OSHA Inspection: WALCOTT COLLISION SERVICES INC.

Issued

Jul 16, 2019

Abate by

Aug 23, 2019

Penalty

Initial $319 · Current $319

General-duty citation text

29 CFR 1903.19(d)(1): The employer did not submit to the Agency documents demonstrating that abatement is complete for each willful or repeat violation and for any serious violation for which the Agency indicates in the citation that such abatement documentation is required.  On May 29, 2019, Walcott Collision Services, Inc. was issued citations and the employer did not document that the citations were abated.  Abatement documentation was not received for the following items:  a.    Citation 1, Item 1, b.    Citation 1, Item 2a, c.    Citation 1, Item 2b, d.    Citation 1, Item 2c, e.    Citation 1, Item 2d, f.    Citation 1, Item 2e, g.    Citation 1, Item 2f h.    Citation 1, Item 3a, i.    Citation 1, Item 3b, j.    Citation 1, Item 3c, k.    Citation 1, Item 3d, l.    Citation 1, Item 3e, m.    Citation 1, Item 4a, n.    Citation 1, Item 4b

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $2,273 · Current $2,273

General-duty citation text

29 CFR 1910.94(a)(7): Aisles and walkways were not kept clear of steel shot or similar abrasive which may have created a slipping hazard:  On or about February 7, 2019, employees working at National Railway Equipment Co. in the Abrasive Blasting Building were exposed to slip and fall hazards and the employer permitted abrasive media to accumulate across the aisleways between the base of the rolling work platforms towards the exit doors.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $3,978 · Current $3,978

Hazardous substances 81108111

General-duty citation text

29 CFR 1910.95(b)(1): When employees were subjected to sound exceeding those listed in Table G-16, feasible administrative or engineering controls were not utilized:  On or about February 7, 2019, an employee at National Railway Equipment Co. in the Abrasive Blasting Building was exposed to noise levels at 105% of the allowable 8-hour time weighted average (TWA) sound level (90 dBA) while abrasive blast cleaning a locomotive.  This level exceeds a noise dose of 100%.  The equivalent dBA level of 105% is approximately 112.0 dBA. This level exceeds an 8-hour TWA of 90 dBA. The sampling was performed for 180-minutes during one shift on February 7, 2019.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 81108111

General-duty citation text

29 CFR 1910.95(d)(1): A representative monitoring program was not developed and implemented when information indicated that an employee's exposure may equal or exceed an 8 hour time weighted average of 85dBA:  On or about February 7, 2019, an employee abrasive blast cleaned a locomotive in the Abrasive Blast Building at National Railway Equipment Company and was exposed to noise above the permissible daily exposure and the employer had not conducted noise monitoring.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 81108111

General-duty citation text

29 CFR 1910.95(g)(5)(i): The employer had not established, within 6 months of an employee's first exposure at or above the action level, a valid baseline audiogram against which subsequent audiograms could be compared:  On or about February 7, 2019, an employee abrasive blast cleaned a locomotive in the Abrasive Blast Building at National Railway Equipment Company for longer than 6-months and the employer had not obtained a baseline audiogram for the employee that was exposed above the action level.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 81108111

General-duty citation text

29 CFR 1910.95(i)(2)(i): The employer did not ensure that hearing protectors were being worn by any employees who are required by paragraph (b)(1) of this section to wear personal protective equipment:  On or about February 7, 2019, an employee abrasive blast cleaned a locomotive in the Abrasive Blast Building at National Railway Equipment Company and was exposed to noise above the permissible daily exposure and the employer had not ensured the wore hearing protectors until a baseline audiogram was provided.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 81108111

General-duty citation text

29 CFR 1910.95(k)(1): The employer had not trained each employee who was exposed to noise at or above an 8-hour time-weighted average of 85 decibels in accordance with the requirements of 29 CFR 1910.95(k):  On or about February 7, 2019, an employee abrasive blast cleaned a locomotive in the Abrasive Blast Building at National Railway Equipment Company and was exposed to noise above the permissible daily exposure and the employer had not  trained the employee on the effects of noise on hearing, the purpose of hearing protectors, and the purpose of audiometric testing.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 81108111

General-duty citation text

29 CFR 1910.95(l)(1): The employer had not made available to affected employees or their representatives copies of 29 CFR 1910.95 and had not posted a copy in the workplace:  On or about February 7, 2019, an employee abrasive blast cleaned a locomotive in the Abrasive Blast Building at National Railway Equipment Company and was exposed to noise above the permissible daily exposure and the employer had not posted a copy of the standard on Occupational Noise Exposure.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $3,978 · Current $3,978

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 had not been established and implemented for required respirator use:  On or about February 7, 2019, employees abrasive blast cleaning a locomotive in the Abrasive Blast Building at National Railway Equipment Company were required to wear a supplied air helmet and the employer had not established a written respiratory program with worksite specific procedures that included the following:  a) Medical evaluations of employees required to use supplied air helmet respirators;  b) Procedures for proper use of supplied air helmet respirators in routine and reasonably foreseeable emergency situations;  c) Specific procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, and otherwise maintaining the supplied air helmet respirators;  d) Procedures to ensure adequate air quality, quantity, and flow of breathing air for the atmosphere-supplying respirators;  e) Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations; and  f) Training of employees in the proper use of supplied air helmet respirators, including putting on and removing them, any limitations on their use, and their maintenance.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer had not identified and evaluated the respiratory hazard(s) in the workplace; including a reasonable estimate of employee exposures to respiratory hazards and identification of the contaminant's chemical state and physical form:  On or about February 7, 2019, employees abrasive blast cleaning a locomotive in the Abrasive Blast Building at National Railway Equipment Company were exposed to respiratory hazards and the employer had not evaluated the respiratory hazards or have a reasonable estimate of employee exposure to respiratory hazards for employees required to wear supplied air respirators (helmets).

