OSHA Inspection: CLARKE PRODUCTS INC.

Issued

Oct 1, 2018

Abate by

Oct 30, 2018

Penalty

Initial $4,268 · Current $2,134 Reduced

General-duty citation text

29 CFR 1910.95(d)(1): When information indicated that any employee's exposure equaled or exceed the 8-hour time-weighted average of 85 decibels, the employer did not develop and implement a monitoring program:  At the facility, the employer did not implement a monitoring program when employees were exposed to high levels of noise;       a) trim area:  On or about April 26, 2018, employees conducting trim activities near the robotic trim area were exposed to continuous noise at 175.2% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 475 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 94.0 dBA.  Exposure calculations include a zero increment for the 5 minutes not sampled.      b) trim area:  On or about April 26, 2018, employees conducting trim activities were exposed to continuous noise at 73.94% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 478 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 87.8 dBA.  Exposure calculations include a zero increment for the 2 minutes not sampled.         c) Solid Surface, rear building:  On or about April 26, 2018, employees conducting trim activities were exposed to continuous noise at 92.78% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 480 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 89.4 dBA.           d) Solid Surface, rear building:  On or about April 26, 2018, employees conducting trim activities were exposed to continuous noise at 85.98% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 480 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 88.9 dBA.

Issued

Oct 1, 2018

Abate by

Oct 30, 2018

Penalty

Initial $6,467 · Current $3,234 Reduced

General-duty citation text

29 CFR 1910.95(g)(1): The employer did not establish and maintain an audiometric testing program as provided by 29 CFR 1910.95(g) by making audiometric testing available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 decibels:  At the facility, the employer did not conduct maintain annual audiogram testing to all employees exposed to high levels of noise.       a) trim area:  On or about April 26, 2018, employees conducting trim activities near the robotic trim area were exposed to continuous noise at 175.2% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 475 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 94.0 dBA.  Exposure calculations include a zero increment for the 5 minutes not sampled.      b) trim area:  On or about April 26, 2018, employees conducting trim activities were exposed to continuous noise at 73.94% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 478 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 87.8 dBA.  Exposure calculations include a zero increment for the 2 minutes not sampled.         c) Solid Surface, rear building:  On or about April 26, 2018, employees conducting trim activities were exposed to continuous noise at 92.78% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 480 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 89.4 dBA.           d) Solid Surface, rear building:  On or about April 26, 2018, employees conducting trim activities were exposed to continuous noise at 85.98% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 480 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 88.9 dBA.

Issued

Oct 1, 2018

Abate by

Oct 30, 2018

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.95(g)(6): At least annually after obtaining the baseline audiogram, the employer did not obtain a new audiogram for each employee exposed at or above an 8-hour time-weighted average of 85 decibels :  At the facility, the employer did not conduct annual audiogram testing to establish a baseline audiogram to employees exposed to high levels of noise.       a) trim area:  On or about April 26, 2018, employees conducting trim activities near the robotic trim area were exposed to continuous noise at 175.2% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 475 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 94.0 dBA.  Exposure calculations include a zero increment for the 5 minutes not sampled.      b) trim area:  On or about April 26, 2018, employees conducting trim activities were exposed to continuous noise at 73.94% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 478 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 87.8 dBA.  Exposure calculations include a zero increment for the 2 minutes not sampled.         c) Solid Surface, rear building:  On or about April 26, 2018, employees conducting trim activities were exposed to continuous noise at 92.78% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 480 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 89.4 dBA.           d) Solid Surface, rear building:  On or about April 26, 2018, employees conducting trim activities were exposed to continuous noise at 85.98% of the permissible daily noise exposure (8-hour Time Weighted Average sound level of 85 dBA) during the 480 minute sampling period and were not included in the hearing conservation program.  For a full eight hour work shift this exposure is equivalent to an average sound level of 88.9 dBA.

Issued

Oct 1, 2018

Abate by

Oct 30, 2018

Penalty

Initial $4,268 · Current $2,134 Reduced

Hazardous substances 17502280

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:      a) Mixing area:  On or about April 26, 2018, employees conducting mixing activities with chemicals such as but not limited to 2-Butanone peroxide and styrene and wearing tight fitting respirators were not fit tested prior to using the respirator.        b) Solid surface area:  On or about April 26, 2018, employees conducting repair activities with catalyst fiber and resin wearing tight fitting respirators were not fit tested prior to using the respirator.

