OSHA Inspection: YELLOW CREEK CASTING CO., INC.

Issued

Aug 2, 2019

Penalty

Initial $4,774 · Current $2,864 Reduced

General-duty citation text

1910.134(g)(1)(i)(A): The employer did not prohibit a tight-fitting facepiece to be worn by employees who had facial hair that comes between the sealing surface of the facepiece and the face:    On or about May 1, 2019 the employer allowed workers in the melt and pouring areas to wear the 3M tight-fitting facepiece respirators with several days growth of facial hair.

Issued

Aug 2, 2019

Abate by

Dec 9, 2019

Penalty

Initial $4,774 · Current $2,864 Reduced

General-duty citation text

29 CFR 1910.1025(c)(1): Employee(s) were exposed to lead at concentrations greater than fifty micrograms per cubic meter of air averaged over an eight-hour period:    On or about May 15, 2019, employees in the foundry area were exposed to lead above the time weighted average (TWA) permissible exposure level (PEL) of 50 ug/M3 including, but not limited to the following workers:    a.  The furnace tender was exposed to lead at a TWA of 179 ug/M3, which is approximately 3.58 times the permissible exposure limit (PEL) of 50 ug/M3, for 288 minutes.  Zero exposure assumed for the time not sampled.     b.  A pouring operator was exposed to lead at a TWA of 53 ug/M3, which is approximately 1.06 times the PEL of 50 ug/M3, for 285 minutes.  Zero exposure assumed for the time not sampled.    c.  A pouring operator was exposed to lead at a TWA of 75 ug/M3, which is approximately 1.5 times the PEL of 50 ug/M3, for 274 minutes.  Zero exposure assumed for the time not sampled.

Issued

Aug 2, 2019

Abate by

Oct 7, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(d)(2): An initial determination was not made to determine if any employee may be exposed to lead at or above the action level:    On or about May 15, 2019, the employer did not conduct initial exposure monitoring for the foundry workers who were found to be exposed to lead above the time weighted average (TWA) action level (AL) of 30 micrograms per cubic meter (ug/M3) including, but not limited to the following workers:    a.  The furnace tender was exposed to lead at a TWA of 179 ug/M3, which is approximately 5.96 times the action level (AL), for 288 minutes.  Zero exposure assumed for the time not sampled.     b.  A pouring operator was exposed to lead at a TWA of 53 ug/M3, which is approximately 1.76 times the AL,  for 285 minutes.  Zero exposure assumed for the time not sampled.    c.  A pouring operator was exposed to lead at a TWA of 75 ug/M3, which is approximately 2.5 times the AL, for 274 minutes.  Zero exposure assumed for the time not sampled.    d. A pouring operator was exposed to lead at a TWA of 45 ug/M3, which is approximately 1.5 times the AL, for 279 minutes.  Zero exposure assumed for the time not sampled.

Issued

Aug 2, 2019

Abate by

Dec 9, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(e)(1)(i): For any employees exposed to lead above the permissible exposure limit for more than 30 days per year the employer did not implement engineering and work practice controls (including administrative controls) were not implemented to reduce and maintain employee exposure to lead:    On or about May 15, 2019, employees in the foundry area were exposed to lead above the time weighted average (TWA) permissible exposure level (PEL) of 50 ug/M3 including, but not limited to the following workers:    a.  The furnace tender was exposed to lead at a TWA of 179 ug/M3, which is approximately 3.58 times the permissible exposure limit (PEL) of 50 ug/M3, for 288 minutes.  Zero exposure assumed for the time not sampled.     b.  A pouring operator was exposed to lead at a TWA of 53 ug/M3, which is approximately 1.06 times the PEL of 50 ug/M3, for 285 minutes.  Zero exposure assumed for the time not sampled.    c.  A pouring operator was exposed to lead at a TWA of 75 ug/M3, which is approximately 1.5 times the PEL of 50 ug/M3, for 274 minutes.  Zero exposure assumed for the time not sampled.      General methods of control applicable in these circumstances include, but are not limited to the following:      1)      Re-evaluate the overhead ventilations systems for ways to improve air movement/capture of the high levels of metal fumes generated while melting and pouring to further ensure the most adequate removal of the metal fume from the worker exposure;      2)     Re-evaluate the existing work practices and/or administrative controls in and around the melting and pouring areas to reduce the worker exposures to the airborne contaminants     3)    Explore the utilization of a downdraft table/platform with local exhaust ventilation to further assist in removal of the high levels of metal fume    4)    Explore a more thorough acquisition of scrap and materials used in the process to ensure as much as feasible material with no or as little as possible lead content.      Step 1: Effective respiratory protection shall be provided and used by exposed employees as an interim protective measure until feasible engineering and/or whatever such controls fail to reduce employee exposure to within permissible exposure limits.  (Abatement must be completed by ***30 days** after issue)      Step 2:  Submit to the Area Director a written plan of abatement outlining a schedule for the implementation of engineering and/or administrative measures control employee exposure to hazardous substances in this citation.  This plan shall include, at a minimum, target dates for the following actions which must be consistent with the abatement dates required by this citation:    1)    Evaluation of the extent and location of the hazard source    2)    Evaluation of control measure options    3)    Selection of optimum control methods    4)    Ordering and delivery of equipment and material(s)    5)    Installation of control measures    6)    Training of employees in proper operation and maintenance of newly-implemented control measures    7)    Assurance of effective performance of control measures      NOTE:  All proposed control measures shall be approved for such particular use by a competent industrial hygienist or other technically qualified person.  (Abatement must be completed by ** 30 days** from issuance)      Step 3:  Abatement shall have been completed by the implementation of feasible engineering and/or administrative controls upon verification of their effectiveness in achieving compliance.  (Abatement must be completed by **60 days** from issuance)

Issued

Aug 2, 2019

Abate by

Dec 9, 2019

Penalty

Initial $4,774 · Current $2,864 Reduced

General-duty citation text

29 CFR 1910.1025(e)(3)(i): The employer did not establish and implement a written compliance program to reduce exposures to or below the permissible exposure limit, solely by means of engineering and work practice controls:    On or about May 15, 2019, a written compliance program was not in place in the furnace and pouring areas for at least the worker overexposures discussed in Cit. 1, item 2(a).

