OSHA Inspection: NEMAK USA, INC.

Issued

Feb 26, 2019

Abate by

May 6, 2019

Penalty

Initial $13,260 · Current $0 Reduced

Hazardous substances R252R278

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1):  The employer did not furnish employment and a place of employment which were free from recognized hazards, that were causing or likely to cause death or serious physical harm to employees in that employees working at or near equipment containing metalworking fluids (MWF) were exposed to microbiological material (endotoxins) that caused hypersensitivity pneumonitis, a debilitating lung disease:  a) The Dial/Cyclone machine required Durakut 525 metalworking fluid (MWF) for the processing of die cast aluminum work pieces. The metal removing stations, the MWF collection and sump system were unenclosed and open to the department's environment.  Bulk samples of MWF collected from the Dial Sump Pit contained up to 92,000 Endotoxin Units (EU)/mL. Air samples collected at the workstation of Dial machine operator(s) indicated the presence of airborne endotoxins at a concentration up to 2,420 EU/m^3 as an 8-hour Time Weighted Average (TWA).  b) The Boss Line's consisted of multiple machines, including the Tuff CNC machine and Toyoda 9 machine, which both required Durakut 525 metal working fluid (MWF) for the processing of die cast aluminum work pieces. The MWF collection and sump system of the Tuff CNC machine were unenclosed and open to the department's environment. Bulk samples of MWF collected from the Toyoda 9 machine's main compartment contained up to 1,900 Endotoxin Units (EU)/mL.  Bulk samples of MWF collected from the open air sump pit of the Tuff CNC machine contained up to 930 EU/mL.  Air samples collected at a workstation between the Boss Line and Dial/Cyclone indicated the presence of airborne endotoxins at a concentration up to 341 EU/m^3 as an 8-hour Time Weighted Average (TWA).  Among other methods, some feasible and acceptable means of abatement include, but are not limited to the following:  a) Enclose all processes dependent on MWFs (including but not limited to operations on the Dial/Cyclone and Boss Line machines) to minimize aerosolizing of MWF and its biological material.  b) Install local exhaust ventilation (LEV) and mist collection systems for capture and control of MWF and its aerosolized biological material.  Ensure that a preventive maintenance schedule is implemented, which at a minimum includes daily inspections of the engineering control systems (e.g. magnahelic airflow pressure gauges); checking and changing filters at regularly scheduled intervals specified by the mist collector manufacturer and dependent on production demands.  c) Add time-delays on door openings where practicable and leave enclosure doors closed until the LEV clears mist inside the machine, and stop the delivery of MWF when machining has completed.