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(e)(1): The employer had not provided 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:  On or about February 7, 2019, employees abrasive blast cleaning a locomotive in the Abrasive Blast Building at National Railway Equipment Company were exposed to respiratory hazards and the employer had not provided a medical evaluation to determine the employee's ability to use a supplied air respirator.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(k)(1): The employer had not provided effective training that covered the required elements in 1910.134(k)(1)(i) through 1910.134(k)(1)(vii):  On or about February 7, 2019, employees abrasive blast cleaning a locomotive in the Abrasive Blast Building at National Railway Equipment Company were required to wear supplied air respirator helmets and the employer had not ensured employees were trained on the following at least annually:    a. Why respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator;  b. What the limitations and capabilities of the respirator are;  c. How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions;   d. How to inspect, put on and remove, use, and check the seals of the respirator;  e. What the procedures are for maintenance and storage of the respirator;  f. How to recognize the medical signs and symptoms that may limit or prevent the effective use of respirators; and  g. The general requirements of this section.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(l)(1): Evaluations of the workplace had not been conducted to ensure the written respiratory protection program was being effectively implemented:  On or about February 7, 2019, employees abrasive blast cleaning a locomotive in the Abrasive Blast Building at National Railway Equipment Company were required to wear supplied air respirator helmets and the employer had not conducted evaluations of the workplace to ensure the written program was effectively implemented.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $3,978 · Current $3,978

Hazardous substances 9135

General-duty citation text

29 CFR 1910.1000(a)(2): Employee(s) were exposed to an airborne concentration of Particulates Not Otherwise Regulated (PNOR) Total dust listed in Table Z-1 in excess of the 8 hour Time Weighted Average concentration of 15 mg per cubic meter:  a)  On or about February 7, 2019, employees abrasive blast cleaning a locomotive in the Abrasive Blast Building at National Railway Equipment Company were exposed to an 8-hour time weighted average level of 99.4 mg/m3 for Particulates Not Otherwise Regulated (PNOR), approximately 6.63 times the Permissible Exposure Limit of 15 mg/m3.  The exposure level was derived from samples collected over a 157 minute sampling period with zero exposure assumed for the unsampled period of 323 minutes.  b)   On February 7, 2019, employees abrasive blast cleaning a locomotive in the Abrasive Blast Building at National Railway Equipment Company were exposed to an 8-hour time weighted average level of 722.8 mg/m3 for Particulates Not Otherwise Regulated (PNOR), approximately 48.19 times the Permissible Exposure Limit of 15 mg/m3.  The exposure level was derived from samples collected over a 416 minute sampling period with zero exposure assumed for the unsampled period of 16 minutes.

Issued

May 29, 2019

Abate by

Jun 27, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 9135

General-duty citation text

29 CFR 1910.1000(e): Feasible administrative or engineering controls had not been determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):  On or about February 7, 2019, employees abrasive blast cleaning a locomotive in the Abrasive Blast Building at National Railway Equipment Company were exposed to Particulates Not Otherwise Regulated (PNOR) in excess of the permissible exposure limit and feasible administrative and/or engineering controls were not implemented.  General methods of control applicable in these circumstances include, but are not limited to, the following:  a) Limit worker access to the areas where exposure may exceed the PEL;  b) Conduct frequent inspections of the worksite to evaluate equipment function and work practices;  c) Test and balance the cross-draft ventilation in the Abrasive Blasting Building to ensure optimal performance and correction of the imbalances observed on each leg of the MAU/Exhaust. Average industrial dusts typically require a duct velocity of 4000 fpm while heavy industrial dusts requires 5000 fpm;  d) Eliminate broom sweeping and shoveling as a means of housekeeping and use a HEPA vacuum or wet methods to capture settled particles;  e) Increase the frequency of removing settled dusts from floors and ledges;  f) Install and utilize static pressure gauges to allow the operators to visual proper operation of the exhaust system;  g) Use barriers and curtain walls to isolate the blasting operations occurring on either side of the locomotive;  h) Install wet, semi-automatic, or fully-automatic blasting operations to reduce exposure to airborne dusts by suppression;  i) Provide wash stations so workers can wash their hands and face routinely and before eating, drinking, or smoking;  j) Vacuum or remove contaminated work clothes before eating, drinking, or smoking;  k) Provide accommodations for end-of-shift showers and change areas with separate storage facilities for street clothes, protective clothing, and equipment; and  l) Administratively rotate employees to ensure exposures are below the allowable exposure limits.