OSHA Inspection: KEY STRUCTURES, LLC

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $10,409 · Current $5,204 Reduced

General-duty citation text

29 CFR  1910.27(a):Scaffolds used in general industry did not meet the requirements in 29 CFR part 1926, subpart L (Scaffolds):   a) Main Work Area: On or about September 10, 2020, and at times prior, employees were exposed to fall hazards of 7 feet to the floor surface below as casters and wheels of mobile scaffolds were not locked with positive wheel and/or wheel and swivel locks, or equivalent means, to prevent movement of the scaffold while the scaffold was used in a stationary manner (per 29 CFR 1926.452(w)(2)).  b) Main Work Area: On or about September 10, 2020, and at times prior, employees were exposed to fall hazards of 7 feet to the floor surface below as manual force used to move the scaffold was applied more than 5 feet (1.5 m) above the supporting surface (per 29 CFR 1926.452(w)(3)).  c) Main Work Area: On or about September 10, 2020, and at times prior, employees were exposed to fall hazards of 7 feet as employees were not trained by a qualified person to recognize the hazards associated with the type of scaffold being used and how to control or minimize those hazards (per 29 CFR 1926.454(a)).  Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $6,940 · Current $3,470 Reduced

General-duty citation text

29 CFR  1910.28(b)(1)(i): The employer did not ensure that each employee on a walking-working surface with an unprotected side or edge that is 4 feet (1.2m) or more above a lower level was protected from falling by guardrail systems, safety net system, or personal fall arrest system:  a) Wrapping Area: On our about September 10, 2020, and at times prior, employees were exposed to fall hazards in excess of 13 feet in height while performing wrapping operations that require employees to walk on the roof surfaces of completed manufactured housing.  b) Framing Area: On our about September 10, 2020, and at times prior, employees were exposed to fall hazards in excess of 13 feet in height while performing framing operations that require employees to climb onto roof framing in order to release crane hooks from the roof.  Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $5,205 · Current $2,602 Reduced

General-duty citation text

29 CFR  1910.28(b)(3)(ii):(ii) Each employee was not protected from tripping into or stepping into or through any hole that is less than 4 feet (1.2 m) above a lower level by covers or guardrail systems:  a) Main Work Floor: On or about September 10, 2020, and at times prior, employees were exposed to tripping hazards from removed railway track rails. Removal of the rails left two parallel floor holes approximately 8 feet in length with a depth of two inches, and width of four inches.  Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $10,409 · Current $5,204 Reduced

