OSHA Inspection: UNIVERSAL RECYCLING TECHNOLOGIES, LLC

Issued

Apr 7, 2023

Abate by

Feb 16, 2024

Penalty

Initial $14,063 · Current $11,954 Reduced

Hazardous substances 1591C141

General-duty citation text

29 CFR  1910.134(a)(1): When effective engineering controls were not feasible or while they were being instituted, appropriate respirators were not used pursuant to the requirements of this section:  On or about November 9, 2022, the employer did not make respiratory protection mandatory for employees working on the D-Man line  when employee exposure to concentrations of more than one substance exceeded the permissible exposure limit for the mixture of heavy metals to include inorganic Lead and Cadmium. The mixture has additive toxic effects on the kidneys.  The employee was dismantling Cathode Ray Tubes. The employee was exposed to inorganic lead at an 8-hour time weighted average (TWA) of 0.00778 milligrams per cubic meter (mg/m3) of air, approximately 0.155 times the permissible exposure limit (PEL) of 0.05 mg/m3; and cadmium at an 8-hour TWA of 0.00807 mg/m3 of air, approximately 1.61 times the PEL of 0.005 mg/m3. The exposure concentration was approximately 1.63 times the permissible 8-hour TWA concentration for the mixture. Sampling was performed for 467 minutes. Zero exposure was assumed for the 13 minute period not sampled.

Issued

Apr 7, 2023

Abate by

Feb 16, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 1591C141

General-duty citation text

29 CFR 1910.1000(d)(1)(i): When determined by the computational formula specified in 29 CFR 1910.1000(d)(2)(i), employees were exposed to concentrations of more than one substance for which 8-hour time weighted averages are listed in Subparts Z of 29 CFR part 1910 in excess of the permissible exposure for the mixture:    (a)  The employer did not ensure that employee exposure to concentrations of more than one substance did not exceed the permissible exposure limit for the mixture of heavy metals to include inorganic Lead and Cadmium. The mixture has additive toxic effects on the kidneys. This violation occurred on November 9, 2022, where the employee was dismantling Cathode Ray Tubes on the D-Man line. The employee was exposed to inorganic Lead at an 8-hour time weighted average (TWA) of 0.00778 milligrams per cubic meter (mg/m3) of air, approximately 0.155 times the permissible exposure limit (PEL) of 0.05 mg/m3; and Cadmium at an 8-hour TWA of 0.00807 mg/m3 of air, approximately 1.61 times the PEL of 0.005 mg/m3. The exposure concentration was approximately 1.63 times the permissible 8-hour TWA concentration for the mixture. Sampling was performed for 467 minutes. Zero exposure was assumed for the 13 minute period not sampled.  (b) The employer did not ensure that employee exposure to concentrations of more than one substance did not exceed the permissible exposure limit for the mixture of heavy metals to include inorganic Lead and Cadmium The mixture has additive toxic effects on the kidneys. This violation occurred on November 9, 2022, where the employee was dismantling Cathode Ray Tubes on the M10 line and D-Man line. The employee was exposed to inorganic Lead at an 8-hour time weighted average (TWA) of 0.0284 milligrams per cubic meter (mg/m3) of air, approximately 0.568 times the permissible exposure limit (PEL) of 0.05 mg/m3;  and Cadmium at an 8-hour TWA of 0.0054 mg/m3 of air, approximately 1.082 times the PEL of 0.005 mg/m3. The exposure concentration was approximately 1.54 times the permissible 8-hour TWA concentration for the mixture. Sampling was performed for 465 minutes. Zero exposure was assumed for the 15 minute period not sampled.

Issued

Apr 7, 2023

Abate by

Feb 16, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 1591C141

General-duty citation text

29 CFR  1910.1000(e): Feasible administrative or engineering controls were not determined and implemented to achieve compliance with the limits prescribed in 29 CFR 1910.1000(a) through (d):  On or about November 9, 2022, employees working the D-Man line exposures were exposed in excess of the permissible exposure limit for the mixture for Lead and Cadmium and administrative or engineering controls were not implemented to decrease employees exposures below the computation formula as specified in in 29 CFR 1910.1000(d)(2)(i).  (a)  The employer did not ensure that employee exposure to concentrations of more than one substance did not exceed the permissible exposure limit for the mixture of heavy metals to include inorganic Lead and Cadmium. The mixture has additive toxic effects on the kidney. This violation occurred on November 9, 2022, where the employee was dismantling Cathode Ray Tubes on the D-Man line. The employee was exposed to inorganic Lead at an 8-hour time weighted average (TWA) of 0.00778 milligrams per cubic meter (mg/m3) of air, approximately 0.155 times the permissible exposure limit (PEL) of 0.05 mg/m3; and Cadmium at an 8-hour TWA of 0.00807 mg/m3 of air, approximately 1.61 times the PEL of 0.005 mg/m3. The exposure concentration was approximately 1.63 times the permissible 8-hour TWA concentration for the mixture. Sampling was performed for 467 minutes. Zero exposure was assumed for the 13 minute period not sampled.  (b) The employer did not ensure that employee exposure to concentrations of more than one substance did not exceed the permissible exposure limit for the mixture of heavy metals to include inorganic Lead and Cadmium The mixture has additive toxic effects on the kidney. This violation occurred on November 9, 2022, where the employee was dismantling Cathode Ray Tubes on the M10 line and D-Man line. The employee was exposed to inorganic Lead at an 8-hour time weighted average (TWA) of 0.0284 milligrams per cubic meter (mg/m3) of air, approximately 0.568 times the permissible exposure limit (PEL) of 0.05 mg/m3;  and Cadmium at an 8-hour TWA of 0.0054 mg/m3 of air, approximately 1.082 times the PEL of 0.005 mg/m3. The exposure concentration was approximately 1.54 times the permissible 8-hour TWA concentration for the mixture. Sampling was performed for 465 minutes. Zero exposure was assumed for the 15 minute period not sampled.

