OSHA Inspection: SCHNEIDER ELECTRIC

Issued

Mar 15, 2021

Abate by

Apr 29, 2021

Penalty

Initial $6,436 · Current $3,500 Reduced

General-duty citation text

29 CFR  1910.134(c)(1): In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer shall establish and implement a written respiratory protection program with worksite-specific procedures. The program shall be updated as necessary to reflect those changes in workplace conditions that affect respirator use. The employer shall include in the program the following provisions of this section, as applicable: 1910.134(c)(1)(I)Procedures for selecting respirators for use in the workplace; 1910.134(c)(1)(ii)Medical evaluations of employees required to use respirators; 1910.134(c)(1)(iii)Fit testing procedures for tight-fitting respirators; 1910.134(c)(1)(iv)Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations; 1910.134(c)(1)(v)Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators; 1910.134(c)(1)(vi)Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators; 1910.134(c)(1)(vii)Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations; 1910.134(c)(1)(viii) Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance; and 1910.134(c)(1)(ix)Procedures for regularly evaluating the effectiveness of the program.   a) On or about September 17, 2020, the employer did not establish and implement a written respiratory program for maintenance employees who were required to wear 3M 8210 N95 respirators while working on the powder coat dust collectors, which contained SOL Epoxy DK15-0907 Epoxy Powder Phenol Novolac Epoxy 2-Methylimidazole (skin and eye irritant, allergic reaction skin, mucous membrane irritant, inhalation hazard, combustible dust), and Armada dust collectors, which contained metal dust (combustible dust).

Issued

Mar 15, 2021

Abate by

Apr 29, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(e)(1): General. The employer shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.    a) On or about September 17, 2020, the employer had not provided a medical evaluation for maintenance employees who were required to wear a 3M 8210 N95 respirators while working on the powder coat dust collectors, which contained SOL Epoxy DK15-0907 Epoxy Powder Phenol Novolac Epoxy 2-Methylimidazole (skin and eye irritant, allergic reaction skin, mucous membrane irritant, inhalation hazard, combustible dust), and Armada dust collectors, which contained metal dust (combustible dust).

Issued

Mar 15, 2021

Abate by

Apr 29, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(f)(1): The employer shall ensure that employees using a tight-fitting facepiece respirator pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT) as stated in this paragraph.   a) On or about September 17, 2020, the employer did not fit-test the respirators for maintenance employees who were required to wear 3M 8210 N95 respirators while working on the powder coat dust collectors, which contained SOL Epoxy DK15-0907 Epoxy Powder Phenol Novolac Epoxy 2-Methylimidazole (skin and eye irritant, allergic reaction skin, mucous membrane irritant, inhalation hazard, combustible dust), and Armada dust collectors, which contained metal dust (combustible dust).

Issued

Mar 15, 2021

Abate by

Apr 29, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(k): Training and information. This paragraph requires the employer to provide effective training to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary. This paragraph also requires the employer to provide the basic information on respirators in Appendix D of this section to employees who wear respirators when not required by this section or by the employer to do so.   a) On or about September 17, 2020, the employer did not provided respirator training for maintenance employees who were required to wear 3M 8210 N95 respirators while working on the powder coat dust collectors, which contained SOL Epoxy DK15-0907 Epoxy Powder Phenol Novolac Epoxy 2-Methylimidazole (skin and eye irritant, allergic reaction skin, mucous membrane irritant, inhalation hazard, combustible dust), and Armada dust collectors, which contained metal dust (combustible dust).

Issued

Mar 15, 2021

Abate by

Apr 29, 2021

Penalty

Initial $6,436 · Current $0 Reduced

General-duty citation text

29 CFR  1910.141(a)(3)(i): All places of employment shall be kept clean to the extent that the nature of the work allows.  a) On or about January 7, 2021, the employer failed to keep working areas clean in that employees were exposed to SOL DK15-0907 Epoxy Powder Phenol Novolac Epoxy 2-Methylimidazole, (skin and eye irritant, allergic reaction skin, mucous membrane irritant, inhalation hazard, combustible dust), which was found to be coating the surfaces of objects, the floor, and the walls in the environmental room and around the powder coat line.

