OSHA Inspection: JD CORDAGE LLC

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $3457.00 · Current $1000.00 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(d)(1)(i):Each employer who had a workplace or operation covered by 29 CFR 1926.62 did not initially determine if any employee was exposed to lead at or above the Action Level of 30 micrograms per cubic meter of air (30 ug/m3), calculated as an 8-hour time-weighted average (TWA):  Worksite:  On or about  05/14/2024, when employees were conducting  the abrasive removal of Lead-based paint from window exteriors, the employer did not initially determine if either worker was exposed to Lead at, or above, OSHA's Action Level of 30 micrograms per cubic meter of air (30 ug/m3), calculated as an 8-hour time time-weighted average.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

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:  Worksite:  On or about 05/14/2024, when employees were conducting the abrasive removal of Lead-based paint from window exteriors, the employer did not collect personal samples representative of a full shift to determine if workers were exposed to Lead.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $3457.00 · Current $1500.00 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), (d)(2)(ii), (d)(2)(iii), and (d)(2)(iv) with appropriate respiratory protection in accordance with 29 CFR 1926.62(f):  Facility, 10 Cordage Park Circle, Plymouth, MA:  On or about 05/14/2024, when maintenance employees were abrasively removing Lead-based paint from window frames and the employer did not conduct an employee exposure assessment to determine Lead exposure and the employer did not ensure that the workers wore appropriate respiratory protection to prevent the inhalation and ingestion of Lead-contaminated dust.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(f)(1)(i): Respirators were not used during periods when an employee's exposure to lead exceeded the Permissible Exposure Limit (PEL):  Facility, 10 Cordage Park Circle, Plymouth, MA:  On or about 05/14/2024, when maintenance employees were abrasively removing Lead-based paint from window frames and the employer did not conduct an initial determination of Lead exposure, the employer did not ensure that the workers wore appropriate respiratory protection to prevent the inhalation and ingestion of Lead-contaminated dust.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $3457.00 · Current $1500.00 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), (d)(2)(ii), (d)(2)(iii), and (d)(2)(iv) with appropriate personal protective clothing and equipment in accordance with 29 CFR 1926.62(g):  Facility (10 Cordage Park Circle, Plymouth, MA): On or about 05/14/2024, when maintenance employees were abrasively removing and manually scraping Lead-based paint, the employer did not ensure that each worker wore protective work clothing and equipment to prevent Lead contamination of the employee's work clothes.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(g)(1): Where employees were exposed to lead above the permissible exposure limit, without regard to the use of respirators; where employees were exposed to lead compounds which may cause skin or eye irritation (e.g. Lead Arsenate, Lead Azide); and as interim protection for employees performing tasks as specified in 29 CFR 1926.62(d)(2), the employer did not ensure that each employee used appropriate protective work clothing and equipment that prevented contamination of the employee and the employee's garments:  Facility (10 Cordage Park Circle, Plymouth, MA): On or about 05/14/2024, when maintenance employees were abrasively removing Lead-based paint, the employer did not ensure that each worker wore protective work clothing and equipment to prevent Lead contamination of the employee's work clothes.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $3457.00 · Current $1000.00 Reduced

General-duty citation text

29 CFR  1926.62(d)(2)(v)(C): 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), (d)(2)(ii), (d)(2)(iii), and (d)(2)(iv) with change areas in accordance with 29 CFR 1926.62(i)(2):  Facility (10 Cordage Park Circle, Plymouth, MA): On or about 05/14/2024, when maintenance employees were abrasively manually scraping and removing Lead paint, the employer did not provide clean change areas for those workers to don and doff contaminated clothing and equipment, as specified in 29 CFR 1926.62 (i)(2)(i) through (iii).

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR  1926.62(i)(2)(i):The employer did not provide clean change areas for employees whose airborne exposure to lead was above the permissible exposure limit, without regard to the use of respirators:  Facility (10 Cordage Park Circle, Plymouth, MA): On or about 05/14/2024, when maintenance employees were abrasively removing Lead paint paint, the employer did not provide clean change areas for those workers to don and doff contaminated clothing and equipment, as specified in 29 CFR 1926.62 (i)(2)(i) through (iii).

