OSHA Inspection: ADVANCED GRAPHITE POWDERS LLC

Issued

Oct 2, 2024

Penalty

Initial $5,531 · Current $2,766 Reduced

General-duty citation text

29 CFR  1910.106(e)(2)(ii)(b)(2): More than 120 gallons of Category 2, 3, or 4 flammable or combustible liquids in containers were located outside of inside storage room(s) or storage cabinet(s):  On or about June 10, 2024, the employer stored approximately 1,083 gallons of Isopropanol 99%, a Category 2 flammable liquid, in containers outside of an inside storage room or cabinet when they kept twenty 54-gallon drums stored in the shipping area.

Issued

Oct 2, 2024

Abate by

Nov 20, 2024

Penalty

Initial $6,452 · Current $3,226 Reduced

General-duty citation text

29 CFR  1910.134(d)(1)(iii): The employer did not identify and evaluate the respiratory hazard(s) in the workplace; including a reasonable estimate of employee exposures to respiratory hazards and identification of the contaminant's chemical state and physical form:  On or about June 10, 2024, the employer failed to identify and evaluate the respiratory hazards in the workplace, including a reasonable estimate of employee exposures to respiratory hazards, when employees on the powder line were exposed to various types of dusts including, but not limited to, calcined petroleum coke, natural graphite, and synthetic graphite. An employee was exposed to PNOR (total dust) that exceeded the PEL while operating the AC Mills on the powder line. No air monitoring or reasonable estimate of employee exposures to respiratory hazards had been completed.

Issued

Oct 2, 2024

Abate by

Jun 6, 2025

Penalty

Initial $6,452 · Current $3,226 Reduced

General-duty citation text

29 CFR  1910.1000(a)(2): Employee(s) were exposed to an airborne concentration of total dust  listed in Table Z-1 in excess of the 8 hour Time Weighted Average concentration of 15 mg/m3:  Employee exposures to particulates not otherwise regulated (PNOR) total dust exceeded the Permissible Exposure Limit (PEL) of 15.00 mg/m3 listed in Table Z-1 for instances such as, but not limited to:  a.) On or about June 10 2024, an employee was exposed to PNOR (total dust) that exceeded the PEL while operating the AC Mills on the powder line. The employee was exposed to an 8-hour time weighted average (TWA) of 19.269 mg/m3 for particulates not otherwise regulated total dust, approximately 1.29 times the Permissible Exposure Limit (PEL) of 15.0 mg/m3. The exposure level was derived from samples collected over a 369 minute sampling period, with zero exposure assumed for the unsampled period of 111 minutes.

Issued

Oct 2, 2024

Abate by

Jun 6, 2025

Penalty

Initial $0 · Current $0

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):   Feasible administrative or engineering controls were not determined and implemented to comply with 29 CFR 1910.1000(a) and assure that employee exposure to particulate not otherwise regulated (PNOR_ total dust was below the permissible exposure limit. Employees with exposure in excess of the permissible exposure limit (PEL) included the following instances:  a.) On or about June 10 2024, an employee was exposed to PNOR (total dust) that exceeded the PEL while operating the AC Mills on the powder line. The employee was exposed to an 8-hour time weighted average (TWA) of 19.269 mg/m3 for particulates not otherwise regulated total dust, approximately 1.29 times the Permissible Exposure Limit (PEL) of 15.0 mg/m3. The exposure level was derived from samples collected over a 369 minute sampling period, with zero exposure assumed for the unsampled period of 111 minutes.  Controls usually applicable in these circumstances include but are not limited to:  1. Local ventilation effectively installed during loading and unloading of the mills.  Step 1: Submit to the Area Director a written detailed plan of abatement outlining a schedule for the implementation of engineering and/or administrative measure to control employee exposure to air contaminants as referenced in this citation. This plan shall include, at a minimum, target dates for the following actions which must be consistent with the dates required by this citation:  1. Evaluation of engineering control options  2. Selection of optimum control method and completion of design  3. Procurement, installation, and operation of selected control measures  4. Testing and acceptance or modification/redesign of controls  Step 2: All proposed control measures shall be evaluated for each particular use by a competent industrial hygienist or other technically qualified person. Proposed control measures selected should be appropriate to the type of material present. Thirty day progress reports are required during the abatement period. Abatement must be completed by 90 days.  Step 3: Abatement should be completed by the implementation of feasible engineering.

