OSHA Inspection: CONTRACT MANUFACTURER, L.L.C.

Issued

Sep 24, 2021

Abate by

Jan 31, 2022

Penalty

Initial $11,703 · Current $6,000 Reduced

General-duty citation text

29 CFR  1910.94(c)(7)(iii)(b): A pressure gage marked to show the pressure drop across the filters of the spray booth to indicate that the filters require cleaning or replacement was not installed.    On or about April 6, 2021, and at times prior thereto, at the top coat powder spray booth, there were no markings on pressure gages to show the pressure drops across the filters of the spray booth to indicate that the filters require cleaning or replacement.   This exposed employees, spraying Truck Bed Black powder (a combustible dust containing TGIC), to health hazards.

Issued

Sep 24, 2021

Abate by

Oct 21, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.107(l)(2)(i):  All non-deposited air-suspended powder was not safely removed via exhaust ducts to the powder recovery cyclone or receptacle.    a.  On or about April 6, 2021, and at times prior thereto, at the top coat powder spray booth openings where truck bed parts entered the spray booth, air suspended Truck Bed Black powder (combustible dust) traveled outside of the booth.  The employer did not ensure all non-deposited air-suspended powder was safely removed via exhaust ducts to the powder recovery receptacle, exposing employees to fire and explosion hazards.  b.  On or about April 7, 2021, and at times prior thereto, at the top coat powder spray booth openings where truck bed parts entered the spray booth, air suspended Truck Bed Black powder (combustible dust) traveled outside of the booth.  The employer did not ensure all non-deposited air-suspended powder was safely removed via exhaust ducts to the powder recovery receptacle, exposing employees to fire and explosion hazards.

Issued

Sep 24, 2021

Abate by

Oct 6, 2021

Penalty

Initial $9,753 · Current $5,000 Reduced

General-duty citation text

29 CFR  1910.107(i)(5):  The handle of the spraying gun was not electrically connected to ground by a metallic connection and so constructed that the operator in normal operating position is in intimate electrical contact with the grounding handle.    On or about April 6, 2021, and at times prior thereto, at the top coat powder spray booth, the employer did not ensure the handle of an electrostatic spray gun was electrically connected to ground by a metallic connection and so constructed that the operator in normal operating position was in intimate electrical contact with the grounding handle.  Employees used manual electrostatic spray guns to powder coat truck beds with Truck Bed Black (combustible dust) which exposes employees to fires and explosion hazards.

Issued

Sep 24, 2021

Abate by

Oct 6, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.107(i)(6):  All electrically conductive objects in the spraying area were not adequately grounded.   On or about June 16, 2021, and at times prior thereto, at the top coat powder spray booth, the employer does not ground all electrically conductive objects in the spraying area including, but not limited to portable metal step platforms and stools on which employees stand or sat when they held electrostatic powder spray guns to powder coat truck beds with Truck Bed Black (combustible dust).  This exposes employees to fires and explosion hazards.

Issued

Sep 24, 2021

Abate by

Oct 6, 2021

Penalty

Initial $0 · Current $4,500

General-duty citation text

29 CFR  1910.107(l)(4)(ii):  Surfaces were not cleaned in such a manner as to avoid scattering dust to other places or creating dust clouds.    a.  On or about April 7, 2021, and at times prior thereto, at the hopper room in front of the parts entry area of the top coat (black powder) spray booth, employees used compressed air to clean black coating powder (combustible dust) from the floor and the employer did not ensure surfaces were cleaned in such a manner as to avoid scattering dust to other places or creating dust clouds.  This exposes employees to fire and explosion hazards.  b.  On or about April 7, 2021, and at times prior thereto, at the trim room which was open to the top coat (black powder) spray booth, employees dry swept black powder from the trim room floor and the employer did not ensure surfaces were cleaned in such a manner as to avoid scattering dust to other places or creating dust clouds.   This exposes employees to fire and explosion hazards.  c.  On or about June 16, 2021, and at times prior thereto, at the hopper room in front of the parts entry area of the top coat (black powder) spray booth, employees dry swept black powder from the hopper room floor and the employer did not ensure surfaces were cleaned in such a manner as to avoid scattering dust to other places or creating dust clouds.  This exposes employees to fire and explosion hazards.

