OSHA Inspection: HAR-CONN CHROME COMPANY

Issued

Apr 8, 2022

Abate by

Apr 3, 2023

Penalty

Initial $13,052 · Current $5,000 Reduced

General-duty citation text

29 CFR  1910.107(b)(5)(i):The average air speed over the open face of the paint spray booth was less than 100 linear feet per minute.  Building 593, Spray Booth 6:  On or about January 03, 2022, the average air speed over the open face of the spray booth was less than 100 linear feet per minute (fpm) when measured with an Alnor Thermoanenometer 9850 during OSHA's full-shift exposure assessment of hexavalent chromium while employee performed electrostatic spraying operations on small aircraft parts. Products included, but were not limited to, a Category 2 flammable liquid called 44GN049 Epoxy Primer Black-Green (product code no. 800119) that contained 10 to 20% strontium chromate and 5 to 10% hexavalent chromium ions. The average air speed measured at 53.3 fpm, which was approximately 6 feet from the external exhaust air filters where spraying was performed.

Issued

Apr 8, 2022

Abate by

Jun 5, 2023

Penalty

Initial $13,052 · Current $13,000 Reduced

Hazardous substances 0689

General-duty citation text

29 CFR  1910.1026(c):Employees were exposed to an airborne concentration of chromium (VI) which exceeded 5 micrograms per cubic meter of air, as an 8-hour time-weighted average:  Building 593,  On or about January 03, 2022, employees performing electrostatic hand spraying operations on small aircraft parts were exposed to an airborne concentration of chromium (VI) that exceeded the permissible exposure limit (PEL) of 5 micrograms per cubic meter of air, as an 8-hour time-weighted average (TWA). Based on a severity of 4.6, samples resulting from an inspection performed by the United States Department of Labor, OSHA exceeded the 95% CL for overexposure with levels presenting at 23.3 micrograms per cubic meter during an 8-hr TWA assessment. Spray painting operations performed in Spray Booth 6 used products that included, but were not limited to, 44GN049 Epoxy Primer Black-Green (product code no. 800119, Mfr. PPG) containing 10 to 20% strontium chromate and 5 to 10% hexavalent chromium ions and a 44GN072 Base Component (product code no. 44GN072, Mfr. PPG) containing 20 to 50% strontium chromate.

Issued

Apr 8, 2022

Abate by

Jun 5, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.1026(f)(1)(i):Feasible engineering controls and work practices were not instituted to reduce and maintain employee exposures to chromium (VI) at or below the permissible exposure limit.  Building 593  On or about January 03, 2022, employees performing hand electrostatic spray-painting operations on small aircraft parts were overexposed to chromium (VI) at 23.3 micrograms per cubic meter of air, which was above the permissible exposure limit (PEL) of 5 micrograms per cubic meter of air. The employer did not institute engineering controls and work practices that would have reduced and maintained employee exposures to chromium (VI) at or below the PEL. Employees were provided with 3M Half Facepiece Reusable Respirators (6300) that had 3M Organic Vapor/Acid Gas Cartridge (6003) attachments as a means to control for these overexposures.