Issued

Aug 2, 2019

Abate by

Dec 9, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1025(l)(1)(ii): The employer did not train each employee who is subject to exposure to lead at or above the action level, or for whom the possibility of skin or eye irritation exists, in accordance with the requirements of 29 CFR 1910.1025:    On or about May 15, 2019, the employer had not instituted the required training program for the workers in the furnace and pouring areas for at least the worker overexposures discussed in Cit. 1, item 2(b).

Issued

Aug 2, 2019

Abate by

Oct 7, 2019

Penalty

Initial $0 · Current $2,846

General-duty citation text

29 CFR 1910.1025(i)(3)(i): Employee(s) exposed to lead in excess of the permissible exposure limit (PEL), without regard to the use of respirators, were not required to shower at the end of the work shift:     On or about May 15, 2019, employees in the foundry area were exposed to lead above the time weighted average (TWA) permissible exposure level (PEL) of 50 ug/M3 including, but not limited to the following workers:    a.  The furnace tender was exposed to lead at a TWA of 179 ug/M3, which is approximately 3.58 times the permissible exposure limit (PEL) of 50 ug/M3, for 288 minutes.  Zero exposure assumed for the time not sampled. The employee did not shower at the end of the work shift before leaving the site.     b.  A pouring operator was exposed to lead at a TWA of 53 ug/M3, which is approximately 1.06 times the PEL of 50 ug/M3, for 285 minutes.  Zero exposure assumed for the time not sampled. The employee did not shower at the end of the work shift before leaving the site.     c.  A pouring operator was exposed to lead at a TWA of 75 ug/M3, which is approximately 1.5 times the PEL of 50 ug/M3, for 274 minutes.  Zero exposure assumed for the time not sampled. The employee did not shower at the end of the work shift before leaving the site.

Issued

Aug 2, 2019

Abate by

Oct 7, 2019

Penalty

Initial $4,774 · Current $2,846 Reduced

General-duty citation text

29 CFR 1910.1025(j)(1)(i):  The employer did not institute a medical surveillance program for all employees who are or may be exposed at or above the action level for more than 30 days per year:    On or about May 15, 2019, the employer did not institute a medical surveillance program for employees who were or could be exposed to lead above the action level. Employees in the foundry area were exposed to lead above the time weighted average (TWA) action level (AL) of 30 ug/M3 including, but not limited to the following workers:    a.  The furnace tender was exposed to lead at a TWA of 179 ug/M3, which is approximately 5.96 times the action limit (AL) of 30 ug/M3, for 288 minutes.  Zero exposure assumed for the time not sampled.      b.  A pouring operator was exposed to lead at a TWA of 53 ug/M3, which is approximately 1.76 times the AL of 30 ug/M3, for 285 minutes.  Zero exposure assumed for the time not sampled.     c.  A pouring operator was exposed to lead at a TWA of 75 ug/M3, which is approximately 2.5 times the AL of 30 ug/M3, for 274 minutes.  Zero exposure assumed for the time not sampled.     d. A pouring operator was exposed to lead at a TWA of 45 ug/M3, which is approximately 1.5 times the AL of 30 ug/M3, for 279 minutes.  Zero exposure assumed for the time not sampled.

Issued

Aug 2, 2019

Abate by

Sep 19, 2019

Penalty

Initial $4,774 · Current $2,864 Reduced

General-duty citation text

29 CFR 1910.1025(m)(2)(i): The employer did not post warning signs in each work area, with at least the information described below, where the permissible exposure limit was exceeded:      On or about May 15, 2019, the employer did not post as required in the furnace and pouring areas the necessary information for employees who were or could be exposed to lead above the permissible exposure limit. Employees in the foundry area were exposed to lead above the time weighted average (TWA) permissible exposure limit (PEL) of 50 ug/M3 including, but not limited to the following workers:    a.  The furnace tender was exposed to lead at a TWA of 179 ug/M3, which is approximately 3.58 times the permissible exposure limit (PEL) of 50 ug/M3, for 288 minutes.  Zero exposure assumed for the time not sampled.      b.  A pouring operator was exposed to lead at a TWA of 53 ug/M3, which is approximately 1.06 times the PEL of 50 ug/M3, for 285 minutes.  Zero exposure assumed for the time not sampled.     c.  A pouring operator was exposed to lead at a TWA of 75 ug/M3, which is approximately 1.5 times the PEL of 50 ug/M3, for 274 minutes.  Zero exposure assumed for the time not sampled.     Warning Signs Would Include:  DANGER  LEAD  MAY DAMAGE FERTILITY OR THE UNBORN CHILD  CAUSES DAMAGE TO THE CENTRAL NERVOUS SYSTEM  DO NOT EAT, DRINK, OR SMOKE IN THIS AREA