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $3457.00 · Current $1000.00 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(d)(2)(v)(D): 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), (d)(2)(ii), (d)(2)(iii), and (d)(2)(iv) with hand washing facilities in accordance with 29 CFR 1926.62(i)(5):  Facility (10 Cordage Park Circle, Plymouth, MA):  When maintenance employees manually scraped and abrasively removed Lead-based paint and the employer did not conduct an initial assessment, the employer did not provide hand washing facilities for the workers to effectively remove contaminated debris.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(i)(5)(i): The employer did not provide adequate handwashing facilities in accordance with 29 CFR 1926.51(f), for use by employees exposed to lead:  Facility (10 Cordage Park Circle, Plymouth, MA): When maintenance employees manually scraped and abrasively removed Lead-based paint, the employer did not provide hand washing facilities for the workers to effectively remove contaminated debris.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $3457.00 · Current $1500.00 Reduced

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(d)(2)(v)(E): 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), (d)(2)(ii), (d)(2)(iii), and (d)(2)(iv) with biological monitoring in accordance with 1926.62(j)(1)(i), to consist of blood sampling and analysis for lead and zinc protoporphyrin levels:   Facility (10 Cordage Park Circle, Plymouth, MA):  On or about 05/14/2024, until the employer performed an employee assessment, as required in 29 CFR 1926.62(d), and documented that the employee(s) performing any of the listed tasks was not exposed above the Permissible Exposure Limit (PEL), the employer did not treat affected employee(s) as if they were exposed above the PEL, and not in excess of ten times the PEL, the employer did not institute an initial medical surveillance system consisting of biological monitoring in the form of blood sampling and analysis for Lead and Zinc protoporphyrin.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 1591

General-duty citation text

29 CFR  1926.62(j)(1)(i):The employer did not make available initial medical surveillance, consisting of biological monitoring in the form of blood sampling and analysis for lead and zinc protoporphyrin levels, to employees occupationally exposed on any day to lead at or above the action level:  Facility (10 Cordage Park Circle, Plymouth, MA):  When employees were abrasively removing Lead-based paint, the employer did not make available initial medical surveillance  in the form of blood sampling and analysis for Lead and Zinc Protoporphyrin levels.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $3457.00 · Current $1000.00 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), (d)(2)(ii), (d)(2)(iii), and (d)(2)(iv) with training as required under 29 CFR 1926.62(l)(1)(i) regarding 29 CFR 1926.59, Hazard Communication:  Facility (10 Cordage Park Circle, Plymouth, MA):  On or about 05/14/2024, until the employer performed an employee assessment, as required in 29 CFR 1926.62(d), and documented that the employee(s) performing any of the listed tasks was not exposed above the Permissible Exposure Limit (PEL), the employer did not treat affected employee(s) as if they were exposed above the PEL, and not in excess of ten times the PEL, the employer did not conduct training as required under 29 CFR 1926.62(l)(1)(i) regarding 29 CFR 1926.59, Hazard Communication.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

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), (d)(2)(ii), (d)(2)(iii), and (d)(2)(iv) with training as required under 29 CFR 1926.62(l)(1)(i) regarding 29 CFR 1926.59, Hazard Communication:  Facility (10 Cordage Park Circle, Plymouth, MA):  On or before 05/14/2024, when employees were required to abrasively remove Lead-based paint, and the employer did not conduct an employee Lead exposure assessment, the employer did not conduct training regarding respirator usage, safety training as required under 29 CFR 1926.21, and Hazard Communication training on the health effects of exposure to Lead.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $3457.00 · Current $1000.00 Reduced

General-duty citation text

29 CFR 1926.62(h)(3): Shoveling, dry or wet sweeping, and brushing were used when vacuuming or other equally effective methods were effective:  Facility (10 Cordage Park Circle, Plymouth, MA):  On or about 05/14/2024, when maintenance employees were abrasively removing Lead-based paint, the paint chips and dust were allowed to fall to the uncovered ground below.  One of the workers used a broom and dustpan to dry sweep and collect the material for disposal.  These actions can further disperse the contaminants into the workers breathing zone.

Issued

2024-10-15 00:00:00

Abate by

2025-03-20 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 1591

General-duty citation text

29 CFR 1926.62(h)(4): Where vacuuming methods were selected, the vacuums were not equipped with HEPA filters and/or were not used and emptied in a manner which minimized the reentry of lead into the workplace:  Facility (10 Cordage Park Circle, Plymouth, MA):  On or about 05/14/2024, when maintenance employees were abrasively removing Lead-based paint, the vacuum used to pick up debris was not equipped as a true HEPA vacuum with HEPA filters.

Issued

2024-10-15 00:00:00

Penalty

Initial $4839.00 · Current $3500.00 Reduced

General-duty citation text

29 CFR  1926.20(b)(2): The employer did not initiate and maintain programs which provided for frequent and regular inspections of the job site, materials, and equipment to be made by competent person(s):   Facility:  On or about 05/14/2024, two workers were conducting abrasive Lead paint removal from elevated window structures in excess of 10 feet above ground level.  While in the lift, neither worker used a lanyard to secure themselves against a fall to the ground below. The employer did not have a program to conduct and document frequent and regular inspections of their worksites to ensure that workers were protected from falls.