OSHA Inspection: SCOT CHRISTOPHER RULE LLC

Issued

Jul 18, 2019

Abate by

Jul 29, 2019

Penalty

Initial $2,500 · Current $1,000 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.134(g)(1)(i)(A): Respirators with tight-fitting facepieces were worn by employees who had facial hair that came between the sealing surface of the facepiece and the face or that interfered with valve function: (Construction Reference 1926.103)    a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees required to wear 3M half face respirators with organic vapor cartridges while spray painting and 3M filtering facepiece respirators while manually scraping lead paint had full beards, on or about February 5, 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

Jul 18, 2019

Abate by

Nov 12, 2020

Penalty

Initial $25,003 · Current $9,000 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1910.134(c)(1): A written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented for required respirator use: (Construction Reference 1926.103)  a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees were required to wear 3M half face respirators with organic vapor cartridges while painting and 3M filtering facepiece respirators while manually scraping lead paint and the employer did not establish a Respiratory Protection Program, on or about February 5, 2019.  SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 1910.134(c)(1)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 2b, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.

Issued

Jul 18, 2019

Abate by

Aug 12, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 1591

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: (Construction Reference 1926.103)    a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees were required to wear 3M half face respirators with organic vapor cartridges while painting and 3M filtering facepiece respirators while manually scraping lead paint and the employer did not provide the employees with a fit test, on or about February 5, 2019.    SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 1910.134(f)(2)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 2c, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.

Issued

Jul 18, 2019

Abate by

Aug 12, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1910.134(k)(1): The employer did not provide respirator training that ensured that each employee could demonstrate knowledge of at least the following elements: Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator; What the limitations and capabilities of the respirator are; How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions; How to inspect, put on and remove, use, and check the seals of the respirator; What the procedures are for maintenance and storage of the respirator, and How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators:    a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees were required to wear 3M N95 respirators while manually scraping lead paint and 3M half face respirators while spray painting and the employer did not provide employees with information about how to inspect, check the seals of the respirator, proper maintenance and storage of the respirator, and how to recognize medical signs and symptoms that may prevent the effective use of respirators, on or about February 5, 2019.    SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 134(k)(1)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 2d, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.

Issued

Jul 18, 2019

Abate by

Nov 12, 2020

Penalty

Initial $25,003 · Current $9,000 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(d)(1)(i): Each employer who had a workplace or operation covered by 29 CFR 1926.62 did not initially determine if any employee was exposed to lead at or above the action level of 30 micrograms per cubic meter of air (30 ug/m3) calculated as an 8-hour time-weighted average (TWA):  a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees were manually scraping lead paint from the ceiling and beams and the employer did not make an initial determination of the employees exposure to lead, on or about February 5, 2019.  SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 1926.62(d)(1)(i)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 1a, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.

Issued

Jul 18, 2019

Abate by

Jul 29, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(d)(2)(i): Until the employer performed an employee exposure assessment, as required in 29 CFR 1926.62(d), and documented that the employee(s) performing any of the listed tasks was not exposed above the Permissible Exposure Limit (PEL), the employer did not treat affected employee(s) as if they were exposed above the PEL, and not in excess of ten times the PEL, and did not implement employee protective measures prescribed in 29 CFR 1926.62(d)(2)(v):    a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees were manually scraping lead paint from the ceilings and beams and the employer did not implement interim employee protective measures as described in 29 CFR 1926.62(d)(2)(v) when the employees were assumed to be exposed above the PEL, on or about February 5, 2019.    SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 1926.62(d)(2)(i)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 1b, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.

Issued

Jul 18, 2019

Abate by

Jul 29, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(e)(2)(i): The employer did not establish and implement a written compliance program to achieve compliance with 29 CFR 1926.62(c) prior to commencement of the job:    a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees were assumed to be exposed to lead at levels greater than the permissible exposure limits while manually scraping lead paint from the ceilings and beams and the employer did not establish a written compliance program, on or about February 5, 2019.    SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 1926.62(e)(2)(i)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 1c, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.

