OSHA Inspection: CASTWELL PRODUCTS, LLC

Issued

Sep 13, 2018

Abate by

Jan 30, 2019

Penalty

Initial $14,228 · Current $7,500 Reduced

Hazardous substances 9010

General-duty citation text

29 CFR 1910.1000(c): An employee(s) was exposed to respirable crystalline quartz silica in excess of the 8-hour time weighted average limits as calculated using the formula listed in Table Z-3:     a)  Castwell Products, LLC, Skokie, IL- On May 17, 2018, an employee working at the Central/105 (Hunter) shakeout was exposed to airborne concentrations of respirable crystalline silica (quartz) at 1.27 mg/M3, approximately 1.33 times the OSHA Permissible Exposure Limit (PEL) of 0.952 mg/M3 as an 8-hour time-weighted average. The PEL was established to prevent silicosis and lung cancer.  The exposure level was derived from a sample taken over a 454 minute period during the third shift starting on May 17, 2018. Zero exposure was assumed for the unsampled period of 26 minutes.      Castwell Products, LLC was previously cited for a violation of this Occupational Safety and Health Standard, 29 CFR 1910.1000(c), which was contained in OSHA inspection Number 1127956, citation number 1, item number 2a, and was affirmed as a final order on August 15, 2016, with respect to a workplace located at 7800 N. Austin Avenue in Skokie, Illinois.     Castwell Products, LLC was previously cited for a violation of this Occupational Safety and Health Standard, 29 CFR 1910.1000(c), which was contained in OSHA inspection Number 961300, citation number 1, item number 2a, and was affirmed as a final order on July 1, 2014, with respect to a workplace located at 7800 N. Austin Avenue in Skokie, Illinois.

Issued

Sep 13, 2018

Abate by

May 1, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 9010

General-duty citation text

29 CFR 1910.1000(e): Feasible administrative or engineering controls were not determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):    a) Castwell Products, LLC, Skokie, IL- On May 17, 2018, effective engineering and administrative controls were not instituted and maintained by the employer in the Central/105 (Hunter) shakeout of the foundry to reduce employee exposure to crystalline silica (quartz), a carcinogen, below the OSHA Permissible Exposure Limits (PELs). Employees working at the Central/105 (Hunter) shakeout area were exposed to respirable crystalline silica (quartz) in excess of the PEL.     See instance descriptions in item 1(a) of this citation.    Methods of engineering, administrative and work practice controls under these circumstances include but are not limited to:    1) Continue enforcing the proper use of respirators. Ensure that an effective respiratory protection program in accordance with 1910.134 is being followed where employees are trained and respiratory protection is used correctly.       2) Implement the following recommendations proposed as a result of the ventilation/engineering survey conducted at the worksite on March 2, 2016, which are based on prudent practices established through the experience of the site visit team and publications from consensus groups, such as the ACGIH (Ventilation Manual) and the American Foundry Society (Foundry Ventilation Manual):        A.  Convert existing side-draft hoods on the Central/105 (Hunter) lines to enclosing hoods.  Benefits include (1) a significant reduction in localized silica emissions from the vibratory conveyor, (2) the "push" component of the ventilation system could be dramatically reduced resulting in less, powered make-up air and associated fan horsepower, (3) the capture efficiency of the enclosing hood is better than the side-draft hood, and (4) the conversion could be easily reversed if higher production returns.         B.  Modify the "push" system  that complements the Central/105 (Hunter) side-draft exhaust hoods by (1) tempering the outside air so the system is not shut down during cold weather, (2) volumetrically balancing the flow rates apportioned to each louvered diffuser.        C.  Continue with and improve housekeeping efforts on paths where industrial trucks travel to reduce exposures for (1) Central/105 (Hunter) shakeout workers who are proximate to the main east-west path for industrial trucks.        D.  Investigate using longer mold cooling times and rotating shakeouts to reduce the significant quantities of mold sand adhering to the castings and gates at the Hunters shakeout vibratory conveyer line.        E. Provide supplied air islands for the Central/105 (Hunter) work positions where employees stand to degate, sort, clean, or throw gates and castings into hoppers. The intent of this engineering control is to have clean air flow down over the worker(s), which normally keeps contaminated air from entering the breathing zone. Design the supply air island to provide a laminar flow of fresh air through the employee's breathing zone at a low enough velocity so that additional airborne contaminated dust is not entrained. Implement work practices to require employees to stand under the islands as much as possible. These islands are feasible as there is no interference with any casting hoists. This control would be more feasible for the two wedger workers along the Hunters line than providing local exhaust ventilation.       F.  Implement a more aggressive administrative control program including housekeeping of floors and other horizontal surfaces where deposited silica can be re-introduced into the general workplace air. Use dustless methods of cleaning such as vacuuming. General housekeeping should be intensified to mitigate dust accumulation that contain respirable particulates.    3)Perform periodic maintenance checks/inspections of the local exhaust ventilation system to ensure that the capture velocity is effective, and that the system is functioning as designed.    ABATEMENT NOTE:    Step 1: Continue to enforce the utilization of respiratory protection as an interim measure of protection for affected employees.  Ensure employees are trained and respiratory protection is worn correctly.     Abatement date: 30 days    STEP 2:  A written detailed plan of abatement shall be submitted to the Area Director outlining a schedule for the implementation of engineering and/or administrative measure to control employee exposures to crystalline silica (quartz) as referenced in the citation.  This plan shall include, at a minimum, target dates for the following action, which must be consistent with the dates required by this citation:         (1)  Evaluation of engineering/administrative controls;    (2)  Selection of the optimum control methods and completion of design;    (3)  Procurement, installation and operation of selected control measures;    (4) Testing and acceptance or modification/redesign of controls.       All proposed control measure shall be evaluated for each particular use by a competent industrial hygienist or other technically qualified persons(s).  30-day progress reports to OSHA are required during the abatement period.       Abatement date: 60 days       STEP 3:  Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.       Abatement date: 90 days      Castwell Products, LLC was previously cited for a violation of this Occupational Safety and Health Standard, 29 CFR 1910.1000(e), which was contained in OSHA inspection Number 1127956, citation number 1, item number 2b, and was affirmed as a final order on August 15, 2016, with respect to a workplace located at 7800 N. Austin Avenue in Skokie, Illinois.     Castwell Products, LLC was previously cited for a violation of this Occupational Safety and Health Standard, 29 CFR 1910.1000(e), which was contained in OSHA inspection Number 961300, citation number 1, item number 2b, and was affirmed as a final order on July 1, 2014, with respect to a workplace located at 7800 N. Austin Avenue in Skokie, Illinois.