OSHA Inspection: ROSS ALUMINUM CASTINGS, LLC

Issued

Sep 1, 2020

Abate by

Sep 11, 2020

Penalty

Initial $9,446 · Current $4,700 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.101(b): The in-plant handling, storage, and utilization of all compressed gases in cylinders, portable tanks, rail tankcars, or motor vehicle cargo tanks were not utilized in accordance with Compressed Gas Association Pamphlet P-1-1965, which is incorporated by reference as specified in Sec. 1910.6:       a)     Ross Aluminum Casting, LLC,  located at 815 N. Oak Ave. Sidney, OH, on or about March 12th, 2020, employees in the aluminum cast degassing area were tasked to use a wrench to open and close a 150 lb. chlorine gas cylinder exposing them to a potential explosive pressure release, toxic gas exposure, corrosive oxidizing agent and skin burn hazards.          Abatement Note:  Per CGA Section P-1 3.4.9: Never use wrenches or tools except those provided or approved by the gas manufacturer. Avoid the use of a wrench on valves equipped with handwheels. Never hammer the valve wheel in attempting to open or close the valve. For valves that are hard to open, or frozen because of corrosion, contact the supplier for instructions.

Issued

Sep 1, 2020

Abate by

Oct 16, 2020

Penalty

Initial $9,446 · Current $4,600 Reduced

Hazardous substances 0640

General-duty citation text

29 CFR 1910.120(q)(1): The employer did not develop and implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:     a) Ross Aluminum Casting, LLC, located at 815 N. Oak Ave. Sidney, OH, on or about March 12th, 2020, the employer did not develop an emergency response plan to address the potential catastrophic release of chlorine from a 150  pound cylinder located in the aluminum cast degassing production area, potentially exposing employees that work in that area to chlorine gas, which can result in serious injury to death.

Issued

Sep 1, 2020

Abate by

Nov 30, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 0640

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer did not identify and evaluate 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.     a)     Ross Aluminum Casting, LLC located at 815 N. Oak Ave. Sidney, OH, on or about March 12th, 2020, employees working in the aluminum cast degassing operation  were required to insert chlorine gas manually into molten aluminum and were not evaluated for the respirable hazards of chlorine to include the 1ppm ceiling exposure limit and the IDLH.  Employees working near and around the furnace area are not protected against exposure to immediately dangerous to life or health (IDLH) levels of toxic Chlorine gas. Acute chlorine toxicity can cause adverse health effects, such as but not limited to burns and corneal abrasions, damage to the respiratory tract dyspnea, violent cough, nausea, vomiting, lightheadedness, headache, chest pain, abdominal discomfort, and corneal burns in addition to the same symptoms of low-level acute exposure. Chronic exposure to chlorine gas can lead to chest pain, cough, sore throat, and hemoptysis.

Issued

Sep 1, 2020

Abate by

Nov 30, 2020

Penalty

Initial $9,446 · Current $4,700 Reduced

Hazardous substances 9000

General-duty citation text

29 CFR 1910.1053(d)(1): The employer did not assess the exposure of each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level in accordance with either the performance option in paragraph (d)(2) or the scheduled monitoring option in paragraph (d)(3) of this section.    a)     Ross Aluminum Casting, LLC, located at 815 N. Oak Ave. Sidney, OH, on or about March 12th, 2020, employees working in the loop, assembly, and knockout area were exposed to crystalline silica levels of 31µg/m3 - 50 µg/m3. The employer did not reassess the exposure of each employee to respirable crystalline silica at or above the action level when the engineering controls were not in operation. The employees were still performing their daily tasks in the same area of operations where they are exposed to levels that exceeded the applicable OELs for respirable crystalline silica.

