OSHA Inspection: MARSH LABEL TECHNOLOGIES, L.L.C.

Issued

2024-08-22 00:00:00

Penalty

Initial $8067.00 · Current $4840.00 Reduced

General-duty citation text

29 CFR  1910.132(d)(1): The employer had not assessed the workplace to determine if hazards had been present, or would have likely been present, which would have necessitated the use of personal protective equipment (PPE).  On or about May 24, 2024, MARSH LABEL TECHNOLOGIES, L.L.C. did not assess the workplace at 100 Sun Valley Circle in Fenton, Missouri, to determine if hazards were present, or would have likely been present, which necessitated the use of PPE. Employees were exposed to health hazards while changing the propane on a forklift and using chemicals during the label manufacturing process. Such activities necessitated the use of appropriate eye protection and hand protection. The employer did not select the appropriate PPE that would properly fit for each affected employee nor communicated such selection decisions to the affected employees. The assessment would require certification in accordance with the requirements set forth in 29 CFR 1910.132(d)(2). Hazardous chemicals utilized by employees, which necessitated the use of PPE, included but were not limited to the following items:  A) Propyl Acetate, CAS 109-60-4 Necessitates the use of eye protection B) n-Propanol, CAS 71-23-8 Necessitates the use of eye protection C) Isopropanol 10%, CAS 67-63-0 (Isopropyl Alcohol) Necessitates the use of eye protection and hand protection D) Propane, CAS 74-98-6 Necessitates the use of eye protection and hand protection

Issued

2024-08-22 00:00:00

Abate by

2024-09-13 00:00:00

Penalty

Initial $11292.00 · Current $6775.00 Reduced

General-duty citation text

29 CFR  1910.178(l)(2)(ii): Training had not consisted of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, video tape, written material), practical training (demonstrations performed by the trainer and practical exercises performed by the trainee), and evaluation of the operator's performance in the workplace.   On or about May 24, 2024, MARSH LABEL TECHNOLOGIES, L.L.C. did not ensure that each powered industrial truck (PIT) operator was competent to operate PITs safely in a workplace at 100 Sun Valley Circle in Fenton, Missouri, thus exposing employees to struck-by, overhead, and caught-between hazards. At least one employee did not successfully complete formal instruction, practical training, and evaluation to operate a forklift and pallet jacks. At least six employees did not successfully complete formal instruction, practical training, and evaluation to  operate electric pallet jacks. PITs utilized by employees may include but may not be limited to the following:  A) Propane-powered Forklift, Make: Toyota, Model: 8FGCU15, Serial: 50597 B) Electric-powered Pallet Jack, Make: Toyota, Model: 8HBW23, Serial: 51257 C) Electric-powered Pallet Jack, Make: Crown Equipment Corp., Model: 40GPW-4-14, Serial: 7A128157

Issued

2024-08-22 00:00:00

Penalty

Initial $11292.00 · Current $6775.00 Reduced

General-duty citation text

29 CFR  1910.1200(e)(1): The employer had not developed, implemented, and maintained at each workplace, a written hazard communication program which at least described 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 would have been met, and which also would have included the requirements of (i) through (ii) of this subparagraph.  On or about May 24, 2024, MARSH LABEL TECHNOLOGIES, L.L.C. did not develop, implement, and maintain in their workplace, at 100 Sun Valley Circle in Fenton, Missouri, a written hazard communication program which at least described how the criteria specified in paragraphs (f) for labels and other forms of warning, (g) for safety data sheets, and (h) for employee information and training would have been met, thus exposing two employees to health hazards from hazardous chemicals. The employer did not have a list of the hazardous chemicals known to be present as determined by the product identifier that is referenced on the appropriate data sheet. The employer also did not identify the methods they will use to inform employees of the hazards of non-routine tasks, which must be included in the program. Employees were not trained on hazardous chemicals in their work area at the time of their initial assignment. Hazardous chemicals including but not limited to the following items were utilized by employees for operating a forklift and manufacturing labels:  A) Propyl Acetate B) n-Propanol C) Isopropanol 10% D) Propane

Issued

2024-08-22 00:00:00

Penalty

Initial $1613.00 · Current $968.00 Reduced

General-duty citation text

29 CFR  1904.40(a): When an authorized government representative had asked for the records kept under Part 1904, the employer had not provided copies of the records within four (4) business hours.  On or about May 24, 2024, MARSH LABEL TECHNOLOGIES, L.L.C. did provide copies of the records kept under Part 1904 within four (4) business hours from when an OSHA representative asked for the records. OSHA 300 Logs for 2021, 2022, 2023 and 2024 year to date (YTD) as well as the OSHA 300A Forms for 2021, 2022, and 2023 were requested by an OSHA representative. MARSH LABEL TECHNOLOGIES, L.L.C. did not provide records kept under Part 1904 until June 6, 2024. MARSH LABEL TECHNOLOGIES, L.L.C did not provide any OSHA 300A Forms nor the OSHA 300 Logs for 2022 and 2024 YTD.

Issued

2024-08-22 00:00:00

Penalty

Initial $1613.00 · Current $968.00 Reduced

General-duty citation text

29 CFR  1904.41(a)(1)(i): The employer's establishment had 20-249 employees at any time during the previous calendar year, and the establishment had been classified in an industry listed in appendix A to subpart E of this part. The employer must have electronically submitted information from OSHA Form 300A Summary of Work-Related Injuries and Illnesses to OSHA or OSHA's designee. The employer must have submitted the information once a year, no later than March 2, 2024.  On or about May 24, 2024, MARSH LABEL TECHNOLOGIES, L.L.C. had 20-249 employees during the 2023 calendar year and is classified as a manufacturer as listed in Appendix A to Subpart E of this part. MARSH LABEL TECHNOLOGIES, L.L.C. did not electronically submit information from OSHA Form 300A Summary of Work-Related Injuries and Illnesses to OSHA or OSHA's designee by March 2, 2024.