OSHA Inspection: WINDOW RESTORATIONS OF CONNECTICUT

Issued

Feb 28, 2024

Abate by

Jun 12, 2024

Penalty

Initial $5,531 · Current $4,000 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(c)(1): The employer did not ensure that no employees were exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 ug/m3) averaged over an 8-hour period:  Shop - Work Stations Router Room De-glazing Room  a) On or about October 31, 2023, an employee working on tasks such as (but not limited to) paint stripping, dry sanding, and using the router was overexposed to lead at 186.8 micrograms per cubic meter (ug/m3) as an 8-hr TWA, which results in a severity of 3.7369. This exposure was approximately 3.74 times the PEL of 50.0 micrograms per cubic meter (ug/m3) and was determined during a sampling period of 323 minutes, using zero exposure for the 157 minutes of the unsampled portion of the 8-hour shift.  b) On or about October 30, 2023, an employee working on tasks such as (but not limited to) paint stripping, dry sanding, and using the router was overexposed to lead at 72.5 micrograms per cubic meter (ug/m3) as an 8-hr TWA, which results in a severity of 1.4508. This exposure was approximately 1.45 times the PEL 50.0 micrograms per cubic meter (ug/m3) and was determined during a sampling period of 444 minutes, using zero exposure for the 36 minutes of the unsampled portion of the 8-hour shift.   c) On or about October 31, 2023, an employee working on tasks such as (but not limited to) paint stripping, dry sanding, and using the router was overexposed to lead at 59.8 micrograms per cubic meter (ug/m3) as an 8-hr TWA, which results in a severity of 1.1968. This exposure was approximately 1.12 times the PEL of 50.0 micrograms per cubic meter (ug/m3) and was determined during a sampling period of 368 minutes, using zero exposure for the 112 minutes of the unsampled portion of the 8-hour shift.

Issued

Feb 28, 2024

Abate by

Jun 12, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(e)(1):Where all feasible engineering and work practice controls that could be instituted were not sufficient to reduce employee exposure to or below the permissible exposure limit, the employer did not fully use such controls to reduce employee exposure to the lowest feasible level and supplement them by the use of respiratory protection that complies with the requirements of 29 CFR 1926.62(f):  On or about August 30, 2023, the employer did not ensure employees were not exposed to lead concentrations above the permissible exposure limit (0.05 mg/m3) through sufficient engineering and work practice controls and did not supplement with the use of respiratory protection that complies with 29 CFR 1926 (f) while employees were working on restoring historical windows and doors in the following areas:  a) Shop - work stations b) Router Room c) De-glazing Room

Issued

Feb 28, 2024

Abate by

Jun 12, 2024

Penalty

Initial $5,531 · Current $0 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(d)(1)(i): The employer did not initially determine if any employee may be exposed to lead at or above the action level:   On or about August 30, 2023, the employer did not perform an initial determination of employee exposures to lead at or above the action level while work operations covered by this standard were performed. Carpenters resurfaced historical lead-based painted windows and doors with various tools including a 120V DeWALT Random Orbit Palm Sander (DWE6423), 120V BOSCH 1617EVS Router, Spengar IR Paint Stripper, and a glaze putty scraper in the following areas:    a.) Shop b.) Router Room c.) De-glazing room d.) In the field during disassembly and installation

Issued

Feb 28, 2024

Abate by

Jun 12, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(d)(1)(iii):The employer did not collect personal samples representative of a full shift, including at least one sample for each job classification in each work area, either for each shift or for the shift with the highest exposure level:  a) Shop - work stations: On or about August 30, 2023, the employer did not perform an initial determination of exposures based on the relevant considerations of information and observations that indicated employees were exposed to lead when Carpenters worked with or were in the vicinity of dust that was suspended by either cleaning with compressed air or by sanding down lead-based painted windows and doors. Carpenters resurfaced historical lead-based painted windows and doors with a 120V DeWALT Random Orbit Sander (DWE6423) at their workstations in the Shop.  b) Router Room: On or about August 30, 2023, the employer did not perform an initial determination of exposures based on the relevant considerations of information and observations that indicated employees were exposed to lead when routing out new sashes with a 120V BOSCH 1617EVS Router in historical windows and doors in the router room.    c) De-glazing Room: On or about August 30, 2023, the employer did not perform an initial determination of exposures based on the relevant considerations of information and observations that indicated employees were exposed to lead. Carpenters stripped old paint and glaze from historical windows and doors with a Spengar IR Paint Stripper and a glazing knife.  d) Field Disassembly and Installation: On or about August 30, 2023, the employer did not perform an initial determination of exposures based on the relevant considerations of information and observations that indicated employees were exposed to lead. Carpenters working off-site in the field, disassembled and restored windows and doors by scraping and sanding material that suspended lead-based paint dust while working at a customer's home or building.

