OSHA Inspection: STRONG INDUSTRIES, INC.

Issued

Mar 5, 2020

Abate by

Apr 9, 2020

Penalty

Initial $7,634 · Current $4,000 Reduced

Hazardous substances 1073

General-duty citation text

29 CFR 1910.132(d)(1): The employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE):    a) Spray Booth: Employees worked with hazardous chemicals (e.g., Isotec Acrylobond HD Iso) that necessitated the use of personal protective equipment, and the employer did not perform the required hazard assessment for PPE, as discovered on or about 10/02/2019.    ABATEMENT CERTIFICATION REQUIRED      ABATEMENT NOTE:  The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.

Issued

Mar 5, 2020

Abate by

Apr 9, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 1073

General-duty citation text

29 CFR 1910.132(a): Protective equipment was not used when necessary whenever hazards capable of causing injury and impairment were encountered:  a) Spray Booth: An employee (sprayer/helper) was exposed to overspray from the isocyanate-containing chemical, Isotec Acrylobond HD Iso, and the employer did not require this employee to wear appropriate arm protection that covered all exposed skin, as discovered on or about 10/24/2019.  ABATEMENT CERTIFICATION REQUIRED

Issued

Mar 5, 2020

Abate by

Apr 9, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 1073

General-duty citation text

29 CFR 1910.138(a): The employer did not select and require employees to use appropriate hand protection when employees hands were exposed to hazardous condition:  a) Spray Booth: Employees sprayed the isocyanate-containing chemical, Isotec Acrylobond HD Iso, and the employer did not require these employees to wear impervious hand protection while spraying this chemical, as discovered on or about 10/24/2019.  ABATEMENT CERTIFICATION REQUIRED

Issued

Mar 5, 2020

Abate by

Apr 9, 2020

Penalty

Initial $11,450 · Current $7,000 Reduced

Hazardous substances 1073

General-duty citation text

29 CFR 1910.134(c)(1): The employer did not establish and implement a written respiratory protection program with worksite-specific procedures when respirators were necessary to protect the health of the employee(s):    a) Spray Booth: Employees were overexposed to the OSHA Permissible Exposure Limit (Ceiling) for Methylene bisphenyl isocyanate (MDI) while spraying a two-component polyurethane, and the employer did not establish and implement a written respiratory protection program when respirators were necessary to protect the health of employees, as discovered on or about 10/24/2019.    ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED

Issued

Mar 5, 2020

Abate by

Jul 15, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 1073

General-duty citation text

29 CFR 1910.1000(a)(1): Employees were exposed to an airborne concentration of Methylene bisphenyl isocyanate (MDI) listed in Table Z-1 in excess of the ceiling concentration of 0.2 milligrams per cubic meter:    a) Spray Booth: An employee, Sprayer and Helper, was exposed to Methylene bisphenyl isocyanate (MDI) at a concentration of 0.2377 milligrams per cubic meter of air, approximately 1.2 times the Permissible Exposure Limit (Ceiling) of 0.2 milligrams per cubic meter of air.  Sampling was performed for 18 minutes on October 24, 2019.     b) Spray Booth: An employee, Sprayer and Helper, was exposed to Methylene bisphenyl isocyanate (MDI) at a concentration of 0.3118 milligrams per cubic meter of air, approximately 1.6 times the Permissible Exposure Limit (Ceiling) of 0.2 milligrams per cubic meter of air.  Sampling was performed for 18 minutes on October 24, 2019.     ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED

Issued

Mar 5, 2020

Abate by

Jul 15, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 1073

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) Spray Booth: An employee, Sprayer and Helper, was exposed to Methylene bisphenyl isocyanate (MDI) at a concentration of 0.2377 milligrams per cubic meter of air, approximately 1.2 times the Permissible Exposure Limit (Ceiling) of 0.2 milligrams per cubic meter of air.  Sampling was performed for 18 minutes on October 24, 2019.  The employer did not implement feasible administrative and/or engineering controls to reduce employee exposure levels to below the Permissible Exposure Limit for MDI.    b) Spray Booth: An employee, Sprayer and Helper, was exposed to Methylene bisphenyl isocyanate (MDI) at a concentration of 0.3118 milligrams per cubic meter of air, approximately 1.6 times the Permissible Exposure Limit (Ceiling) of 0.2 milligrams per cubic meter of air.  Sampling was performed for 18 minutes on October 24, 2019.  The employer did not implement feasible administrative and/or engineering controls to reduce employee exposure levels to below the Permissible Exposure Limit for MDI.    ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED      GENERAL METHODS OF CONTROL APPLICABLE IN THESE CIRCUMSTANCES INCLUDE, BUT ARE NOT LIMITED TO, THE FOLLOWING:    - Increase ventilation inside the spray booth.    - Increase housekeeping inside the spray booth.    - Train the helper employee to not remain inside the spray booth when not actively assisting the sprayer employee.      - Relocate the supply of support blocks to outside of the spray booth.      - Automate the spray booth process.       Abatement Schedule:    Step 1.  Effective respiratory protection shall be provided to and used by exposed employees as an interim protective measure until feasible engineering and/or administrative controls can be implemented or whenever such controls fail to reduce employee exposure to within permissible exposure limits.    Step 2.  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 abatement dates required by this citation:    (1)  Evaluation of engineering/administrative control options;  (2)  Selection of optimum control methods and completion of design;  (3)  Procurement, installation, and operation of selected control measures;  (4)  Testing and acceptance or modification/redesign of controls.      All proposed control measures shall be approved for each particular use by a competent industrial hygienist or other technically qualified person.  45-day progress reports are required during the abatement period.    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.    Date by which violation must be abated:  Step 1  00/00/00  Date by which violation must be abated:  Step 2  00/00/00  Date by which violation must be abated:  Step 3  00/00/00

Issued

Mar 5, 2020

Abate by

Apr 9, 2020

Penalty

Initial $22,901 · Current $10,000 Reduced

Hazardous substances 1073

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 chemical hazard that the employees had not been previously trained about was introduced into their work area:    a) Spray Booth: Employees were overexposed to MDI while working with the isocyanate-containing chemical, Isotec Acrylobond HD Iso, and the employer did not provide these employees with hazard communication training specific to isocyanate exposure, as discovered on or about 10/24/2019.    b) Spray Booth: Employees worked with hazardous chemicals, including, but not limited to, acetone, and the employer did not provide these employees with hazard communication training, as discovered on or about 10/02/2019.    ABATEMENT CERTIFICATION AND DOCUMENTATION RECQUIRED    The employer, Strong Industries, Inc., was previously cited for a violation of this Occupational Safety and Health Standard, which was contained in OSHA inspection number 1122254, citation number 01, item number 02a, and was affirmed as a final order on 05/02/2016, with respect to a workplace located at 3204 Point Township Drive, Northumberland, PA 17857.

Issued

Mar 5, 2020

Abate by

Apr 9, 2020

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(7)(i): The employer did not provide training to ensure that the purpose and function of the energy control program were understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls were acquired by employees:  a) Spray Booth: Employees locked-out the power to the spray booth's fans prior to performing work on their blades, and the employer did not provide these employees with lockout/tagout training, as discovered on or about 10/02/2019.  ABATEMENT CERTIFICATION REQUIRED