OSHA Inspection: NATIONAL FLEET SERVICES OF OHIO, LLC

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $14,518 · Current $7,000 Reduced

General-duty citation text

29 CFR 1910.134(c)(1): In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer failed to establish and implement a written respiratory protection program with worksite-specific procedures. The program shall be updated as necessary to reflect those changes in workplace conditions that affect respirator use. The employer shall include in the program the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures.  On or about November 7, 2023, the employer failed to develop and implement a written respiratory protection program for employees that used different chemical products that generate respiratory hazards including but not limited to Zinc Metal, ZRC Cold Galvanizing Compound, Carbon and Alloy Steels, Zirconium, Carbon Steel solid wire and rods, and Cadmium anodes. These products generated respirable hazards where employees were discovered to be over the Permissible Exposure Limit (PEL) including but not limited to Zinc Oxide Fumes, Bulk Iron, Zinc, and Cadmium during work operations including grinding, mig welding, and spray-painting metal sub frames of the trucks. The program must include how to train employees on hazardous chemical products used in different operations and how to identify the different hazards located in the SDS and labels on the containers for products.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(e)(1): The employer shall 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 November 7, 2023, the employer did not provide a medical evaluation program for employees who require the use of respirators in the workplace or use respirators in the workplace including the 3M Particulate Respirator 9010 and the LPR-100 Series Half Mask Respirator with P100 filters. The employer must require employees to wear the respirators for operations where they are exposed to respirable hazards over the Permissible Exposure Limit (PEL) including but not limited to mig welding, grinding, and spraying product onto the frame of the trucks including but not limited to Zinc Metal, ZRC Cold Galvanizing Compound, Carbon and Alloy Steels, Zirconium and Carbon Steel, and Cadmium anodes that generate respirable hazards including but not limited to Zinc Oxide Fumes, Bulk Iron, Zinc, and Cadmium.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(f)(2): The employer shall ensure that an employee using a tight-fitting facepiece respirator is fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.  On or about November 7, 2023, the employer did not develop and implement an effective fit testing program that evaluates employees' effectiveness in wearing a respirator that is tight fitting and fits the employees' face including the 3M Particulate Respirator 9010 and the LPR-100 Series Half Mask Respirator with P100 filters. The employer is required to have employees wear the respirators in the workplace as there are operations such as mig welding, grinding, and spraying product onto the frame of the trucks that require the use of respirators and have employees exposed to respirable hazards over the Permissible Exposure Limits (PELs) including but not limited to Zinc Oxide Fumes, Bulk Iron, Zinc, and Cadmium from products including but not limited to Zinc Metal, ZRC Cold Galvanizing Compound, Carbon and Alloy Steels, Zirconium and Carbon Steel, and Cadmium anodes.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(k)(1)(i): 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 requires why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator.  On or about November 7, 2023, the employer did not develop and implement effective employee training on the use of respirators in the workplace including the 3M Particulate Respirator 9010 and the LPR-100 Series Half Mask Respirator with P100 filters. The employer had respirator use be optional for welding and grinding operations however certain employees were exposed to respirable hazards over the Permissible Exposure Limits (PELs) including but not limited to Zinc Oxide Fumes, Bulk Iron, Zinc, and Cadmium from products including but not limited to Zinc Metal, ZRC Cold Galvanizing Compound, Carbon and Alloy Steels, Zirconium and Carbon Steel, and Cadmium anodes. Because of their overexposure employees conducting mig welding, grinding, and spraying operations on the frame of the truck must be required to wear respirators when conducting these operations.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 0491

General-duty citation text

29 CFR 1910.1027(d)(1)(i): Each employer who has a workplace or work operation covered by this section failed to determine if any employee may be exposed to cadmium at or above the action level.  On or about November 7, 2023, the employer did not ensure that a determination was conducted for employees conducting welding operations and prep grinders to evaluate exposure to cadmium above the action level.  The employees conducting welding operations generate respirable hazards including cadmium fumes from mig welding the trucks. The trucks contain anode bolts that are made of cadmium, which gets released when the bolts are heated to attach a catalytic converter cage to the truck. During sampling it was determined a prep grinder working near the welding operations was exposed to cadmium fumes over the action level and welders who were also sampled were over the Permissible Exposure Limit (PEL) for cadmium. Long term exposure to cadmium over the PEL can cause chronic illnesses including lung disease and cancer.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 0491

General-duty citation text

29 CFR 1910.1027(g)(1): General. For employees who use respirators required by this section, the employer must provide each employee an appropriate respirator that complies with the requirements of paragraphs 1910.1027(g)(1)(i) to paragraph 1910.1027(g)(1)(vii).  On or about November 7, 2023, the employer failed to develop and implement a program that requires all employees to wear a respirator for mig welding operations. Welders weld catalytic converter cages onto to anode bolts of the trucks and the bolts release and expose employees to respirable hazards over the Permissible Exposure Limit (PEL) for cadmium fumes. On December 5, 2023, two welders were sampled and were exposed to an 8-hour TWA of 0.016 milligrams per cubic meter and 0.021 milligrams per cubic meter of cadmium fumes. The exposure levels were derived from a sample collected over a 387-minute and 380-minute sampling period, with zero exposure assumed for the unsampled period of 93 minutes and 100 minutes.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 0491

