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

2. M Mfg Co Complaint 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 Co Complaint 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

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

8. Inspection Findings/Citations Cont.
(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
(d)(1)(i) – failure to monitor & determine exposure to formaldehyde

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

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

11. M Mfg
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

12. The T Co – Joint Health & Safety Complaint 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

13. The T Co – Joint Health & Safety Complaint 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

14. 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
Established in 1980 a family owned business

19. 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

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

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

22. 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

23. QUESTIONS?