Issued

Sep 1, 2020

Abate by

Nov 30, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 9000

General-duty citation text

29 CFR 1910.1053(d)(3)(iii): Where the most recent exposure monitoring indicates that employee exposures are at or above the action level but at or below the PEL, the employer did not repeat such monitoring within six months of the most recent monitoring.    a) Ross Aluminum Casting, LLC, located at 815 N. Oak Ave. Sidney, OH, on or about March 12th, 2020, employees working in the loop, assembly, and knockout area were potentially exposed to crystalline silica levels above the action level.  The employer did not re-sample within six months of BWCs initial sampling where monitoring results indicated levels of 31µg/m3 - 50 µg/m3.

Issued

Sep 1, 2020

Abate by

Apr 30, 2021

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) Ross Aluminum Casting, LLC, located at 815 N. Oak Ave. Sidney, OH, on or about March 12th, 2020,  employees working in the Knockout/Shake out, assembly, loop and molding area were potentially over-exposed to respirable crystalline when engineering and/or work practice controls were not effective or not used in certain areas of the production facility.      Multi-step abatement       Step 1:  Effective respiratory protection shall be provided 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:  Submit to the Area Director a written, detailed plan of abatement outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposure 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.      Step 3:  Abatement shall have been completed by the implementation of feasible engineering controls and/or administrative controls upon verification of their effectiveness in achieving compliance.      Feasible engineering controls include, but are not limited to:  1.     Provide local ventilation to limit exposure to within acceptable limits; the system shall be inspected periodically.  2.     Portable engineering control devices can be used at the location to collect the airborne respirable crystalline silica, i.e., local HEPA filtered ventilation systems.        Date by which Step 1 must be abated:   /   /       Date by which Step 2 must be abated:   /   /      Date by which Step 3 must be abated:   /   /

Issued

Sep 1, 2020

Abate by

Sep 15, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 9000

General-duty citation text

29 CFR 1910.1053(f)(2)(ii): The employer did not review and evaluate the effectiveness of the written exposure control plan at least annually and update it as necessary.      a)     Ross Aluminum Casting, LLC, located at 815 N. Oak Ave. Sidney, OH, on or about March 12th, 2020, the employer did not review and evaluate the effectiveness of the written exposure control plan at least annually and update it as necessary. The employees working in the loop, assembly, and knockout area were exposed to crystalline silica levels above the action level where the most recent monitoring results show levels of 31µg/m3 - 50 µg/m3 at the production facility.

Issued

Sep 1, 2020

Abate by

Sep 25, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 9000

General-duty citation text

29 CFR 1910.1053(g)(1): Where respiratory protection is required by this section, the employer did not provide each employee an appropriate respirator that complies with the requirements of this paragraph and 29 CFR 1910.134. Respiratory protection is required.  a) Ross Aluminum Casting, LLC, located at 815 N. Oak Ave. Sidney, OH, on or about March 12th, 2020, employees working in the loop, assembly and knockout areas were exposed to crystalline silica levels above the action level without being provided with respirators.

Issued

Sep 1, 2020

Abate by

Sep 25, 2020

Penalty

Initial $0 · Current $0

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 the employee, and at a reasonable time and place, for each employee who will be occupationally exposed to respirable crystalline silica at or above the action level for 30 or more days per year.   a)     Ross Aluminum Casting, LLC, located at 815 N. Oak Ave. Sidney, OH, on or about March 12th, 2020, employees were exposed to respirable crystalline silica levels above the action level (AL) while working in the loop, assembly, and knockout area and had not received a medical evaluation as required by the standard.

Issued

Sep 1, 2020

Abate by

Sep 25, 2020

Penalty

Initial $0 · Current $0

Hazardous substances 9000

General-duty citation text

29 CFR 1910.1053(j)(3)(i): The employer did not ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following:  a)     Ross Aluminum Casting, LLC, located at 815 N. Oak Ave. Sidney, OH, on or about March 12th, 2020, employees conducting molding, knockout, and resurfacing of aluminum cast products did not receive the proper training that enables them to understand the health hazards associated with exposure to respirable crystalline silica while working in a silica regulated area; exposing the employees to respirable crystalline silica hazards which can cause adverse health effects, such as but not limited to, silicosis.