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:  a) Key Structures, LLC.: On or about September 10, 2020, and at times prior, employees were exposed to respiratory hazards from chemicals such as, but not limited to; Titanium Dioxide, Propanoic Acid, Zinc Oxide, and Diuron  (CORONADO SUPER KOTE 5000 EXTERIOR ACRYLIC SATIN), and Titanium Dioxide, Silica, and Ammonia (BENJAMIN MOORE SUPER HIDE ZERO VOC INTERIOR LATEX) while using these chemicals in various phases of the manufactured housing door, interior, and exterior painting process. The employer did not provide medical evaluations to employees required to use the respirators as required in 1910.134(c)(1)(ii).  b) Key Structures, LLC.: On or about September 10, 2020, and at times prior, employees were exposed to respiratory hazards from chemicals such as, but not limited to; Titanium Dioxide, Propanoic Acid, Zinc Oxide, and Diuron  (CORONADO SUPER KOTE 5000 EXTERIOR ACRYLIC SATIN), and Titanium Dioxide, Silica, and Ammonia (BENJAMIN MOORE SUPER HIDE ZERO VOC INTERIOR LATEX) while using these chemicals in various phases of the manufactured housing door, interior, and exterior painting process. The employer did not provide fit testing procedures for tight-fitting respirators to employees required to use the respirators as required in 1910.134(c)(1)(iii).  c) Key Structures, LLC.: On or about September 10, 2020, and at times prior, employees were exposed to respiratory hazards from chemicals such as, but not limited to; Titanium Dioxide, Propanoic Acid, Zinc Oxide, and Diuron  (CORONADO SUPER KOTE 5000 EXTERIOR ACRYLIC SATIN), and Titanium Dioxide, Silica, and Ammonia (BENJAMIN MOORE SUPER HIDE ZERO VOC INTERIOR LATEX)  while using these chemicals in various phases of the manufactured housing door, interior, and exterior painting process. The employer did not provide procedures for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators of employees required to use the respirators as required in 1910.134(c)(1)(v).  d) Key Structures, LLC.: On or about September 10, 2020, and at times prior, employees were exposed to respiratory hazards from chemicals such as, but not limited to; Titanium Dioxide, Propanoic Acid, Zinc Oxide, and Diuron  (CORONADO SUPER KOTE 5000 EXTERIOR ACRYLIC SATIN), and Titanium Dioxide, Silica, and Ammonia (BENJAMIN MOORE SUPER HIDE ZERO VOC INTERIOR LATEX)  while using these chemicals in various phases of the manufactured housing door, interior, and exterior painting process. The employer did not provide training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations for employees required to use the respirators as required in 1910.134(c)(1)(vii).  e) Key Structures, LLC.: On or about September 10, 2020, and at times prior, employees were exposed to respiratory hazards from chemicals such as, but not limited to; Titanium Dioxide, Propanoic Acid, Zinc Oxide, and Diuron  (CORONADO SUPER KOTE 5000 EXTERIOR ACRYLIC SATIN), and Titanium Dioxide, Silica, and Ammonia (BENJAMIN MOORE SUPER HIDE ZERO VOC INTERIOR LATEX)  while using these chemicals in various phases of the manufactured housing door, interior, and exterior painting process. The employer did not provide training on putting on, removing, or the limitations of the respirators for employees required to use the respirators as required in 1910.134(c)(1)(viii).  f) Key Structures, LLC.: On or about September 10, 2020, and at times prior, employees were exposed to respiratory hazards from chemicals such as, but not limited to; Titanium Dioxide, Propanoic Acid, Zinc Oxide, and Diuron  (CORONADO SUPER KOTE 5000 EXTERIOR ACRYLIC SATIN), and Titanium Dioxide, Silica, and Ammonia (BENJAMIN MOORE SUPER HIDE ZERO VOC INTERIOR LATEX)  while using these chemicals in various phases of the manufactured housing door, interior, and exterior painting process. The employer did not establish work-site specific procedures to regularly evaluate the effectiveness of the program as required in 1910.134(c)(1)(ix).  Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(e)(1):The employer did not provide 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:  a) Key Structures, LLC.: On or about September 10, 2020, and at times prior, employees were exposed to respiratory hazards from chemicals such as, but not limited to; Titanium Dioxide, Propanoic Acid, Zinc Oxide, and Diuron  (CORONADO SUPER KOTE 5000 EXTERIOR ACRYLIC SATIN), and Titanium Dioxide, Silica, and Ammonia (BENJAMIN MOORE SUPER HIDE ZERO VOC INTERIOR LATEX) while using these chemicals in various phases of the manufactured housing door, interior, and exterior painting processes. The employer did not provide medical evaluations to employees required to use half-mask tight fitting respirators.  Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(f)(2):Employee(s) using a tight-fitting facepiece respirator were not annually fit tested:  a) Key Structures, LLC.: On or about September 10, 2020, and at times prior, employees were exposed to respiratory hazards from chemicals such as, but not limited to; Titanium Dioxide, Propanoic Acid, Zinc Oxide, and Diuron  (CORONADO SUPER KOTE 5000 EXTERIOR ACRYLIC SATIN), and Titanium Dioxide, Silica, and Ammonia (BENJAMIN MOORE SUPER HIDE ZERO VOC INTERIOR LATEX) while using these chemicals in various phases of the wood treatment process. The employer did not provide fit testing procedures for tight-fitting respirators to employees required to use half-mask tight fitting respirators.  Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(k)(1):The employer did not provide effective training to ensure that each employee could demonstrate knowledge of 1910.134(k)(1)(i) - (vii):  a) Key Structures, LLC.: On or about September 10, 2020, and at times prior, employees were exposed to respiratory hazards from chemicals such as, but not limited to; Titanium Dioxide, Propanoic Acid, Zinc Oxide, and Diuron (CORONADO SUPER KOTE 5000 EXTERIOR ACRYLIC SATIN), and Titanium Dioxide, Silica, and Ammonia (BENJAMIN MOORE SUPER HIDE ZERO VOC INTERIOR LATEX) while using these chemicals in various phases of the wood treatment process. The employer did not provide training on putting on, removing, or the limitations of the respirators for employees required to use half-mask tight fitting respirators. The employer did not provide training on maintenance and storage of half-mask tight fitting respirators, nor on proper fit or seal-check.  Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $8,675 · Current $4,338 Reduced