Issued

Mar 15, 2021

Abate by

Apr 29, 2021

Penalty

Initial $10,728 · Current $6,000 Reduced

General-duty citation text

29 CFR 1910.146(c)(7)(i): A space classified by the employer as a permit-required confined space may be reclassified as a non-permit confined space under the following procedures: 1910.146(c)(7)(i) If the permit space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated.   a) From October 8, 2020 to January 4, 2021, the employer had reclassified and entered the powder coat process line, a permit required confined space, on 13 occasions without ensuring the space posed no actual or potential atmospheric hazards in order for maintenance employees to perform repairs and preventive maintenance. On the cure oven, the natural gas was not always gas locked out until November of 2020, the preheat oven and cure oven were not isolated from the natural gas lines as the isolation procedure was not correctly performed by all employees, and the atmosphere was not tested.

Issued

Mar 15, 2021

Abate by

Apr 29, 2021

Penalty

Initial $10,728 · Current $0 Reduced

General-duty citation text

29 CFR  1910.146(d)(3)(i): Develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, the following: Specifying acceptable entry conditions.  a) From October 8, 2020 to January 4, 2021,  the employer reclassified and entered the powder coat process line , a permit required confined space, on 13 occasions without implementing the means, procedure and practices specifying safe entry conditions  in order for maintenance employees to perform repairs and preventive maintenance. The cure oven did not have the natural gas locked out until November of 2020, the preheat oven and cure oven were not isolated from the natural gas using a double block and bleed, and the atmosphere was not tested in the spaces for natural gas, carbon monoxide, carbon dioxide, nitrogen oxide, and oxygen deficiency.

Issued

Mar 15, 2021

Abate by

Apr 29, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.146(d)(5)(i): Test conditions in the permit space to determine if acceptable entry conditions exist before entry is authorized to begin, except that, if isolation of the space is infeasible because the space is large or is part of a continuous system (such as a sewer), pre-entry testing shall be performed to the extent feasible before entry is authorized and, if entry is authorized, entry conditions shall be continuously monitored in the areas where authorized entrants are working;  a) From October 8, 2020 to January 4, 2021,  the employer reclassified and entered the powder coat process line, a permit required confined space, on 13 occasions without testing entry conditions for oxygen deficiency, natural gas, carbon monoxide, carbon dioxide, and nitrogen oxide.

Issued

Mar 15, 2021

Abate by

Apr 29, 2021

Penalty

Initial $10,728 · Current $0 Reduced

General-duty citation text

29 CFR 1910.146(g)(3): The training shall establish employee proficiency in the duties required by this section and shall introduce new or revised procedures, as necessary, for compliance with this section.   a) On or about October 8, 2020, the employer did not provide training when a procedure was changed in that that employees were not trained on locking out the natural gas on the cure oven for the powder coat line, an entry supervisor and employees were not trained on how to isolate the natural gas lines on the cure oven and preheat oven, and entry supervisors were not trained to test for the atmospheric hazards in the permit required confined space prior to entry for hazards such as oxygen deficiency, natural gas, carbon monoxide, carbon monoxide, and nitrogen oxide.

Issued

Mar 15, 2021

Abate by

Apr 29, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(j): Duties of entry supervisors. The employer shall ensure that each entry supervisor: 1910.146(j)(1) Knows the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; 1910.146(j)(2) Verifies, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin.   a) On or about October 8, 2020, the employer had not ensured that each entry supervisor knew the hazards in the permit required confined spaced and verified that the appropriate entries had been made, all tests specified by the permit were conducted, and that the procedures were in place before endorsing the permit in that the entry supervisors failed to recognize the atmospheric hazards present from the natural gas and the byproducts from heating the SOL Epoxy DK15-0907 Epoxy Powder Phenol Novolac Epoxy 2-Methylimidazole which created carbon monoxide, carbon dioxide, and nitrogen oxide,  and had not ensure that employees were locking out the natural gas line on the cure oven, and had not ensured proper isolation of the natural gas line.

Issued

Mar 15, 2021

Abate by

Apr 29, 2021

Penalty

Initial $6,436 · Current $2,000 Reduced

General-duty citation text

29 CFR 1910.1200(h)(3): Training. Employee training shall include at least: 1910.1200(h)(3)(ii)The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area; 1910.1200(h)(3)(iii) The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.   a) On or about January 7, 2021, the employer had not provided training on SOL Epoxy DK15-0907 Epoxy Powder Phenol Novolac Epoxy 2-Methylimidazole (a combustible dust; skin, mucous membrane, and eye irritant; allergic skin reaction, and inhalation hazard).