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Area Office Interesting Cases The N Co – Joint Health & Safety Arlene Lamont, AAD
N Co 34 Complaint Item Inspection 1. Employees are exposed to heavy metal exposure during and after thermal spray process using "Alcro" spray wire. 2. The employers has not developed or implemented a respiratory protection program. Current policy is a "recommended" procedure. 3. The employer does not ensure a designated employee is responsible to monitor or implement a respiratory protection program.
N Co Complaint Inspection 4. The employer does not provide respiratory fitness test to employees using respirators. 5. The employer does not provide respiratory protection training. 6. Employees have tested positive for excessive levels of exposures to chemicals.
Complaint items Cont. 7. The employer has not ensured or verified supplied air systems provided are monitored or assured grade D breathing air is supplied to employees 8. Supplied air units are located by gasoline powered welder that produce carbon monoxide. 9. Overhead hoist are used beyond there max rated capacity.
Complaint Items Cont. 10. Overhead hoist has a frayed wire rope. 11. Overhead hoist are not inspected daily, monthly, or annually. 12. The employer places lift straps back into service that have been removed from service due to defects. 13. Thermal spray gun used in the above process has high pressure air hoses have radiator hose clamps vice required crimped fittings.
Complaint Items Cont 14. Hoses in the shop and on tool trailers that have been shop made with radiator hose clamps. 15. The employer does not ensure forklifts are inspected. 16. Forklift operators are not trained and certified to operate forklifts. 17. There are no currently licensed drivers to my knowledge.
Complaint Items Cont. 18. Forklifts are not used as per design. Forklifts are used in and outside the shop on damaged parking lot surfaces that could cause lift tip over. 19. Bench grinders in the weld shop have missing or broken shields. 20. The employer does not provide face shields in the weld shop for grinding.
Complaint Items Cont. 21. Angle grinders used in weld shop are not equipped with guards. 22. American Lathe chuck shield was removed by the owner and not replaced. 23. Shelving used for storage in shop and trailer shop are shop made and have not been rated for capacity.
Complaint items Cont 24. Table saw in the carpenter shop has no blade guard. 25. Small orange sandblaster is not equipped with a dead man controller to prevent accidental activation. 26. Electrical panels are blocked by clutter and equipment. 27. Paint and other flammables are not stored properly.
Complaint Items Cont. 28. Trash cans are used for disposal of oily and solvent soaked rags in the weld shop. 29. Electrical cords on hand tools are repaired with tape (magnetic particle yoke in big shop). 30. Equipment is blown off with high pressure air nozzles and no face shields for use. 31. Shops are cluttered with materials.
Complaint Items Cont. 32. Water from parking lot drains into the shop. 33. Water for flushing and hand washing is from our well and is often contaminated by surface water and is not marked "Non potable”. 34. Cheater pipes are used regularly on hand tools.
About N Co Non-union workforce, employs 16 Primary operation is maintaining and conducting OEM repair work to Compressors used in Oil and Gas Support activities “Portable line boring services” NAICS 213112 Established in 1979 incorp. In TX
Inspection Findings/Safety Citations 7 serious violations were cited under safety ½ ton hoist had broken hook latch Exit sign not marked Table saw not guarded Sander not guarded Unguarded Pulley on 2 wire ARC Spray machine Unguarded Vertical belt on 2 wire ARC Spray machine ◦ Compressed air not reduced to 30 psi ◦ Electrical breaker panels blocked ◦ ◦ ◦ 1 Other than serious violation ◦ Extension cord no strain relief
Alcro Spray Wire Process
Alcro Spray Wire Process
Inspection Findings/Prop. Citations 1910. 132(e)(1) – medical evaluation not provided prior to wearing respirator 1910. 134(f)(1) – Failure to conduct fit testing for all employees 1910. 141(b)(1) – potable drinking water not provided ◦ Water tested by 3 rd party had E. Coli and total coliform (well water)
Inspection Findings/Citations Cont. 1910. 1025(d)(2) – Initial determine not conducted for lead exposure ◦ Lead found on all wipe samples ◦ Lead well under Action Level on air sample ◦ Employer stated they did not work with lead products 1910. 1025(l)(1)(i) – employees not informed of Appendices A & B for potential exposure to airborne lead at any level
Inspection Findings/Citations Cont. 1910. 1025(h)(1) – failure to maintain surfaces of lead: ◦ All samples taken except table tops tested hot for lead: Machine shop plastic table top – 102 m g/10 cm 2 Male Bathroom #1 floor - 80 m g/10 cm 2 Female Bathroom floor - 52 m g/10 cm 2 Break Room/lunch floor - 40 m g/10 cm 2 Machine shop metal work bench - 20 m g/10 cm 2 Machine shop floor - 224 m g/10 cm 2
Inspection Findings/Citations Cont. 1910. 1026(c) – Employees were exposed above PEL for chromium (VI) - 5 m g/m 3 ◦ Spray welding Alcro wire, TWA =. 02397 mg/m 3 4. 8 times the PEL of. 005 mg/m 3 1910. 1026(e)(1) – regulated area not established, exposure exceeded PEL 1910. 1026(f)(1)(i) – Engineering Controls & work practices not instituted to maintain exposure below the PEL
Inspection Findings/Citations Cont. 1910. 1026(d)(2)(iv) – ER used the scheduled monitoring option, monitoring exceeded PEL and ER did not perform periodic monitoring every 3 months. 1910. 1026(h)(1) – appropriate PPE not provided for Hexavalent Chromium skin contact ◦ Disposal FR used, medical samples indicated chromium on skin or body hair ◦ Disposable booties fell apart in about 20 mins
Inspection Findings/Citations Cont. 1991. 1026(j)(1)(i) – Surfaces were not maintained free of Chromium (VI) ◦ All samples taken except table tops and female bathroom tested hot for chromium: Machine shop plastic table top – 88 m g/10 cm 2 Male Bathroom #1 floor - 65 m g/10 cm 2 Break Room/lunch floor - 85 m g/10 cm 2 Machine shop metal work bench - 255 m g/10 cm 2 Machine shop floor - 161 m g/10 cm 2
Inspection Findings/Citations Cont. 1991. 1026(k)(1)(i) – medical surveillance not conducted Chromium (VI) ◦ ER main argument, not exposed over 30 days/year ◦ All employees received fit for duty for CDL ◦ Some received a metal screen that was paid for by the employer – basic blood/hair draw Employee medical lab results show (H) levels Nickle Cadmium Chromium Uranium lead
Inspection Findings/Citations Cont. 1991. 1026(l)(2) – employees were not trained effectively on the health hazards of Chromium (VI) or the purpose of medical surveillance
N Co abatement @IC All safety items were abated and completed by the time of the informal conference Medical clearance, fit testing and training was completed for employees for respirators used Water was treated by 3 rd party and was potable 3 rd party air sampling results exceeded PEL for Hexavalent Chrome in Aug 2016 & CA 2013 ◦ ER thought they were in compliance since insurance said they were well below the PEL with the use of Full Face SAR