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Area Office Interesting Cases

This report highlights workplace safety concerns at M.Mfg.Co. and The T.Co., including formaldehyde exposure, lack of PPE, unsanitary conditions, electrical hazards, and non-compliance with safety regulations. Air sampling results and inspection findings are discussed.

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Area Office Interesting Cases

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  1. Area Office Interesting Cases M Mfg Co - Health The T Co – Joint Health & Safety Arlene Lamont, AAD

  2. M Mfg CoComplaint Inspection • The employer does not ensure that employees working in areas using formaldehyde and Bronopal are provided with ventilation exposing the employees to respiratory illnesses or health effects. • The employer does not ensure that employees working with formaldehyde and Bronopal are provided PPE.

  3. M Mfg CoComplaint Inspection • The formaldehyde dispensing equipment leaks inside the building and is not cleaned up or disposed of. • The employer does not ensure the evacuation system (grey hose and cone) is inspected and operated per manufacturer’s requirements, it is not functioning.

  4. About M Mfg Co • Non-union workforce, employs 22 • Primary operation is custom chemical blending, packaging, production, and shipping • SIC 2841 • Established in 1980 incorp. In TX

  5. Formaldehyde Blending Shop

  6. Inspection Findings/Citations • 1910.132(d)(2) – PPE hazard assessment was not completed or certified • 1910.1048(j)(3) – suitable PPE and training was not provided to perform formaldehyde leak and spill clean up • 1910.1048(c)(1) – overexposure to formaldehyde 0.75 ppm PEL • Exposed to 1.631 ppm (8-hr TWA) • 2.17 times the PEL

  7. Inspection Findings/Citations Cont. • 1910.1048(c)(2) – overexposure to formaldehyde 2 ppm STEL • Exposed to 3.20 ppm (STEL) • 1.59 times the PEL • Exposed to 2.90 ppm (STEL) • 1.45 times the PEL • 1910.1048(d)(1)(i) – failure to monitor & determine exposure to formaldehyde

  8. Inspection Findings/Citations Cont. • 1910.1048(f)(1) – failure to institute engineering/work practice controls to ensure exposures were below the TWA and the STEL • 1910.1048(g)(2)(i) – respiratory protection program was not implemented • 1910.1048(i)(1) – change room not provided • 1910.1048(i)(2) – quick drench shower not operable

  9. Inspection Findings/Citations Cont. • 1910.1048(i)(3) – eyewash not operable • 1910.1048(l)(1)(i) – medical surveillance program not implement when exposed above the action level or STEL • 1910.1048(n)(1) – no training conducted on health hazards of formaldehyde • 1910.1200(e)(1) – list of hazardous chemicals not maintained

  10. M Mfg abatement @IC • All items were abated and completed by the time of the informal conference • Documentation and training records were provided • Engineering Controls were submitted – a lid was placed on the blender, exhaust repaired and exhaust fan ventilation was added to the blender area • Air sampling results by 3rd party showed ND

  11. The T Co – Joint Health & SafetyComplaint inspection • Concrete dust and silica blows all over the yard • Restrooms, break rooms, working area are unsanitary • Electrical outlets and plugs without covers • Electrical panels left open

  12. The T Co – Joint Health & SafetyComplaint inspection Cont. • Employees not trained to operate overhead cranes, cranes not inspected • Employees exposed to fall hazards without safety rails or have damaged rails • Platforms and fixed ladders over 20 feet do not have safety cages or guard rails • Employer not logging injuries on OSHA 300 logs

  13. About T Co • Non-union workforce, employs 130 • Primary operation is the design and manufacture of concrete septic tanks, grease traps, storm cellars, and manholes • NAICS 327390 • Established in 1980 a family owned business

  14. Inspection Findings/Citations • 12 serious violations were cited under safety • Housekeeping • Electrical • No Guard rails • Ladder deficiencies • Crane bridge not equipped with trolley bumpers • 2 repeat – serious violations • Restrooms were not kept clean/sanitary • Receptacle gang boxes and switches were missing covers

  15. Inspection Findings/Citations • 3 citations issued under the health inspection • 1910.132(d)(2) - PPE hazard assessment was not completed or certified • 1910.134(k) – employees voluntary using N95 filtering face piece respirators were not provided a copy of Appendix D • 1910.1200(f)(5) – hazcom failure to label or mark hazardous chemical or hazard warning

  16. Discussion of air sample results • Heavy Equipment Operator • Respirable dust – 0.189 mg/m3 • Operator Dry Mixer • Respirable dust - 0.127 mg/m3 • Forklift driver • Respirable silica – 0.232 mg/m3 • Calculated PEL – 1.587 mg/m3 • Compared to the new standard this will be 4.64 X the PEL of 50 mg/m3

  17. Discussion of air sample results Cont. • Batch Plant Operator • Respirable dust – 0.22 mg/m3 • Quality • Respirable Silica – 3.24 mg/m3 • Calculated PEL 3.23 mg/m3 • Compared to the new standard this will be 64.8 X the PEL of 50 mg/m3

  18. QUESTIONS?

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