Issued

Sep 24, 2021

Abate by

Oct 6, 2021

Penalty

Initial $11,703 · Current $6,000 Reduced

Hazardous substances 91309135T405

General-duty citation text

29 CFR  1910.134(d)(1)(ii):  The employer did not select and use a NIOSH-certified respirator in compliance with the conditions of its certification.    a.  On or about April 7, 2021, and at times prior thereto, at the top coat powder spray booth, the employer does not ensure employees use NIOSH-certified supplied air respirators in compliance with the conditions of the respirator's certification in that the respirator's inner shroud was not worn.  Employees were required to wear loose fitting supplied air respirators during top coat powder spraying operations and were exposed to respiratory hazards including, but not limited to 1,3,5-triglycidyl isocyanurate (TGIC), respirable dust, and total dust.  b.  On or about June 16, 2021, and at times prior thereto, at the top coat powder spray booth, the employer does not ensure employees use NIOSH-certified supplied air respirators in compliance with the conditions of the respirator's certification in that the outer shroud of the respirator was not draped over the shoulders.  Employees were required to wear loose fitting supplied air respirators during top coat powder spraying operations and were exposed to respiratory hazards including, but not limited to 1,3,5-triglycidyl isocyanurate (TGIC), respirable dust, and total dust.

Issued

Sep 24, 2021

Abate by

Oct 6, 2021

Penalty

Initial $11,703 · Current $6,000 Reduced

Hazardous substances 91309135T405

General-duty citation text

29 CFR  1910.134(e)(6)(i):  The employer did not obtain from the physician or other licensed health care professional (PLHCP) a written recommendation regarding the employee's ability to use the respirator.     On or about April 6, 2021, and at times prior thereto, the employer did not obtain from the physician or other licensed health care professional (PLHCP) a written medical recommendation regarding the following employee's ability to use a loose fitting supplied air respirator.  The employees were exposed to respiratory hazards including, but not limited to 1,3,5-triglycidyl isocyanurate (TGIC), respirable dust, total dust, carbon monoxide, carbon dioxide, oil mist, and water vapor:  a. At the black powder spray booth, an employee who sprayed black powder to the bottom areas of truck beds and who was required to wear a loose fitting supplied air respirator.    b. At the black powder spray booth, an employee who sprayed black powder to the bottom areas of truck beds and who was required to wear a loose fitting supplied air respirator.    c. At the black powder spray booth, an employee who sprayed black powder to the top areas of truck beds and who was required to wear a loose fitting supplied air respirator.    d. At the black powder spray booth, an employee who sprayed black powder to the bottom areas of truck beds and who was required to wear a loose fitting supplied air respirator.

Issued

Sep 24, 2021

Abate by

Feb 15, 2022

Penalty

Initial $11,703 · Current $6,000 Reduced

Hazardous substances 91309135T405

General-duty citation text

29 CFR  1910.134(g)(2)(ii)(A):  The employer did not ensure that employees left the respirator use area to wash their faces and facepieces as necessary to prevent eye or skin irritation associated with respirator use.   On or about June 16, 2021, and at times prior thereto, at the top coat powder spray booth, the employer does not ensure that employees left the respirator use area to wash their faces to prevent eye or skin irritation associated with use of supplied air respirators.  Employees were required to wear supplied air respirators during top coat powder spraying operations and were exposed to respiratory hazards including but not limited to 1,3,5-triglycidyl isocyanurate (TGIC), respirable dust, and total dust.

Issued

Sep 24, 2021

Abate by

Jan 14, 2022

Penalty

Initial $11,703 · Current $0 Reduced

Hazardous substances 91309135T405

General-duty citation text

29 CFR  1910.134(h)(1):  Respirators were not cleaned and disinfected using the procedures in Appendix B-2 of 29 CFR 1910.134 or equivalent procedures recommended by the respirator manufacturer.   On or about April 7, 2021, and at times prior thereto, at the trim floor room, the employer does not ensure that supplied air respirators were cleaned using the procedures in Appendix B-2 of 29 CFR 1910.134 or equivalent procedures recommended by the respirator manufacturer.  Employees were required to wear loose fitting supplied air respirators during top coat powder spraying operations and were exposed to respiratory hazards including, but not limited to 1,3,5-triglycidyl isocyanurate (TGIC), respirable dust, and total dust.

Issued

Sep 24, 2021

Abate by

Jan 14, 2022

Penalty

Initial $0 · Current $0

Hazardous substances 91309135T405

General-duty citation text

29 CFR  1910.134(h)(2)(i):  Respirators were not stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals or  were not packed or stored to prevent deformation of the facepiece and exhalation valve.    On or about April 7, 2021, and at times prior thereto, at the hopper room of the top coat powder spray booth, the employer does not ensure that supplied air respirators were stored to protect them from contamination in that they were stored uncovered in plastic tubs that were not cleaned of black dust.  Employees were required to wear loose fitting supplied air respirators during top coat powder spraying operations and were exposed to respiratory hazards including, but not limited to 1,3,5-triglycidyl isocyanurate (TGIC), respirable dust, and total dust.