Issued

Apr 7, 2023

Abate by

May 5, 2023

Penalty

Initial $8,036 · Current $6,831 Reduced

Hazardous substances 1591C141

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:  On or about October 26, 2022, employees were not provided respiratory medical evaluations when it was mandatory to wear a respirator when cleaning inside the glass packaging room and M10 area.

Issued

Apr 7, 2023

Abate by

May 5, 2023

Penalty

Initial $10,046 · Current $8,539 Reduced

Hazardous substances 1591C141

General-duty citation text

29 CFR  1910.134(f)(1): The employer did not ensure that employee(s) required to use a tight-fitting facepiece respirator passed the appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT):  On or about October 26, 2022, the employer did not ensure the employees passed a fit test when it was mandatory for employees to wear a respirator when cleaning inside the glass packaging room and M10 area.

Issued

Apr 7, 2023

Abate by

Jul 3, 2023

Penalty

Initial $14,063 · Current $11,954 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1910.1025(e)(3)(ii): The written compliance program for lead did not include the required sections:   On or about October 12, 2022, the employer's written lead compliance program did not include the information required in sections [A] - [C] and [E] - [G]:   a.  The written lead compliance program did not describe each operation in which lead was emitted, as required under section [A].  b.  The written lead compliance program did not have a description of the specific means that will be employed to achieve compliance, including engineering plans and studies used to determine methods selected for controlling exposure to lead, as required under section [B].  c.  The written lead compliance program did not have a report of the technology considered in meeting the permissible exposure limit, as required under section [C].  d.  The written lead compliance program did not have a detailed schedule for implementation of the program, including documentation such as copies of purchase orders for equipment, construction contracts, etc., as required under section [E].   e.  The written lead compliance program did not have a work practice program which includes items required under paragraphs (g), (h) and (i) of this regulation, as required under section [F].  f.   The written lead compliance program did not have an administrative control schedule required by paragraph (e)(5) of this section, if applicable, as required under section [G].

Issued

Apr 7, 2023

Abate by

May 5, 2023

Penalty

Initial $14,063 · Current $11,954 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1910.1025(f)(3)(i)(A): Respirators required under 29 CFR 1910.1025 for protection against lead, were not selected from Table II of 29 CFR 1910.1025: in accordance with 29 CFR 1910.134(d)(3)(i)(A):   On or about October 12, 2022, an employee working in the Glass Area - Processing was exposed to Lead at 183 ug/m3 or 4.09 times the Lead permissible exposure limit  of  50 ug/m3 and the employer did not provide the employee with appropriate respiratory protection, such as an elastomeric half mask respirator with HEPA cartridges.

Issued

Apr 7, 2023

Abate by

Jul 3, 2023

Penalty

Initial $14,063 · Current $11,954 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1910.1025(h)(1):All surfaces were not maintained as free as practicable of accumulations of lead:  On or about October 26, 2022, the employer did not ensure that all surfaces were maintained as free as practicable of the accumulation of lead inside and outside of employees' lockers used for storing personal items and work related personal protective equipment. The lockers were located between the glass processing and the D-Man Line.

Issued

Apr 7, 2023

Abate by

Jul 3, 2023

Penalty

Initial $0 · Current $0

Hazardous substances C141

General-duty citation text

29 CFR  1910.1027(k)(1):Surfaces were not maintained as free as practicable of accumulations of cadmium:  On or about October 26, 2022, the employer did not ensure that all surfaces were maintained as free as practicable of the accumulation of cadmium inside and outside of employees' lockers used for storing personal items and work related personal protective equipment, the lockers were located between the glass processing and the D-Man area.

Issued

Apr 7, 2023

Abate by

May 5, 2023

Penalty

Initial $14,063 · Current $11,954 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1910.1025(j)(3)(i)(B): Medical examinations and consultations for Lead were not performed prior to assignment for each employee being assigned for the first time to an area in which airborne concentrations of lead were at or above the action level:   Medical examinations and consultations for lead were not performed prior to assignment for employees assigned to an area in which airborne concentration of Lead were at or above the Action Level:  (a)  On October 12, 2022, and at times thereafter, an employee in the Glass Area - Processing was exposed to Lead at 183 ug/m3 as an 8-hour time weighted average, or 6.1 times the action level, and did not have a medical examination and consultation prior to assignment, or at anytime after assignment.  (b) On October 12, 2022, and at times thereafter, an employee in the Glass Area - Processing was exposed to Lead at 48 ug/m3 as an 8-hour time weighted average, or 1.6 times the action level, and did not have a medical examination and consultation prior to assignment, or at anytime after assignment.  (c) On November 9, 2022, and at times thereafter, an employee on the Shred Line and M-10 tumbler area was exposed to Lead at 37.8 ug/m3 as an 8-hour time weighted average, or 1.26 times the action level, and did not have a medical examination and consultation prior to assignment, or at anytime after assignment.