OSHA has proposed penalties of $1,326,367 to a metal heat treatment company after the company exposed employees to atmospheric, thermal, electrical, and mechanical hazards as they performed maintenance inside heat-treating furnaces. In addition to the penalties, OSHA placed the company in the Severe Violator Enforcement Program. OSHA cited the company for 25 willful, serious, and other-than-serious violations for hazards related to permit-required confined spaces, falls, machine guarding, respiratory protection, chemical exposures, emergency response, and electrical equipment. The company also failed to provide adequate personal protective equipment, and train their employees on hazards in the facility.
Here is a break down of the citations:
Citation 2 Item 1
Type of Violation: Serious; $11,934
29 CFR 1910.28(b)(1)(i): The employer did not ensure that each employee on a walking-working surface with an unprotected side or edge that was 4 feet (1.2 m) or more above a lower level was protected from falling by one or more of the following: Guardrail systems, safety net systems, or personal fall arrest systems
A) On or about October 1, 2018, the employer did not ensure that employees were protected from fall hazards while walking and working on the platform located in the LS Area. Employees conducted activities such as checking thermocouple. Employees were not protected by methods such as, but not limited to, guardrails or safety net systems or by personal fall arrest systems. Employees were exposed to fall hazards of approximately 7 feet from the platform to the floor below.
B) On or about October 18, 2018, the employer did not ensure that employees were protected from fall hazards while walking and working on the platform located in the LS Area. Employees conducted activities such as checking and adding salt to the chemical baths. Employees were not protected by methods such as, but not limited to, guardrails, safety net systems or by personal fall arrest systems. Employees were exposed to fall hazards of approximately 7 feet from the platform to the floor below.
C) On or about October 17, 2018, the employer did not ensure that employees were protected from fall hazards while walking and working on top of the heat treating furnace# 5 (Type TFC-80-ERT-QSQ; Serial # 025430) located in the CRT Area. Employees conducted activities such as replacing the fan shaft. Employees were not protected by methods such as, but not limited to, guardrails or safety net systems or by personal fall arrest systems. Employees were exposed to fall hazards of approximately 7 feet from the top of the furnace to the floor below.
D) On or about October 18, 2018, the employer did not ensure that employees ·were protected from fall hazards while walking and working on top of the heat treating furnace# 23 (Type TFC-80-ERT; Serial # DKD-FN000760) located in the CRT Area. Employees conducted activities such as replacing the fan shaft. Employees were not protected by methods such as, but not limited to, guardrails or safety net systems or by personal fall arrest systems. Employees were exposed to fall hazards of approximately 7 feet from the top of the furnace to the floor below.
Citation 2 Item 2
Type of Violation: Serious; $8,525
29 CFR 1910.146(c)(2): The employer did not inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces:
A) On or about October 19, 2018, the employer did not inform exposed employees, either by posting danger signs or other equally effective means, of the existence and location of and the danger posed by permit spaces such as, but not limited to, the heating chamber of the heat treating furnace # 23 (Type TFC-80-ERT; Serial # DKD-FN000760) located in the CHT Area. Employees were exposed to atmospheric, mechanical, thermal and engulfment hazards.
Citation 2 Item 3
Type of Violation: Serious; $11,934
29 CFR 1910.146(d)(3)(i): Under the permit-required confined space program required by 29 CPR 1910.146(c)(4), the employer did not develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including specifying acceptable entry conditions:
A) On or about September 25, 2018, the employer did not specify the acceptable and safe entry condition for employees assigned to enter permit spaces, such as the heat treating furnace # 10 (Type TFC-80-ERT) located in the CRT Area. Employees conducting maintenance work inside the furnaces were exposed to atmospheric, mechanical, thermal and engulfment hazards.
B) On or about September 26, 2018, the employer did not specify the acceptable and safe entry condition for employees assigned to enter permit spaces, such as the heat treating furnace # 10 (Type TFC-80-ERT) located in the CHT Area. Employees conducting maintenance work inside the furnaces were exposed to atmospheric, mechanical, thermal and engulfment hazards.
C) On or about October 15, 2018, the employer did not specify the acceptable and safe entry condition for employees assigned to enter permit spaces, such as the heat treating furnace # 8 (Type THN(TFC)-80-ERT; Serial # 031560) located in the CHT Area. Employees conducting maintenance work inside the furnaces were exposed to atmospheric, mechanical, thermal and engulfment hazards.
D) On or about October 15, 2018., the employer did not specify the acceptable and safe entry condition for employees assigned to enter permit spaces, such as the heat treating furnace# 1 (Type THN-80-HR; Serial# 025480) located in the CHT Area. Employees conducting maintenance work inside the furnaces were exposed to atmospheric, mechanical, thermal and engulfment hazards.
