OSHA Inspection: AMERICAN SPRAY FOAM INSULATION, LLC

Issued

Mar 7, 2022

Abate by

Apr 21, 2022

Penalty

Initial $1,865 · Current $1,253 Reduced

Hazardous substances P125

General-duty citation text

29 CFR  1910.132(d)(1):The employer did not assess the workplace to determine if hazards were present, or were likely to be present, which necessitated the use of personal protective equipment:  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, the employer had not conducted a hazard assessment to determine the appropriate personal protective equipment for use when spraying isocyanate-based spray foam insulation inside a newly renovated house.  Employees wore polypropylene coveralls and utility gloves.

Issued

Mar 7, 2022

Abate by

Apr 21, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.138(a): The employer did not select and require employee(s) to use appropriate hand protection when employees' hands were exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasion; punctures; chemical burns; thermal burns; and harmful temperature extremes.  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, employees were provided with Firm Grip Utility Gloves to wear while applying isocyanate-containing spray foam insulation.  Health hazards of the insulation include skin irritation.

Issued

Mar 7, 2022

Abate by

Apr 21, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1926.28(a): Appropriate personal protective equipment was not worn by employee(s) in all operations where there was exposure to hazardous conditions:  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, the employer did not provide and ensure that his employees used personal protective equipment that was appropriate for the hazards associated with the application of isocyanate-containing spray foam insulation.

Issued

Mar 7, 2022

Abate by

Apr 21, 2022

Penalty

Initial $4,351 · Current $2,827 Reduced

Hazardous substances P125

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: (Construction Reference 1926.103)  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, the employer required employees to use full face respirators with organic vapor cartridges while spraying isocyanate-based insulation inside a home.  The employer had not developed and implemented a written respiratory protection program.

Issued

Mar 7, 2022

Abate by

Apr 21, 2022

Penalty

Initial $0 · Current $0

Hazardous substances P125

General-duty citation text

29 CFR  1910.134(d)(1)(i): Selection of appropriate respirators was not based on the respiratory hazard(s) to which the worker was exposed and user factors that affect respirator performance and reliability: (Construction Reference 1926.103)  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, employees applying isocyanate-based spray foam insulation inside a house wore full face respirators with organic vapor cartridges.  Part A of the mixture contains 4,4'-Diphenylmethane diisocyanate (MDI).  The NIOSH Pocket Guide to Chemical Hazards indicates that supplied air respirators are required.

Issued

Mar 7, 2022

Abate by

Apr 21, 2022

Penalty

Initial $0 · Current $0

Hazardous substances P125

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: (Construction Reference 1926.103)  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, employees who were required to wear full-face respirators were not provided with medical evaluations prior to using the respirators.

Issued

Mar 7, 2022

Abate by

Apr 21, 2022

Penalty

Initial $0 · Current $0

Hazardous substances P125

General-duty citation text

29 CFR  1910.134(f)(2): Employee(s) using tight-fitting facepiece respirators were not fit tested prior to initial use of the respirator: (Construction Reference 1926.103)  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, employees were required to wear full face respirators with organic vapor cartridges while applying isocyanate-containing spray foam insulation.  The employees were not provided with fit testing to ensure that they were wearing a respirator that fits properly.

Issued

Mar 7, 2022

Abate by

Apr 21, 2022

Penalty

Initial $0 · Current $0

Hazardous substances P125

General-duty citation text

29 CFR  1910.134(k)(1): The employer did not provide respirator training that ensured that each employee could demonstrate knowledge of at least the following elements: Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator; What the limitations and capabilities of the respirator are; How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions; How to inspect, put on and remove, use, and check the seals of the respirator; What the procedures are for maintenance and storage of the respirator, and How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators.  (Construction Reference 1926.103):   33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, the employer had not provided training to employees on how to don and doff a respirator, how to clean the respirator, or when to change the cartridges.  Employees wore full face respirators when spraying isocyanate-based spray polyurethane foam insulation.

