $40,416 Reduced

General-duty citation text

29 CFR 1910.134(f)(2): The employer did not ensure that an employee using a tight-fitting facepiece respirator was fit tested prior to the initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) was used, and at least annually thereafter:     a.  On or about January 31, 2018 through February 16, 2018, the employer had not ensured that each employee working in the production room with full and half face tight fitting air-purifying respirators had been provided with either an initial use fit test(s) or had received annual fit test(s), accordingly.     b.  On or about January 31, 2018, the employer had not ensured that each employee working in the epoxy room with half face tight fitting air-purifying respirators had been provided with either an initial use fit test or had received an annual fit test, accordingly.     c.  On or about January 31, 2018, the employer had not ensured that each employee working in the packaging room with half  face tight fitting air-purifying respirators had been provided with either an initial use fit test or had received an annual fit test, accordingly.     H.B. Fuller Company dBA Wisdom Adhesives LLC was previously cited for a violation of an equivalent Occupational Safety and Health Standard 1910.134(f)(1), which was contained in OSHA inspection number 1214688, citation number 1, item number 3c and was affirmed as a final order on September 20, 2017, with respect to a workplace located at 1575 Executive Drive, Elgin, IL 60123.     H.B. Fuller Construction Products, Inc. was previously cited for a violation of this Occupational Safety and Health Standard 1910.134(f)(2) which was contained in OSHA Inspection #1055771, Citation #1, Item 2,  and was affirmed as a final order on October 26, 2015, with respect to a workplace located at  315 S. Hicks Rd., Palatine, Illinois, 60067.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $71,137 · Current $40,416 Reduced

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:          a.  On or about January 31, 2018, in the production room, all employees had not been trained with effective information on hazardous chemicals in their work areas such as, but not limited to methyl methacrylate, ethyl 2-cyanoacrylate and nitromethane.      b.  On or about January 31, 2018, in the activator department, all employees had not been trained with effective information on hazardous chemicals in their work areas such as, but not limited to methyl methacrylate and ethyl 2-cyanoacrylate.     c.  On or about January 31, 2018, in the epoxy department, all employees had not been trained with effective information on hazardous chemicals in their work areas such as, but not limited to methyl methacrylate and nitromethane.      d.  On or about January 31, 2018, in the packaging room, all employees had not been trained with effective information on hazardous chemicals in their work areas such as, but not limited to methyl methacrylate, ethyl 2-cyanoacrylate and nitromethane.      H.B. Fuller Company dBA Wisdom Adhesives LLC was previously cited for a violation of this Occupational Safety and Health Standard 1910.1200(h)(1), which was contained in OSHA inspection number 1214688, citation number 1, item number 5c and was affirmed as a final order on September 20, 2017, with respect to a workplace located at 1575 Executive Drive, Elgin, IL 60123.    H.B. Fuller Construction Products, Inc. was previously cited for a violation of this Occupational Safety and Health Standard 1910.1200(h)(1), which was contained in OSHA inspection number 1221652, citation number 1, item number 3, and was affirmed as a final order on August 16, 2017, with respect to a workplace located at 1105 s. Frontenac Street, Aurora, IL 60504.

Issued

Jul 25, 2018

Penalty

Initial $129,336 · Current $40,416 Reduced

General-duty citation text

29 CFR 1910.134(d)(1)(i): The employer did not select and provide an appropriate respirator based on the respiratory hazard(s) to which the worker is exposed and workplace and user factors that affect respirator performance and reliability:    a.   On or about January 31, 2018 through February 16, 2018, employees in the production room were provided with full and half face tight fitting air-purifying respirators for use in operating conditions under which the employer had documented multiple exposures to methyl methacrylate  (MMA) at levels exceeding the respirators' maximum use concentrations (MUC's) as well as MMA's established level for an Immediately Dangerous to Life or Health (IDLH) atmosphere.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer did not identify and evaluate the respiratory hazard(s) in the workplace; including a reasonable estimate of employee exposures to respiratory hazards and identification of the contaminant's chemical state and physical form:    a.  On or about January 31, 2018, in the facility, employees manufactured and worked with various chemicals including, but not limited to nitromethane and ethyl 2-cyanoacrylate (CA).  The employer failed to evaluate employee exposure to hazardous chemicals including but not limited to nitromethane and CA to ensure that employees were adequately protected.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(k)(6): The employer did not provide the basic advisory information on respirators, as presented in Appendix D of 29 CFR 1910.134, in written or oral format to employees who wear respirators when such use was not required by the employer:  a.  On or about January 31, 2018, in the facility, the employer provided employees with filtering facepiece respiratory protection for voluntary use. The employer failed to provide employees offered to wear the respiratory protection with the information contained in Appendix D.

Issued

Jul 25, 2018

Abate by

Sep 11, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1052(l)(1): The employer did not provide information and training for each affected employee prior to or at the time of initial assignment to a job involving potential exposure to methylene chloride:        a.  On or about January, 31, 2018, in the activator department, an employee was potentially exposed to chemicals containing methylene chloride when filling containers.  The employee performing this task had not been provided with methylene chloride information and training to include the requirements of 1910.1052 , the information available in the appendices of 1910.1052, and how to access or obtain a copy of 1910.1052 and its appendices in the workplace.

Issued

Jul 25, 2018

Abate by

Aug 20, 2018

Penalty

Initial $13,260 · Current $8,000 Reduced

General-duty citation text

29 CFR 1910.178(a)(6): The employer did not ensure that all nameplates and markings were in place.       Production Room - On or about May 14, 2018, the Crown forklift truck did not have a nameplate which contains important information regarding the forklift such as capacities and appropriate designation.  The forklift was used in an environment   containing Class I, Division II rated flammable materials being processed including but not limited to methyl methacrylate and acetone exposing employees to explosions and fire hazards.     In accordance with 29CFR 1903.19(d), abatement certification is required for this violation (using CERTIFICATION OF CORRECTIVE ACTION WORKSHEET), and in addition, documentation that abatement is complete must be included with your certification. This documentation may include, but is not limited to, evidence of the purchase or repair of the equipment, photographic or video evidence of abatement or other written records.