General-duty citation text

29 CFR 1910.1027(l)(1)(i)(A): The employer failed to institute a medical surveillance program for all employees who are or may be exposed to cadmium at or above the action level unless the employer demonstrates that the employee is not, and will not be, exposed at or above the action level on 30 or more days per year (twelve consecutive months).  On or about November 7, 2023, the employer did not provide a medical surveillance program for employees who are or may be exposed to cadmium at or above the action level on 30 or more days per year. The employer must require employees conducting welding and prep grinding operations to be a part of a surveillance program as they are exposed to respirable hazards including but not limited to Cadmium from the welding operations done by employees including mig welding the anode bolts of the frame of the truck, which are coated in Cadmium, to a catalytic converter cage. During sampling it was determined welders sampled were over the Permissible Exposure Limit (PEL) for Cadmium and a prep grinder was discovered to be over the action level for cadmium.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $12,445 · Current $7,000 Reduced

Hazardous substances 2610I200Z100

General-duty citation text

29 CFR 1910.1000(a)(2): Other substances -- 8-hour Time Weighted Averages. An employee's exposure to any substance in Table Z-1, the exposure limit of which is not preceded by a "C", shall not exceed the 8-hour Time Weighted Average given for that substance any 8-hour work shift of a 40-hour work week.  On or about November 7, 2023, the employer failed to ensure that all prep grinders working in building 583 Miller Road in Avon Lake, Ohio 44012 were below the Permissible Exposure Limit (PEL) for respirable zinc oxide fumes of 8-hour Time Weighted Average (TWA) of 5 milligrams per cubic meter each and bulk iron of 10 milligrams per cubic meter. A prep grinder was sampled on December 5, 2023, and was exposed to an 8-hour TWA of 21.57 milligrams per cubic meter for zinc oxide fumes, approximately 4.31 times the PEL, 21.57 milligrams per cubic meter for bulk iron, approximately 2.16 times the PEL, and 17.11 milligrams per cubic meter for zinc, approximately 3.42 times the PEL. Prep Grinders grind and work with products including but not limited to zinc metal, ZRC Cold Galvanizing Compound, and carbon and alloy steels which contain zinc and iron. The exposure levels were derived from a sample collected over a 357-minute sampling period, with zero exposure assumed for the unsampled period of 123 minutes.

Issued

Mar 19, 2024

Abate by

Jul 30, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 2610I200Z100

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 7, 2023, the employer failed to develop and implement effective engineering and administrative controls that limited employee exposure to respiratory hazards generated from mig welding, grinding and spraying operations including spraying using ZRC Cold Galvanizing Compound, welding using zirconium and carbon steel solid wire and grinding on zinc metal and carbon and alloy steels of the metal sub frames of the trucks. Employees were exposed to respirable hazards including but not limited to zinc oxide fumes, zinc oxide, and bulk iron from these welding operations. On December 5, 2023, an employee was sampled and exposed to an 8-hour TWA of 21.57 milligrams per cubic meter for zinc oxide fumes, approximately 4.31 times over the PEL, 21.57 milligrams per cubic meter for bulk iron, approximately 2.16 times over the PEL, and 17.11 milligrams per cubic meter for zinc, approximately 3.42 times over the PEL The exposure levels were derived from a sample collected over a 357-minute sampling period, with zero exposure assumed for the unsampled period of 123 minutes.

Issued

Mar 19, 2024

Abate by

Jul 30, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 0491

General-duty citation text

29 CFR  1910.1027(c): The employer failed to assure that no employee is exposed to an airborne concentration of cadmium in excess of five micrograms per cubic meter of air (5 ug/m(3)), calculated as an eight-hour time-weighted average exposure (TWA).  On or about November 7, 2023, the employer failed to ensure that welders working in building 583 Miller Road in Avon Lake, Ohio 44012 were below the Permissible Exposure Limit (PEL) for cadmium fumes of an 8-hour Time Weighted Average (TWA) of 0.005 milligrams per cubic meter. Welders were sampled on December 5, 2023. A welder was exposed to an 8-hour TWA of 0.016 milligrams per cubic meters for cadmium fumes, which is approximately 3.2 times over the PEL. The exposure level was derived from a sample collected over a 387-minute sampling period, with zero exposure assumed for the unsampled period of 93 minutes. A second welder was exposed to an 8-hour TWA of 0.021 milligrams per cubic meters for cadmium fumes, which is approximately 4.2 times over the PEL. The exposure level was derived from a sample collected over a 380-minute sampling period, with zero exposure assumed for the unsampled period of 100 minutes.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $14,518 · Current $7,000 Reduced