General-duty citation text

29 CFR  1910.179(j)(3): The following items were not be inspected for defects at intervals as defined in paragraph (j)(1)(ii) of this section or as specifically indicated, including observation during operation for any defects which might appear between regular inspections:  a) Main Work Floor: On or about September 10, 2020, and at times prior, employees were exposed to struck-by and crushing hazards by overhead gantry cranes in the facility. Cranes had not been periodically (one to twelve month intervals) inspected.  Abatement Note:  Abatement certification and documentation are required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $12,145 · Current $6,072 Reduced

General-duty citation text

29 CFR  1910.179(b)(8):Employee(s) other than designated personnel were permitted to operate crane(s):  a) Overhead Cranes: On or about September 10, 2020, and at times prior, employees were exposed to struck-by and crushing hazards as employees using the cranes were not designated personnel.  Abatement Note:  Abatement certification and documentation are required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $5,205 · Current $2,602 Reduced

General-duty citation text

29 CFR  1910.334(a)(2)(i): Portable cord and plug connected equipment and flexible cord sets (extension cords) were not visually inspected before use on any shift for external defects (such as loose parts, deformed and missing pins, or damage to outer jacket or insulation) and for evidence of possible internal damage (such as pinched or crushed outer jacket):  a) Near Door Painting Spray Area: On or about September 10, 2020, and at times prior, employees were exposed to electrical shock hazards while using extension cords and equipment, such as a Titan 740 Impact Electric Paint Sprayer, with damage to the outer jacket of the cords.  Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $1,735 · Current $868 Reduced

General-duty citation text

29 CFR  1904.29(b)(3):  The employer did not enter each recordable injury or illness on the OSHA 300 Log and 301 Incident Report within seven (7) calendar days of receiving information that a recordable injury or illness has occurred:  a) Key Structures, LLC,: On or about September 10, 2020 and at times prior the employer did not keep records of employee injuries on OSHA 300 and 301 forms or equivalent forms.  Abatement Note:  Abatement certification and documentation are required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.94(c)(4)(i): Spray room(s) including floors were not constructed of masonry, concrete or other noncombustible material:  a) Door Painting Spray Area: On or about September 10, 2020, and at times prior, employees were exposed to ventilation hazards while spraying paint onto door surfaces with a Titan 740 Impact Electric Paint Sprayer in the door spray area. Spray area is constructed of plywood and tarps, with no doors or shutters.  Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Feb 5, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.94(c)(4)(ii): Spray rooms did not have noncombustible fire doors and shutters:  a) Door Painting Spray Area: On or about September 10, 2020, and at times prior, employees were exposed to ventilation hazards while spraying paint onto door surfaces with a Titan 740 Impact Electric Paint Sprayer in the door spray area. Spray area is constructed of plywood and tarps, with no doors or shutters.  Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").

Issued

Dec 9, 2020

Abate by

Jan 6, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.157(e)(2): Portable fire extinguishers were not visually inspected at least monthly:   a) Doors Painting Spray Room: On or about September 10, 2020, and at times prior, a fire extinguisher in the door painting spray area had not been visually inspected and overspray buildup on the extinguisher had not been corrected.  Abatement Note:  Abatement certification is required for this item (see enclosed "Certification of Corrective Action Worksheet").