Issued

Feb 28, 2024

Abate by

Jun 12, 2024

Penalty

Initial $5,531 · Current $3,000 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(d)(2)(v)(A): Until the employer performed an employee exposure assessment as required under 29 CFR 1926.62(d) and determined actual employee exposure, the employer did not provide to employees performing the tasks described in 29 CFR 1926.62(d)(2)(i)(A) with appropriate respiratory protection in accordance with 29 CFR 1926.62(f):  On or about August 30, 2023, without having performed an employee lead exposure assessment, the employer did not institute the required elements of a respirator program in the following locations:  a) Shop b) Routing Room c) De-glazing Room

Issued

Feb 28, 2024

Abate by

Jun 12, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(f)(2)(i): The employer did not implement a respiratory protection program in accordance with 29 CFR 1910.134(b) through (d) (except (d)(1)(iii)), and (f) through (m) for each employee required by 29 CFR 1926.62 to use a respirator:  On or about August 30, 2023, the employer did not institute the required elements of a respirator program in accordance with 29 CFR 1910.134(b) through (d) for employees required to wear elastomeric half-face respirators while restoring historical lead-based painted windows and doors in the following locations:  a) Shop b) Routing Room c) De-glazing Room

Issued

Feb 28, 2024

Abate by

Jun 12, 2024

Penalty

Initial $5,531 · Current $2,500 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(d)(2)(v)(B): Until the employer performed an employee exposure assessment as required under 29 CFR 1926.62(d) and determined actual employee exposure, the employer did not provide employees performing the tasks described in 29 CFR 1926.62(d)(2)(i)(A), with appropriate personal protective clothing and equipment in accordance with 29 CFR 1926.62(g):  On or about August 30, 2023, without having performed an employee exposure assessment, the employer failed to provide carpenters with the appropriate personal protective clothing and equipment in accordance with 29 CFR 1926.62(g). Employees performed tasks described in 29 CFR 1926.62(d)(2)(i)(A) (e.g. manual scraping; manual sanding; and infrared gun applications) in the following locations:  a) Shop b) Routing Room c) De-glazing Room d) In the field during disassembly and installation

Issued

Feb 28, 2024

Abate by

Jun 12, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(g)(1)(i):The employer did not provide, at no cost to the employee, and ensure that the employee used appropriate protective work clothing and equipment that prevented contamination of the employee and the employee's garments, such as, but not limited to coveralls or similar full-body work clothing:  On or about August 30, 2023, the employer did not ensure that carpenters used and/or were provided the appropriate protective work clothing and equipment to prevent contamination of the employee and their garments such as coveralls or similar full-body work clothing, among others. Employees performed dust suspending activities during the restoration of historical lead-based painted windows and doors in the following areas:  a) Shop b)Routing Room c) De-glazing Room

Issued

Feb 28, 2024

Abate by

Jun 12, 2024

Penalty

Initial $5,531 · Current $2,500 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(d)(2)(v)(F): Until the employer performed an employee exposure assessment as required under 29 CFR 1926.62(d) and determined actual employee exposure, the employer did not provide to employees performing the tasks described in 29 CFR 1926.62(d)(2)(i)(A), with training in accordance with 29 CFR 1926.21, Safety training and education:  On or about August 30, 2023, the employer did not ensure that all employees, performing the tasks described in 29 CFR 1926.62(d)(2)(i)(A), were made aware of the requirements of Subpart D. Employees performed dust suspending operations while working with historical lead-based painted windows and doors. These tasks included, but were not limited by, sanding; cleaning with compressed air; and emptying vacuumed dust, which exposed employees to inhalation and skin contact hazards within the following areas:    a) Shop b) Routing Room c) De-Glazing Room d) In the field during disassembly and installation

Issued

Feb 28, 2024

Abate by

Jun 12, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(l)(2): Employees were not trained in the elements listed in paragraphs (i) through (viii) of this section:  On or about August 30, 2023, the employer did not ensure that all employee(s) working in areas where there was potential exposure to airborne lead at any level were informed of the contents of this section including, but not limited to, its appendices and the nature of operations that could result in exposure. Employees performed dust suspending operations that, among other tasks, included sanding, cleaning with compressed air, and emptying vacuumed dust while working with historical lead-based painted windows and doors that exposed them to inhalation, skin contact, and ingestion hazards within the following areas:    a) Shop b) Routing Room c) De-glazing Room d) In the field during disassembly and installation  Abatement note: Training on the following elements of 1926.62(l)(2) is to be provided to exposed employees: (i) The content of this standard and its appendices; (ii) The specific nature of the operations which could result in exposure to lead above the action level; (iii) The purpose, proper selection, fitting, use, and limitations of respirators; (iv) The purpose and a description of the medical surveillance program, and the medical removal protection program including information concerning the adverse health effects associated with excessive exposure to lead (with particular attention to the adverse reproductive effects on both males and females and hazards to the fetus and additional precautions for employees who are pregnant); (v) The engineering controls and work practices associated with the employee's job assignment including training of employees to follow relevant good work practices described in appendix B of this section.

Issued

Feb 28, 2024

Penalty

Initial $3,687 · Current $2,000 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(h)(1): All surfaces were not maintained as free as practicable of accumulations of lead:  On or about August 30, 2023, the employer did not ensure that all surfaces including windowsills, workbenches, where drinks and snacks were stored, were maintained as free as practicable from the accumulation of lead dust while employees restored historical lead-based painted windows and doors.  a.) Break Room

Issued

Feb 28, 2024

Abate by

Jun 12, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 1591

General-duty citation text

29 CFR  1926.302(b)(4):Compressed air, 30 p.s.i. or more, was used for cleaning purposes:  On or about August 30, 2023, compressed air was used to clean lead particle accumulations from work benches, and other surfaces after lead-based painted windows and doors were resurfaced. This was performed with a compressed air gun having a pressure over 60 p.s.i. within the following areas:   a) Shop - Work stations