OSHA Inspection: MORGAN TRUCK BODY, LLC

Issued

Aug 21, 2023

Abate by

Oct 6, 2023

Penalty

Initial $15,625 · Current $12,500 Reduced

General-duty citation text

29 CFR  1910.120(q)(1):  The employer did not develop and implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:  Tank Room:  On, or about, May 1, 2023, the remaining contents in a used tank of HandiFoam FR HFO A-side expanding foam component was released while employees were removing hoses from used tanks for disposal.  The tank contained 4-4'-diphenylmethane diisocyanate (MDI) and an isocyanate detection unit immediately sounded an alarm.  The employees evacuated the room and the alarm continued to sound.  Instead of calling for assistance as directed on the information posted on the Tank Room door, the employer sent in a Maintenance Technician to disable the alarm.  Later on that shift and on subsequent days, a Foaming Lead Person entered the room to turn the open/close valves on the piping system that supplied the foam components to work areas in the plant.  The level of MDI in the tank room was not determined until approximately ten days later when a representative from the chemical manufacturer was on site and told the company that it was safe to enter the room and the detection unit was put back into service.  The employer did not follow the established procedures of either calling a contractor listed on the posting on the tank room entry door or following the Spill Response/Chemical Release procedures contained in the Emergency Action Plan (EHS-S-113).

Issued

Aug 21, 2023

Abate by

Oct 6, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.120(q)(3)(iv):  Employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard, did not wear positive-pressure self-contained breathing apparatus until such time that the individual in charge of the incident command system determined through the use of air monitoring that a decreased level of respiratory protection would not result in hazardous exposures to employees:  Tank Room:  On, or about, May 1, 2023, an employee entered the Tank Room to disable the alarm system after 4-4'-diphenylmethane diisocyantate (MDI) was released during the scrapping of used portable tanks.  The employer did not either determine that the Tank Room was safe to enter through the use of detection equipment or provide the employee with a self-contained breathing apparatus.  In addition, employees also entered the Tank Room to turn the foam piping system on/off while the alarm system was disabled and the level of MDI in the atmosphere was unknown.

Issued

Aug 21, 2023

Abate by

Oct 6, 2023

Penalty

Initial $15,625 · Current $12,500 Reduced

General-duty citation text

29 CFR  1910.1200(e)(1)(ii):  The written hazard communication program did not include the methods the employer would use to inform employees of the hazards of non-routine tasks:  Facility:  On, or about, May 1, 2023, the employer's Hazard Communication Program (EHS-E-001) did not address how employees would be informed of the hazards associated with non-routine tasks.  Employees were directed to clean-up expended tanks of expanding foam components which was a non-routine task.  The tanks contained 4-4' diphenylmethane diisocyanate (MDI) and other hazardous chemicals.

Issued

Aug 21, 2023

Abate by

Oct 6, 2023

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.1200(h)(1): Employees were not provided effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new hazard that the employees had not been previously trained about was introduced into their work area:   Facility:  On, or about, May 1, 2023, the employer did not provide information and training regarding the hazardous components of HandiFoam FR HFO A-side and HandiFoam B-side to employees who were tasked with disposing of expended one gallon tanks of the material.  Two of the employees had not received training regarding the hazards associated with the chemicals and none of the  employees had received training regarding what measures they could take to protect themselves from the hazards associated with handling used tanks of HandiFoam FR HFO A-side and HandiFoam B-side.  One team of employees was tasked with removing the hoses from the tanks and another team of employees opened the tanks to dump the contents into barrels.