Issued

Jul 18, 2019

Abate by

Aug 2, 2019

Penalty

Initial $25,003 · Current $9,000 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(j)(1)(i): The employer did not make available initial medical surveillance, consisting of biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels, to employees occupationally exposed on any day to lead at or above the action level:    a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees assumed to be exposed to lead at levels greater than the permissible exposure limits while manually scraping lead paint from the ceilings and beams were not provided initial medical surveillance, on or about February 5, 2019.    SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 1926.62(j)(1)(i)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 3, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.

Issued

Jul 18, 2019

Abate by

Aug 12, 2019

Penalty

Initial $25,003 · Current $9,000 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(l)(1)(i): The employer did not ensure that at least the following lead hazards were communicated to employee(s): reproductive/developmental toxicity; central nervous system effects; kidney effects; blood effects; and acute toxicity effects:    a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees were manually scraping lead paint from the ceilings and beams and employees were not effectively provided the information on the hazards of lead, on or about February 5, 2019.    SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 1926.62(l)(1)(i)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 4a, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.

Issued

Jul 18, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(m)(2)(i): The employer did not post the following warning signs in each work area where an employee exposure to lead was above the permissible exposure limit:    a) Simon Silk Mills, Easton, PA, Building B: Employees were manually scraping lead paint from the ceilings and beams and a sign warning of exposure to lead was not posted, on or about February 5, 2019.    SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 1926.62(m)(2)(i)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 4b, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.

Issued

Jul 18, 2019

Abate by

Nov 12, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met: (Construction Reference: 1926.59)  a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees were manually scraping lead paint from the ceilings and beams and using Sherwin Williams paints and Fiberlock Lead Shield. The employer did not have a written hazard communication program, on or about February 5, 2019.  SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 1910.1200(e)(1)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 4c, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.

Issued

Jul 18, 2019

Abate by

Aug 2, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(g)(1): Employers did not have a safety data sheet in the workplace for each hazardous chemical which they use (Construction Reference: 1926.59):     a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees were using Sherwin Williams paints and Fiberlock Lead Shield and exposed to lead during paint removal.  The employer did not have safety data sheets available for employees, on or about February 5, 2019.    SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 1910.1200(g)(1)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 4d, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.

Issued

Jul 18, 2019

Abate by

Aug 12, 2019

Penalty

Initial $0 · Current $0

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: (Construction Reference: 1926.59)    a) Simon Silk Mills, Easton, PA, Buildings B and C: Employees were manually scraping lead paint from the ceilings and beams and using Sherwin Williams paints and Fiberlock Lead Shield. The employer did not not provide employees with training on the hazard communication program, hazards of chemicals used, and the information on the safety data sheets, on or about February 5, 2019.    SCOT CHRISTOPHER RULE, LLC, WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD (29 CFR 1910.1200(h)(1)) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 12797307, CITATION NUMBER 1, ITEM NUMBER 4e, AND WAS AFFIRMED AS A FINAL ORDER ON MAY 9, 2018, WITH RESPECT TO A WORKPLACE LOCATED AT BUILDING L, 1247 SIMON BLVD, EASTON, PA.    ABATEMENT NOTE:   Employees shall be informed of the following:      1.  The requirements of this section;      2.  Any operations where hazardous chemicals are present;      3.  The location and availability of the written Hazard Communication Program, list(s) of hazardous chemicals and Safety Data Sheets.       Employee training shall include at least:       1.  Methods and observations that may be used to detect the presence or release of hazardous chemical in the work area.       2.  The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area.       3.  The measures employees can take to protect themselves such as specific procedures and personal, protective equipment to be used.       4.  The details of the employer's Hazard Communication Program including an explanation of the labels received on shipped containers and the workplace labeling system used by the employer; Safety Data Sheets, including the order of information and how employees can obtain and use the appropriate hazard information.