Issued

Sep 24, 2021

Abate by

Oct 6, 2021

Penalty

Initial $7,802 · Current $4,000 Reduced

Hazardous substances 91309135T405

General-duty citation text

29 CFR  1910.134(i)(5)(iv):  The employer did not ensure that the person authorized to perform the necessary sorbent bed and filter changes filled out a tag indicating by the signature and date that maintenance changes were performed.    On or about April 6, 2021, and at times prior thereto, the employer did not ensure that the person authorized to perform the necessary sorbent bed and filter changes filled out a tag indicating by the signature and date that maintenance changes were performed on the compressed air purifier that provided breathing air to supplied air respirators worn by employees who conducted powder spray operations.  This exposed the employees to respiratory hazards including, but not limited to 1,3,5-triglycidyl isocyanurate (TGIC), respirable dust, total dust, oil mist, and water vapor.

Issued

Sep 24, 2021

Abate by

Oct 6, 2021

Penalty

Initial $11,703 · Current $6,000 Reduced

Hazardous substances T405

General-duty citation text

29 CFR  1910.141(g)(2):  Employees were permitted to consume food or beverage in area(s) exposed to toxic materials.   On or about June 16, 2021, and at times prior thereto, at the hopper room of the top coat powder spray booth, the employer permitted employees to consume beverage where Truck Bed Black top powder coat was conveyed and exposed employees to hazardous chemicals including including, but not limited to 1,3,5-triglycidyl isocyanurate (TGIC).

Issued

Sep 24, 2021

Abate by

Nov 12, 2021

Penalty

Initial $11,703 · Current $6,000 Reduced

Hazardous substances 91309135T405

General-duty citation text

29 CFR  1910.1000(a)(2):  Employee(s) were exposed to an airborne concentration of particulates not otherwise regulated listed in Table Z-1 in excess of the 8 hour Time Weighted Average concentration of 5 milligrams per cubic meter of air.   a.  On or about April 7, 2021, and at times prior, at the powder spray booth, an employee was exposed to particulates not otherwise regulated (Respirable Fraction), in excess of 5 milligrams per cubic meter of air, during manual electrostatic powder spraying of truck beds with Truck Bed Black.  An employee's personal 8-hour time-weighted average (8-Hr TWA) exposure to particulates not otherwise regulated (Respirable Fraction) was 12.25 mg/m3.  This exceeded the OSHA 8-Hr TWA PEL of 5 mg/m3 for particulates not otherwise regulated (Respirable Fraction) by 2.4 times.    b.  On or about April 7, 2021, in the powder spray booth, employees were exposed to particulates not otherwise regulated (Total Dust) in excess of 15 milligrams per cubic meter of air during manual electrostatic powder spraying of truck beds with Truck Bed Black.  An employee's personal 8-hour time-weighted average (8-Hr TWA) exposure to particulates not otherwise regulated (Total Dust) was 225.8 mg/m3.  This exceeded the OSHA 8-Hr TWA PEL of 15 mg/m3 for particulates not otherwise regulated (Total Dust) by 15 times.     c.  On or about April 7, 2021, in the powder spray booth, employees were exposed to particulates not otherwise regulated (Total Dust) in excess of 15 milligrams per cubic meter of air during manual electrostatic powder spraying of truck beds with Truck Bed Black.  An employee's personal 8-hour time-weighted average (8-Hr TWA) exposure to particulates not otherwise regulated (Total Dust) was 386.4 mg/m3.  This exceeded the OSHA 8-Hr TWA PEL of 15 mg/m3 for particulates not otherwise regulated (Total Dust) by 26 times.    d.  On or about April 7, 2021, in the powder spray booth, employees were exposed to particulates not otherwise regulated (Total Dust) in excess of 15 milligrams per cubic meter of air during manual electrostatic powder spraying of truck beds with Truck Bed Black.  An employee's personal 8-hour time-weighted average (8-Hr TWA) exposure to particulates not otherwise regulated (Total Dust) was 120.9 mg/m3.  This exceeded the OSHA 8-Hr TWA PEL of 15 mg/m3 for particulates not otherwise regulated (Total Dust) by 8 times.