Issued

Oct 2, 2024

Abate by

Nov 20, 2024

Penalty

Initial $6,452 · Current $3,226 Reduced

General-duty citation text

29 CFR  1910.1200(g)(2)(xi): The chemical manufacturer or importer preparing the safety data sheet did not ensure that it included Section 11, Toxicological information:  On or about June 10, 2024, the employer prepared safety data sheets for materials including, but not limited to, Natural Graphite, Synthetic Graphite, Calcined Petroleum Coke, Calcined Pitch Coke, Natural & Synthetic Graphite Blend, Graphene, Carbon Black, Carbon Fiber, Expandable Graphite, and Bio Coal (Charcoal). The employer did not ensure that the safety data sheets included the associated information in Section 11, Toxicological information.

Issued

Oct 2, 2024

Abate by

Nov 20, 2024

Penalty

Initial $12,905 · Current $6,453 Reduced

General-duty citation text

29 CFR  1910.1200(g)(5): The chemical manufacturer, importer or employer preparing the safety data sheet did not ensure that the information provided accurately reflects the scientific evidence used in making the hazard classification:  On or about June 10, 2024, the employer failed to ensure that the information provided in the safety data sheet for Natural Graphite, Synthetic Graphite, Calcined Petroleum Coke, Calcined Pitch Coke, Natural & Synthetic Graphite Blend, Graphene, Carbon Black, Carbon Fiber, and Expandable Graphite reflects the scientific evidence used in making the the hazard classification when they were each stated to be "not classified as "hazardous" under the Globally Harmonized System of Classification and Labeling nor the US OSHA Hazard Communication Standard."  GES-AGP dba Advanced Graphite Powders was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.1200(g)(5), which was contained in OSHA inspection number 1600917, citation number 1  item number 2 and was affirmed as a final order December 19, 2022 on  with respect to a workplace located at 12900 Snow Road, Parma, Ohio 44130.

Issued

Oct 2, 2024

Penalty

Initial $12,905 · Current $6,453 Reduced

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:  On or about June 10, 2024, the employer failed to provide effective information and training on hazardous chemicals in the work area when employees exposed to chemicals including, but not limited to, Natural Graphite, Synthetic Graphite, Calcined Petroleum Coke, Calcined Pitch Coke, Natural & Synthetic Graphite Blend, Graphene, Carbon Black, Carbon Fiber, Expandable Graphite, and Bio Coal (Charcoal) on the powder line were not provided hazard communication training.   GES-AGP dba Advanced Graphite Powders was previously cited for a violation of this occupational safety and health standard or its equivalent standard 1910.1200(h)(1) which was contained in OSHA inspection number 1600917, citation number 1, item number 3 and was affirmed as a final order on December 19, 2022, with respect to a workplace located at 12900 Snow Road, Parma, Ohio 44130.

Issued

Oct 2, 2024

Abate by

Oct 29, 2024

Penalty

Initial $259 · Current $128 Reduced

General-duty citation text

29 CFR  1910.134(k)(6): The employer did not provide the basic advisory information on respirators, as presented in Appendix D of 29 CFR 1910.134, in written or oral format to employees who wear respirators when such use was not required by the employer:  On or about June 10, 2024, the employer failed to provide the basic advisory information on respirators, as present in Appendix D of 29 CFR 1910.134, to employees on the powder line who wear N 95 dust masks on a voluntary basis while working on the rebaggers, mills, or screeners. Employees are exposed to chemicals including, but not limited to, Natural Graphite, Synthetic Graphite, Calcined Petroleum Coke, Calcined Pitch Coke, Natural & Synthetic Graphite Blend, Graphene, Carbon Black, Carbon Fiber, Bio Coal (Charcoal), and Expandable Graphite dusts.   GES-AGP dba Advanced Graphite Powders was previously cited for a violation of this occupational safety and health standard or its equivalent standard 29 CFR 1910.134(k)(6), which was contained in OSHA inspection number 1600917, citation number 2, item number 1 and was affirmed as a final order on December 19, 2022, with respect to a workplace located at 12900 Snow Road, Parma, Ohio 44130.