OSHA Inspection: SMOOTH-ON INC

Issued

Mar 12, 2019

Penalty

Initial $7,246 · Current $0 Reduced

Hazardous substances 900091309135

General-duty citation text

29 CFR 1910.134(f)(2): Employee(s) using a tight-fitting facepiece respirator were not annually fit tested:    a) P2: Employees wearing tight-fitting respirators, over exposed to silica while making various products, were not provided fit tests within a 12 month period, on or about January 2, 2019.    No abatement certification or documentation required.

Issued

Mar 12, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 900091309135

General-duty citation text

29 CFR 1910.134(k)(5): Respiratory protection retraining was not conducted annually:    a) P2: Employees, over exposed to silica while manufacturing various products, were not provided with annual respiratory protection training, on or about January 2, 2019.      No abatement certification or documentation required.

Issued

Mar 12, 2019

Abate by

Jul 1, 2019

Penalty

Initial $4,347 · Current $9,130

Hazardous substances 9130

General-duty citation text

29 CFR 1910.1000(c): An employee(s) was exposed to respirable particulates not otherwise classified in excess of the 8-hour time weighted average limits of 5 mg/m³ listed in Table Z-3:     a) BRC Room: An employee, BRC Operator, operating the Snow White ribbon blender and packing out the finished product was exposed to an 8 hour time-weighted average (TWA) of 6.38 mg/m3 of respirable particulates not otherwise classified. This level is 1.28 times the permissible exposure limit of 5 mg/m3. This exposure occurred over a 418 minute sampling period on January 22, 2019. A zero exposure is assumed for the 62 minutes not sampled.    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 12, 2019

Abate by

Jul 1, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 9130

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) P2: An employee, BRC Operator, operating the Snow White ribbon blender and packing out the finished product was exposed to respirable particulates not otherwise classified above the permissible exposure limit of 5 mg/m3 and the employer did not implement all feasible engineering and work practice controls, on or about January 22, 2019.      Feasible abatement methods include but are not limited to:  1. Install effective local exhaust ventilation while adding material and packing out the finished product.  2. Develop a method to add materials by an enclosed system and/or in a way that the material would not have to be manually dumped.  3. Use a vacuum to clean off bags and pallets as well as clean the room.      ABATEMENT STEPS ARE AS FOLLOW:      STEP 1 - A written detailed plan of abatement shall be submitted to the Area Director outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposures to hazardous substances as referenced in this citation. This plan shall include, at a minimum, target dates for the following actions which must be consistent with the dates required by this citation:      1.  Evaluation of engineering control options;      2.  Selection of optimum control method and completion of design;      3.  Procurement, installation and operation of selected control measures;      4.  Testing and acceptance or modification/redesign of controls.      Note: All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person. Ninety- (90) day progress reports are required during the abatement period.       STEP 2 - Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.

Issued

Mar 12, 2019

Abate by

Jul 1, 2019

Penalty

Initial $7,246 · Current $9,130

Hazardous substances 9000

General-duty citation text

29 CFR 1910.1053(c): The employer did not ensure that no employee was exposed to an airborne concentration of respirable crystalline silica in excess of 50 ug/m3, calculated as an 8-hour TWA:    a) P2: An employee, Team Lead Operator, was adding Minusil 5 to the Large Hockmeyer while exposed to 63.13 µg/m3 as an 8 hour time-weighted average (TWA) of silica. This level is 1.26 times the permissible exposure limit of 50 µg/m3. This exposure occurred over a 428 minute sampling period on January 22, 2019. A zero exposure is assumed for the 52 minutes not sampled.    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 12, 2019

Abate by

Jul 1, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 9000

General-duty citation text

29 CFR 1910.1053(f)(1): The employer did not use engineering and work practice controls to reduce and maintain employee exposure to respirable crystalline silica to or below the PEL, unless the employer can demonstrate that such controls are not feasible:    a) P2: An employee, Team Lead Operator, was adding Minusil 5 to the Large Hockmeyer while exposed to silica above the permissible exposure limit of 50 µg/m3 and the employer did not implement all feasible engineering and work practice controls, on or about January 22, 2019.      Feasible abatement methods include but are not limited to:  1. Install effective local exhaust ventilation.  2. Develop a method to add silica containing materials by an enclosed system.  3. Develop a method to add silica containing materials by means other than manual dumping.      ABATEMENT STEPS ARE AS FOLLOW:       STEP 1 - A written detailed plan of abatement shall be submitted to the Area Director outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposures to hazardous substances as referenced in this citation. This plan shall include, at a minimum, target dates for the following actions which must be consistent with the dates required by this citation:      1.  Evaluation of engineering control options;      2.  Selection of optimum control method and completion of design;      3.  Procurement, installation and operation of selected control measures;      4.  Testing and acceptance or modification/redesign of controls.      Note: All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person. Ninety- (90) day progress reports are required during the abatement period.        STEP 2 - Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.

Issued

Mar 12, 2019

Abate by

Apr 15, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 9000

General-duty citation text

29 CFR 1910.1053(f)(2)(i): The employer did not establish and implement a written exposure control plan:  a) P2: An employee, Team Lead Operator, was adding Minusil 5 to the Large Hockmeyer while exposed to silica above the permissible exposure limit of 50 µg/m3 and the employer did not establish a written silica exposure control plan, on or about January 22, 2019.  Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 12, 2019

Abate by

Mar 20, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 9000

General-duty citation text

29 CFR 1910.1053(e)(2)(ii): The employer failed to post signs at all entrances to regulated areas:  a) P2: An employee, Team Lead Operator, was adding Minusil 5 to the Large Hockmeyer while exposed to silica above the permissible exposure limit of 50 µg/m3 in a regulated area and the employer did not post signs at the entrances to the regulated area with the required language specified in 29 CFR 1910.1053(j)(2), on or about January 22, 2019.   Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.

Issued

Mar 12, 2019

Abate by

Jul 1, 2019

Penalty

Initial $7,246 · Current $0 Reduced

Hazardous substances 9000

General-duty citation text

29 CFR 1910.1053(i)(1)(i): The employer did not make medical surveillance available at no cost to each employee, and at a reasonable time and place, for each employee who has been occupationally exposed to respirable crystalline silica at or above the action level for 30 or more days per year:    a) P2: Employees were conducting activities while exposed to silica above the permissible exposure limit of 50 µg/m3 for more than 30 days per year and the employer did not provide employees with a medical examination as required by this standard, on or about January 22, 2019.    Abatement certification required within 10 days after abatement date. The certification shall include a statement that abatement is complete, date and method of abatement, and states that employees and their representatives were informed of this abatement.