OSHA Inspection: R.M. LUCAS CO., LLC

Issued

Jun 25, 2025

Abate by

Aug 12, 2025

Penalty

Initial $8,276 · Current $4,140 Reduced

General-duty citation text

29 CFR 1910.132(d)(1): The employer did not assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE):  a.) Production - On or about February 25, 2025, the employer did not adequately assess personal protective equipment required in the facility, including but not limited to respirators, eye protection, safety shoes, cut-resistant and chemical resistant gloves to protect employees from contact with chemicals such as flexseal, calcium carbonate, xylene, toluene, titanium dioxide, aerosil, cyclohexylamine, soy methyl esters, naphtha and sodium hydroxide.

Issued

Jun 25, 2025

Abate by

Aug 12, 2025

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.132(d)(1)(iii): The employer did not identify and evaluate the respiratory hazards in the workplace; this evaluation shall include a reasonable estimate of employee exposure to respiratory hazards.  a.)  Production - On or about February 25, 2025, an employee required to clean 300, 600, and 1000 gallon mixing tanks was exposed to hazardous chemicals including but not limited to flexseal, calcium carbonate, xylene, toluene, titanium dioxide, aerosil, cyclohexylamine, soy methyl esters, naphtha and sodium hydroxide.  The employer failed to identify and evaluate respiratory hazards in the workplace, thereby exposing employees to chemical hazards.

Issued

Jun 25, 2025

Abate by

Aug 12, 2025

Penalty

Initial $8,276 · Current $4,140 Reduced

General-duty citation text

29 CFR 1910.134(c)(1): A written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented for required respirator use:  a.) Tank Cleaning Area - On or about February 25, 2025, the employer did not establish and implement a written respiratory protection program with work-site specific procedures when respirator use was required by the company to protect employees against respiratory irritation from chemicals and chemical compounds including but not limited to flexseal, aerosil, cyclohexylamine, soy methyl esters, naphtha, sodium hydroxide, calcium carbonate, xylene, toluene, and titanium dioxide.  An employee was required to wear a half-mask respirator and cartridges while cleaning 300, 600, and 1000 gallon mixing tanks.   b.) Mixing Room - On or about February 25, 2025, the employer did not establish and implement a written respiratory protection program with work-site specific procedures when respirator use was required by the company to protect employees against respiratory irritation from chemicals and chemical compounds including but not limited to flexseal, calcium carbonate, aerosil, cyclohexylamine, soy methyl esters, naphtha, sodium hydroxide, calcium carbonate, xylene, toluene, and titanium dioxide.  An employee was required to wear a half-mask respirator and cartridges while emptying Kraton G1701, a styrene-ethylene-propylene (SEP) polymer, into a mixer.

Issued

Jun 25, 2025

Abate by

Aug 12, 2025

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee was fit tested or required to use the respirator in the workplace:  a.) Mixing Room - On or about February 25, 2025, employees were required to wear half-mask respirators while mixing chemical products.  However, the employer did not provide medical evaluations to determine each affected employee's ability to use a respirator when respiratory protection was required in the workplace.

Issued

Jun 25, 2025

Abate by

Aug 12, 2025

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(k)(1):The employer did not provide respirator training that would ensure each employee could demonstrate knowledge of items in section (i)-(vii):  a.) Mixing Room - On or about February 25, 2025, the employer did not provide respirator training for each employee required to wear half-mask respirators.  Employees were required to wear respirators when mixing batches of sealants, adhesives, and coatings in the Schold mixers.  b.) Tank Cleaning Area - On or about February 25, 2025, the employer did not provide respirator training for each employee required to wear half-mask respirators.  An employee was required to wear a respirator when entering to clean 300, 600, and 1000 gallon mixing tanks of hazardous chemicals.

Issued

Jun 25, 2025

Abate by

Aug 12, 2025

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(f)(2): Employee(s) using tight-fitting facepiece respirators were not fit tested prior to initial use of the respirator:(a)    a.)  Mixing Room - On or about February 25, 2025, employees provided and required to wear half-mask were not fit tested prior to initial use of the respirator.

Issued

Jun 25, 2025

Abate by

Aug 12, 2025

Penalty

Initial $8,276 · Current $4,145 Reduced

General-duty citation text

29 CFR  1910.146(c)(1): The employer did not evaluate the workplace to determine if any spaces were permit-required confined spaces:  a.) Tank Cleaning Area - On or about February 25, 2025, the employer failed to evaluate spaces in the workplace, including 300 gallon, 600 gallon, and 1000 gallon sealant mixing tanks to determine if they are permit-required confined spaces.  Employees are required to enter the sealant mixing tanks to perform cleaning tasks.