Issued

Mar 7, 2022

Abate by

Apr 21, 2022

Penalty

Initial $3,108 · Current $2,088 Reduced

General-duty citation text

29 CFR  1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met: (Construction Reference: 1926.59):  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, employees regularly worked with hazardous chemicals including, but not limited to spray foam insulation containing 4,4'-Diphenylmethane diisocyanate (MDI), door and window sealer containing polymeric diphenylmethane diisocyanate, and flammable aerosols containing aliphatic hydrocarbons.  The employer had not developed and implemented a written Hazard Communication Program.

Issued

Mar 7, 2022

Abate by

Apr 21, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1926.21(b)(2): The employer did not instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his/her environment to control or eliminate any hazards or other exposure to illness or injury:  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, employees were not provided with training related to the hazards associated with exposure to hazardous chemicals including, but not limited to: spray foam insulation containing 4,4'-Diphenylmethane diisocyanate (MDI), door and window sealer containing polymeric diphenylmethane diisocyanate, and flammable aerosols containing aliphatic hydrocarbons.  The employer had not provided employees with training related to the health hazards associated with those chemicals and measures the employees were to take to protect themselves.

Issued

Mar 7, 2022

Abate by

Apr 21, 2022

Penalty

Initial $0 · Current $0

Hazardous substances P125

General-duty citation text

29 CFR  1926.21(b)(3): Employees required to handle or use poisons, caustics, and other harmful substances were not instructed regarding the safe handling and use, and were not made aware of the potential hazards, personal hygiene, and personal protective measures required:  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, employees were not provided with training related to the hazards associated with exposure to hazardous chemicals including, but not limited to: spray foam insulation containing 4,4'-Diphenylmethane diisocyanate (MDI), door and window sealer containing polymeric diphenylmethane diisocyanate, and flammable aerosols containing aliphatic hydrocarbons.  The employer had not provided employees with training related to the health hazards associated with those chemicals and measures the employees were to take to protect themselves.

Issued

Mar 7, 2022

Penalty

Initial $4,351 · Current $2,827 Reduced

General-duty citation text

29 CFR  1926.451(f)(7):  Scaffolds were not erected, moved, dismantled, or altered, by trained and experienced employees under the supervision and direction of a competent person qualified in scaffold erection, moving, dismantling or alteration:; Such activities were not performed only by experienced and trained employees selected for such work by the competent person:  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, the employer erected two Baker's Scaffolds inside the house for employees to use.  The scaffolds were not inspected by a competent person prior to use by employees.

Issued

Mar 7, 2022

Penalty

Initial $3,729 · Current $2,505 Reduced

General-duty citation text

29 CFR  1926.501(b)(4)(ii): Each employee on a walking/working surface was not protected from tripping in or stepping into or through holes by covers:  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, employees who were using baker scaffolds and applying spray foam insulation were exposed to holes in the floor of the Family Room of a newly constructed house.

Issued

Mar 7, 2022

Penalty

Initial $3,729 · Current $0 Reduced

General-duty citation text

29 CFR  1926.502(i)(2): Covers were not capable of supporting, without failure, at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time.  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, there were eight cardboard-covered holes in the floor decking in the Family Room exposing employees to trip and fall hazards.  The cardboard would not support the weight of the employees or the scaffolding they were using.

Issued

Mar 7, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1926.502(i)(4): All covers were not color coded or marked with the word "HOLE" or "COVER" to provide warning of the hazard:  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, holes in the plywood floor deck of the Family Room were not color-coded or otherwise marked to provide warning to employees who were applying spray foam insulation and/or trimming cured insulation.  The holes were covered with cardboard that was similar in color to the plywood floor.  Employees were exposed to trip and fall hazards.

Issued

Mar 7, 2022

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1926.452(w)(9): Caster stems and wheel stems were not pinned or otherwise secured in scaffold legs or adjustment screws.  33 FENN HILL ROAD, WASHINGTON DEPOT, CT:  On or about September 15, 2021, employees used baker scaffolds that were missing cotter pins used to secure casters to the scaffold legs.  Employees used the scaffolds while applying spray foam insulation and/or trimming excess cured insulation.