Issued

Oct 1, 2018

Abate by

Oct 30, 2018

Penalty

Initial $21,341 · Current $10,671 Reduced

Hazardous substances 17502280

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) Mixing area:  On or about April 26, 2018, employees conducting mixing activities with chemicals such as but not limited to 2-Butanone peroxide and styrene and wearing tight fitting respirators were not medically cleared prior to using the respirator.         b) Solid surface area:  On or about April 26, 2018, employees conducting repair activities with catalyst fiber and resin wearing tight fitting respirators were not medically cleared prior to using the respirator.    Clarke Products Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.134(e)(1), which was contained in OSHA inspection number 1040846, citation number 02, item number 01 and was affirmed as a final order on September 10, 2015, with a final abatement date of September 20, 2015, with respect to a workplace located at 2100 B Orchard Lane, Waco, TX 76705.    Clarke Products Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.134(e)(1), which was contained in OSHA inspection number 945996, citation number 01, item number 01 and was affirmed as a final order on December 12, 2013, with a final abatement date of December 27, 2013, with respect to a workplace located at 2100 B Orchard Lane, Waco, TX 76705.

Issued

Oct 1, 2018

Abate by

Oct 30, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 17502280

General-duty citation text

29 CFR 1910.134(k): The employer did not provide comprehensive, understandable training which did not occur annually and/or more often if necessary:      a) Mixing area:  On or about April 26, 2018, employees conducting mixing activities with chemicals such as but not limited to 2-Butanone peroxide and styrene and wearing tight fitting respirators were not provided training prior to using the respirator.         b) Solid surface area:  On or about April 26, 2018, employees conducting repair activities with catalyst fiber and resin wearing tight fitting respirators were not provided training prior to using the respirator or annually thereafter.    Clarke Products Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.134(e)(1), which was contained in OSHA inspection number 1040846, citation number 01, item number 02 and was affirmed as a final order on September 10, 2015, with a final abatement date of September 20, 2015, with respect to a workplace located at 2100 B Orchard Lane, Waco, TX 76705.

Issued

Oct 1, 2018

Abate by

Oct 30, 2018

Penalty

Initial $17,072 · Current $8,536 Reduced

Hazardous substances 17502280

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) Mixing area:  On or about April 26, 2018, employees conducting mixing activities with catalyst fiber and resins containing chemicals such as but not limited to 2-Butanone peroxide and styrene were not provided training prior to initial use of the products or when the materials changed.      b) Solid surface area:  On or about April 26, 2018, employees conducting polishing, sanding, and repair activities with catalyst fiber and resins containing chemicals such as but not limited to 2-Butanone peroxide and styrene were not provided training prior to initial use of the products or when the materials changed.         c) Spray booths:  On or about April 26, 2018, employees conducting material spraying activities with catalyst fiber and resins containing chemicals such as but not limited to 2-Butanone peroxide and styrene were not provided training prior to initial use of the products or when the materials changed.    Clarke Products Inc. was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.1200(h)(1), which was contained in OSHA inspection number 1040846, citation number 01, item number 04 and was affirmed as a final order on September 10, 2015, with a final abatement date of September 20, 2015, with respect to a workplace located at 2100 B Orchard Lane, Waco, TX 76705.

Issued

Oct 1, 2018

Abate by

Oct 30, 2018

Penalty

Initial $0 · Current $0

Hazardous substances 175022809130

General-duty citation text

29 CFR 1910.134(c)(2)(i): Respirator users were not provided with the information contained in Appendix D to 29 CFR 1910.134 when the employer determined that any voluntary respirator use was permissible:       a) Spray booth area:  On or about April 26, 2018, employees conducting spraying activities with chemicals such as but not limited to 2-Butanone peroxide and styrene and wearing filtering face piece respirators were not provided with Appendix D prior to using the respirator.         b) Solid surface area:  On or about April 26, 2018, employees conducting polishing, sanding and grinding activities wearing filtering face piece respirators were not provided with Appendix D prior to using the respirator.