OSHA Inspection: THE AMERICAN STEEL PRODUCTS CO.

Issued

May 16, 2023

Abate by

Jul 21, 2023

Penalty

Initial $3,349 · Current $1,250 Reduced

Hazardous substances 05051520244025909000

General-duty citation text

29 CFR  1910.134(c)(1): In the workplace where respirators are required by the employer, the employer failed to establish and implement an adequate written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures required to have respirator use.   On or about February 23, 2023 the employer did not develop and implement a written respiratory protection program with worksite specific procedures for respirators used in the workplace including the Model 9251 Gerson Paint Body Combo Kits, 3M Half Facepiece Reusable Respirator 6200 with P100 Filters, and Honeywell RU6500 with P100 Filters. The employer requires employees to wear the respirators for painting operations including but not limited to using the products Shopcoat Primer Red Oxide and PRO INDUSTRIAL DTM Acrylic Semi-Gloss Extra White to refurbish steel processing equipment that contain hazardous chemicals including but not limited to Calcium Carbonate, Titanium Dioxide, Iron Oxide, Xylene, and Respirable Powder Cristobalite.

Issued

May 16, 2023

Abate by

Jul 21, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 05051520244025909000

General-duty citation text

29 CFR  1910.134(d)(1)(iii): The employer failed to identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.  On or about February 23, 2023 the employer did not conduct a workplace evaluation to identify the different types of respiratory hazards found in the spray painting operations used for refurbishing steel processing equipment. The paint used in this operation include the products Shopcoat Primer Red Oxide and PRO INDUSTRIAL DTM Acrylic Semi-Gloss Extra White and contain hazardous chemicals including but not limited to Calcium Carbonate, Titanium Dioxide, Iron Oxide, Xylene, and Respirable Powder Cristobalite.

Issued

May 16, 2023

Abate by

Jul 21, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 05051520244025909000

General-duty citation text

29 CFR  1910.134(e)(1): The employer failed to 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.  On or about February 23, 2023 the employer did not develop and implement a medical evaluation program for employees who use respirators in the workplace including the Model 9251 Gerson Paint Body Combo Kits, 3M Half Facepiece Reusable Respirator 6200 with P100 Filters, and Honeywell RU6500 with P100 Filters. The employer requires employees to wear the respirators for painting operations including but not limited to using the products Shopcoat Primer Red Oxide and PRO INDUSTRIAL DTM Acrylic Semi-Gloss Extra White to refurbish steel processing equipment that contain hazardous chemicals including but not limited to Calcium Carbonate, Titanium Dioxide, Iron Oxide, Xylene, and Respirable Powder Cristobalite.

Issued

May 16, 2023

Abate by

Jul 21, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 05051520244025909000

General-duty citation text

29 CFR  1910.134(k): The employer failed 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.  On or about February 23, 2023 the employer did not conduct employee training for employees who conduct spray painting operations for refurbishing steel processing equipment. The employer has respirators for employees to wear including the Model 9251 Gerson Paint Body Combo Kits, 3M Half Facepiece Reusable Respirator 6200 with P100 Filters, and Honeywell RU6500 with P100 Filters but does not train employees on any of the respirators available. The employer requires employees to wear the respirators for painting as part of refurnishing machinery operations using the products Shopcoat Primer Red Oxide and PRO INDUSTRIAL DTM Acrylic Semi-Gloss Extra White. These paints contain hazardous respirable chemicals including but not limited to Calcium Carbonate, Titanium Dioxide, Iron Oxide, Xylene, and Respirable Powder Cristobalite.

Issued

May 16, 2023

Abate by

Jul 21, 2023

Penalty

Initial $3,349 · Current $1,250 Reduced

Hazardous substances 05051520244025909000

General-duty citation text

29 CFR  1910.1200(e)(1): The employer failed to develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria of labeling on the shipped containers, Safety Data Sheets (SDS), and employee information and training will be met.  On or about February 23, 2023 the employer failed to develop and maintain a written Hazard Communication (HAZCOM) program for employees who conduct spray painting operations for refurbishing steel processing equipment. The program must include how to train employees on hazardous chemical products used in spray painting operations and how to identify the different hazards located in the SDS and labels on the containers for products including but not limited to the Shopcoat Primer Red Oxide and the PRO INDUSTRIAL DTM Acrylic Semi-Gloss Extra White which contain the chemical products Calcium Carbonate, Titanium Dioxide, Iron Oxide, Xylene, and Respirable Powder Cristobalite.

Issued

May 16, 2023

Abate by

Jul 21, 2023

Penalty

Initial $0 · Current $0

Hazardous substances 05051520244025909000

General-duty citation text

29 CFR  1910.1200(h)(1): Employers failed to provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets.  On or about February 23, 2023 the employer failed to develop and maintain a written training program for employees that handle hazardous chemical products for paint spraying operations that include the chemical products of Calcium Carbonate, Titanium Dioxide, Iron Oxide, Xylene, and Respirable Powder Cristobalite. The employees are responsible for using the paints such as the Shopcoat Primer Red Oxide and PRO INDUSTRIAL DTM Acrylic Semi-Gloss Extra White in spraying operations using a Titan Impact 440 Airless Sprayer as part of the process of refurbishing steel processing equipment. Without training, employees may be unaware of the respirable hazards associated with the paint and the controls to mitigate exposures.