Issued

Apr 8, 2022

Abate by

Aug 1, 2022

Penalty

Initial $13,052 · Current $13,000 Reduced

General-duty citation text

29 CFR  1910.1026(g)(2): The employer required respirator use for protection against chromium (VI); however, the employer did not institute a respiratory protection program in accordance with the Respiratory Protection standard, 29 CFR 1910.134, which covers each employee required to use a respirator:  Building 593:   On or about January 03, 2021, the employer did not institute a respiratory protection program in accordance with 1910,134:  a) The half face respirators were not reevaluated for continued effectiveness by employees spray finishing small aircraft parts and using products containing hexavalent chromium (Cr(VI)) compounds which included, but were not limited to, 44GN072 Base Component (product code no. 44GN072, Mfr. PPG) that contained 20 to 50% strontium chromate (29 CFR 1910.134(g)(2)(i)).  b) The employer did not set the maximum use concentration (MUC) at the lower limit when the calculated MUC exceeded the performance limit of the organic vapor cartridge attached to the half face elastomeric respirator used. With the time-weighted average (TWA) full-shift exposure levels exceeding the 5 micrograms per cubic meter OSHA permissible exposure limit (PEL) by 360%, with readings at 23 micrograms per cubic meter, the frequency that this process was performed during the week reduced the performance limits for the cartridges used (29 CFR 1910.134(d)(3)(i)(B)(3)). c) The Organic vapor cartridges were not changed with the frequency required for exposures that exceeded the Cr(VI) PEL, at 23 micrograms per cubic meter, during an 8-hour TWA as measured during OSHA's investigation. Rather, the same cartridge was used for several similar paint jobs for approximately one month intervals at a time (1910.134(d)(3)(iii)(B)(2)).

Issued

Apr 8, 2022

Abate by

Aug 1, 2022

Penalty

Initial $9,324 · Current $9,000 Reduced

General-duty citation text

29 CFR  1910.1026(h)(2)(i):The employer did not ensure that employees removed all protective clothing and equipment contaminated with chromium (VI) at the end of the work shift or at the completion of their tasks involving chromium (VI) exposure, whichever came first:  Har-Conn Chrome Company: On or about October 18, 2021, the employer did not ensure that employees performing spray painting, anodizing, and plating operations removed all protective clothing that became contaminated with chromium (VI) at the end of their work shifts in the following areas:  a.) Building 603 - Anodizing area b.) Building 603 - Electroplating room (EN Room)

Issued

Apr 8, 2022

Abate by

Aug 1, 2022

Penalty

Initial $13,052 · Current $0 Reduced

General-duty citation text

29 CFR  1910.1026(j)(1)(i):The employer did not ensure that all surfaces were maintained as free as practicable of accumulations of chromium (VI):   a.) Building 603 - Anodizing area: On or about December 20, 2021, surfaces in the anodizing area such as the stair rail was not maintained as free as practicable from accumulations of chromium (VI) from processes that included cleaning methods using compressed air, which suspended the solvent into the air and onto the surfaces. Presence of the contaminant was confirmed at 0.291 micrograms on a wipe sample taken.   b.) Building 603 - Workstation outside of EN Room: On or about December 20, 2021, the surface of the chemical film setup workstation, right outside of the EN Room, was not maintained as free as practicable from accumulations of chromium (VI) while employees performed tasks that included, but were not limited to, reviewing job process instructions while sitting at this station. Presence of the contaminant was confirmed at 0.883 micrograms on a wipe sample taken from the table.   c.) Building 603 - Nickel Chromate and Iridate Tanks in the EN Room:  On or about December 20, 2021, the surface of the drying station was not maintained as free as practicable from accumulations of chromium (VI) when compressed air was used to dry off parts that went through a water rinse in the chromium rinse tank and the hot water rinse tank after being dipped in hexavalent Cr(VI) compound containing tanks. Presence of the contaminant was confirmed at 9.101 micrograms on a wipe sample taken.

Issued

Apr 8, 2022

Abate by

Apr 3, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.1026(j)(2)(iii)(A):When compressed air was used to remove chromium (VI) from surfaces, the employer did not ensure that the compressed air was used in conjunction with a ventilation system designed to capture the dust cloud created by the compressed air:  a.) Building 603 - Anodizing area: On or about October 18, 2021,  the employer did not provide ventilation for cleaning methods that used compressed air on parts dipped into tanks containing Cr(VI) compounds. The contaminant was suspended into the air and onto surfaces during these procedures.   b.) Building 603 - Nickel Chromate and Iridate Tanks in the EN Room:  On or about October 18, 2021, the employer did not provide ventilation for cleaning methods that used compressed air on parts dipped into tanks containing Cr(VI) compounds. The contaminant was suspended into the air and onto surfaces during these procedures.