Issued

Jun 25, 2025

Abate by

Aug 12, 2025

Penalty

Initial $8,276 · Current $4,145 Reduced

General-duty citation text

29 CFR  1910.147(c)(1): The employer did not establish a program consisting of an energy control procedure, employee training and periodic inspections to ensure that before any employee performed any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative:  a.) Tube Filling Area - On or about February 25, 2025, employees were required to perform service and maintenance activities, including but not limited to, clearing jams in the Schwerdtel filling machines.  The employer did not have a written lockout/tagout program which included energy control procedures, employee training and periodic inspections of the program.  The employees were thereby exposed to hazards associated with the unexpected energizing or startup of machines and equipment.  b.)  Tube Filling Area - On or about February 25, 2025, employees were required to perform service and maintenance activities, including but not limited to, removing, replacing, and resetting drums in the Schwerdtel drum press machine.  The employer did not have a written lockout/tagout program which included energy control procedures, employee training and periodic inspections of the program.  The employees were thereby exposed to hazards associated with the unexpected energizing or startup of machines and equipment.  c.) Tube Filling Area - On or about February 25, 2025, employees were required to perform service and maintenance activities, including but not limited to, cleaning the Schwerdtel filling machine.  The employer did not have a written lockout/tagout program which included energy control procedures, employee training and periodic inspections of the program.  The employees were thereby exposed to hazards associated with the unexpected energizing or startup of machines and equipment.

Issued

Jun 25, 2025

Abate by

Aug 12, 2025

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.147(c)(7)(i)(A): Authorized employee(s) did not receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation:  a.) Tube Filling Area - On or about February 25, 2025, employees performed service and maintenance activities, including but not limited to, clearing jams on the Schwerdtel filling machines.  The employer failed to provide training to each authorized employee performing service and/or maintenance on the Schwerdtel filling machines to ensure the purpose and function of the energy control program are understood and the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees, thereby exposing employees crush and amputation injuries.  b.)  Tube Filling Area - On or about February 25, 2025, employees performed service and/or maintenance, including but not limited to, opening and replacing drums on the Schwerdtel drum press machines.  The employer failed to provide training to each authorized employee performing service and/or maintenance on the Schwerdtel drum press machines to ensure the purpose and function of the energy control program are understood and the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees, thereby exposing employees crush and amputation injuries.  c.) Tube Filling Area - On or about February 25, 2025, employees performed service and maintenance activities, including but not limited to, cleaning the Schwerdtel filling machines.  The employer failed to provide training to each authorized employee performing service and/or maintenance on the Schwerdtel filling machines to ensure the purpose and function of the energy control program are understood and the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees, thereby exposing employees crush and amputation injuries.

Issued

Jun 25, 2025

Abate by

Aug 12, 2025

Penalty

Initial $8,276 · Current $4,145 Reduced

General-duty citation text

29 CFR 1910.178(l)(1)(i): The employer did not ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph (l):  a.) Mixing Room - On or about February 25, 2025, the employer failed to ensure that employee(s) who operate powered industrial trucks were properly trained, evaluated, and certified to perform the tasks in a safe manner, thereby exposing employees to struck-by hazards.

Issued

Jun 25, 2025

Penalty

Initial $8,276 · Current $4,145 Reduced

General-duty citation text

29 CFR  1910.212(a)(1): One or more methods of machine guarding was not provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks:   a.) Acrylics Area - On or about February 25, 2025, the employer failed to provide effective guarding to protect employees working at or near the pail capper machine,  thereby exposing employees to ingoing nip points, rotating parts, and/or amputation hazards.

Issued

Jun 25, 2025

Penalty

Initial $8,276 · Current $4,140 Reduced

General-duty citation text

29 CFR 1910.1200(e)(1): The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met:  a.)  Tank Cleaning Area - On or about February 25, 2025, the employer failed to develop and implement a workplace hazard communication program to inform employees of hazards associated with chemicals such as but not limited to flexseal, calcium carbonate, xylene, toluene, titanium dioxide, aerosil, cyclohexylamine, soy methyl esters, naphtha and sodium hydroxide.  An employee was exposed to hazardous chemicals while cleaning 300, 600, and 1000 gallon mixing tanks.  b.) Mixing Room - On or about February 25, 2025, the employer failed to develop and implement a workplace hazard communication program to inform employees of hazards associated with chemicals such as but not limited to flexseal, calcium carbonate, xylene, toluene, titanium dioxide, aerosil, cyclohexylamine, soy methyl esters, naphtha and sodium hydroxide.  An employee was exposed to hazardous chemical when required to mix batches of coatings, sealants, and adhesives in the Schold mixers.