Hazardous substances 0491

General-duty citation text

29 CFR 1910.1027(e)(1): The employer did not establish a regulated area wherever an employee's exposure to airborne concentrations of cadmium is or can reasonably be expected to be in excess of the permissible exposure limit (PEL).  On or about November 7, 2023, the employer failed to ensure a regulated area inside of building 583 Miller Road in Avon Lake, Ohio 44012 was established where employees would be reasonably expected to be at or over the permissible Exposure Limit (PEL) for cadmium across an 8-hour Time Weighted Average (TWA) of 0.005 milligrams per cubic meter. On December 5, 2023, two welders were sampled and determined to be exposed to an 8-hour TWA of 0.016 milligrams per cubic meter and 0.021 milligrams per cubic meter of cadmium fumes. The exposure levels were derived from a sample collected over a 387-minute and 380-minute sampling period, with zero exposure assumed for the unsampled period of 93 minutes and 100 minutes.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $14,518 · Current $7,000 Reduced

Hazardous substances 0491

General-duty citation text

29 CFR 1910.1027(f)(1)(i): Except as specified in paragraphs (f)(1)(ii), (iii) and (iv) of this section the employer failed to implement engineering and work practice controls to reduce and maintain employee exposure to cadmium at or below the PEL, except to the extent that the employer can demonstrate that such controls are not feasible.  On or about November 7, 2023, the employer failed to verify that their current work practice controls to reduce cadmium exposure below the Permissible Exposure Limit (PEL) for cadmium of an 8-hour Time Weighted Average (TWA) of 0.005 milligrams per cubic meter was effective. Welders were given a Filtair MWX-D Mobile Weld Fume Extractor and employees were also given a 3M Particulate Respirator 9010 or LPR-100 Series Half Mask Respirator with P100 filters. Two welders sampled on December 5, 2023, were exposed to an 8-hour TWA of 0.016 milligrams per cubic meter and 0.021 milligrams per cubic meter of cadmium fumes from welding operations including welding on the steel frame that contains anode bolts of a box truck. The exposure levels were derived from a sample collected over a 387-minute and 380-minute sampling period, with zero exposure assumed for the unsampled period of 93 minutes and 100 minutes.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 0491

General-duty citation text

29 CFR 1910.1027(f)(2)(i): Where the PEL is exceeded, the employer shall establish and implement a written compliance program to reduce employee exposure to or below the PEL by means of engineering and work practice controls, as required by paragraph (f)(1) of this section. To the extent that engineering and work practice controls cannot reduce exposures to or below the PEL, the employer shall include in the written compliance program the use of appropriate respiratory protection to achieve compliance with the PEL.  On or about November 7, 2023, the employer failed to develop and implement a written compliance program to help train employees and help them identify exposures to cadmium below the Permissible Exposure Limit (PEL) for cadmium of 0.005 milligrams per cubic meter across an 8-hour Time Weighted Average (TWA) for welding operations that generated cadmium fumes. Welders use products including but not limited to carbon and alloy steels and zirconium and carbon steel solid wire and rods for operations that generate respiratory hazards including welding the catalytic converter cages to the bolts of the trucks. These products and operations generated respirable hazards where employees were found on December 5, 2023, to be over the Permissible Exposure Limit (PEL) including but not limited to cadmium during work operations. Two welders were discovered to have an exposure of 0.016 milligrams per cubic meter and 0.021 milligrams per cubic meter for cadmium fumes.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $0 · Current $0

Hazardous substances 0491

General-duty citation text

29 CFR  1910.1027(f)(3)(i): When ventilation is used to control exposure, measurements that demonstrate the effectiveness of the system in controlling exposure, such as capture velocity, duct velocity, or static pressure shall be made as necessary to maintain its effectiveness.  On or about November 7, 2023, the employer failed to verify that their current work practice control of using a Filtair MWX-D Mobile Weld Fume Extractor was effective in reducing employees' cadmium exposure below the Permissible Exposure Limit (PEL) for cadmium of an 8-hour Time Weighted Average (TWA) of 0.005 milligrams per cubic meter. Two welders sampled on December 5, 2023, were exposed to an 8-hour TWA of 0.016 milligrams per cubic meter and 0.021 milligrams per cubic meter of cadmium fumes despite all welders being supplied a fume extractor used at each welding location. The exposure levels were derived from a sample collected over a 387-minute and 380-minute sampling period, with zero exposure assumed for the unsampled period of 93 minutes and 100 minutes.

Issued

Mar 19, 2024

Abate by

Apr 11, 2024

Penalty

Initial $14,518 · Current $7,000 Reduced

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 specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, safety data sheets, and employee information and training will be met.  On or about November 6, 2023, the employer failed to develop and maintain a written Hazard Communication (HAZCOM) program for employees that use different chemical products including but not limited to Zinc Metal, ZRC Cold Galvanizing Compound, Carbon and Alloy Steels, Zirconium and Carbon Steel, and Gas Mixture (Argon 50-90%, Carbon Dioxide 10-50%) for operations including grinding, mig welding, and spray-painting metal sub frames of trucks. The program must include how to train employees on hazardous chemical products used in different operations and how to identify the different hazards located in the SDS and labels on the containers for products including but not limited to respiratory hazards, skin irritation and sensitization, and damage to the central nervous system.