E) On or about October 17, 2018, the employer did not specify the acceptable and safe entry condition for employees assigned to enter permit spaces, such as the heat treating furnace # 5 (Type TFC-80-QSQ; Serial# 025430) located in the CHT Area. Employees conducting maintenance work inside the furnaces were exposed to atmospheric, mechanical, thermal and engulfment hazards.
F) On or about October 19, 2018, the employer did not specify the acceptable and safe entry condition for employees assigned to enter permit spaces, such as the heat treating furnace# 23 (Type TFC-80-ERT; Serial# DKDJFN000760) located in the CRT Area. Employees conducting maintenance work inside the furnaces were exposed to atmospheric, mechanical, thermal and engulfment hazards.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 3 Item 1a
Type of Violation: Willful; $119,338
29 CFR 1910.146(d)(3)(iii): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer does not develop and implement the means, procedures, and practices ·necessary for safe permit space entry operations, including isolating the permit space:
A) the employer does not implement the means, procedures, and practices necessary for isolating permit spaces, such as the heat treating furnace# 10 (Type TFC-80-ERT) located in the CHT Area. Employees conducting maintenance work inside the furnaces are exposed to atmospheric, mechanical, thermal and engulfment hazards.
Citation 3 Item 1b
Type of Violation: Willful
29 CFR 1910.146(d)(3)(iv): Under the permit space program, the employer does not develop and implement the means, procedures, and practices necessary for safe permit entry operations, including, but not limited to, purging, inserting, flushing or ventilation the permit spaces as necessary to eliminate or control atmospheric hazards:
A) the employer does not ensure that atmospheric hazards are eliminated or controlled while employees are working inside the heat treating furnace# 10 (Type TFC-80-ERT) located in the CHI Area.
Citation 3 Item 1c
Type of Violation: Willful
29 CFR 1910.146(d)(4): The employer does not provide the equipment specified in paragraphs (d)(4)(i)-(d)(4)(ix) of this section at no cost to employees, does not maintain that equipment properly, and/or does not ensure that employees use that equipment properly: A) the employer does not provide atmospheric testing and monitoring equipment to employees who enter permit spaces, such as the heat treating furnace # 10 (Type TFC-80-ERT) located in the CHT Area. Employees conducting maintenance work inside the furnaces are exposed to atmospheric hazards.
Citation 3 Item 1d
Type of Violation: Willful
29 CFR 1910.146(d)(5): Permit-required confined space(s) are not evaluated as required under (d)(5)(i) through (d)(5)(vi) of this paragraph when entry operations are conducted:
A) the employer does not perform atmospheric testing and monitoring to evaluate the conditions in the permit spaces, such as the heat treating furnace # 10 (Type TFC-8 0-ERT) located in the CRT Area. Employees entering the furnaces without atmospheric testing and monitoring are exposed to atmospheric hazards.
Citation 3 Item 1e
Type of Violation: Willful
29 CFR 1910.146(e)(1): Before entry is authorized, the employer does not document the completion of measures required by 29 CPR 1910 .146( d)(3) by preparing an entry permit:
A) the employer does not document the completion of the measures required for safe permit space entry. Entry permits are not completed prior to entering into the heat treating furnace # 10 (Type TFC-80-ERT) located in the CHT Area, exposing employees to atmospheric, mechanical, thermal and engulfment hazards.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 3 Item 2a
Type of Violation: Willful; $119,338
29 CFR 1910.146(d)(3)(iii): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer does not develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including isolating the permit space:
A) the employer does not implement the means, procedures, and practices necessary for isolating permit spaces, such as the heat treating furnace # 8 (Type THN(TFC)-80-ERT; Serial# 031560) located in the CHT Area. Employees conducting maintenance work inside the furnaces are exposed to atmospheric, mechanical, thermal and engulfment hazards.
Citation 3 Item 2b
Type of Violation: Willful
29 CFR 1910.146(d)(3)(iv): Under the permit space program, the employer does not develop and implement the means, procedures, and practices necessary for safe permit entry operations, including, but not limited to, purging, inserting, flushing or ventilation the permit spaces as necessary to eliminate or control atmospheric hazards:
A) the employer does not ensure that atmospheric hazards are eliminated or controlled while employees are working inside the heat treating furnace # 8 (Type THN(TFT)-80-ERT; Serial# 031560) located in the CRT Area.
Citation 3 Item 2c
Type of Violation: Willful
29 CFR 1910.146(d)(4): The employer does not provide the equipment specified in paragraphs (d)(4)(i)-(d)(4)(ix) of this section at no cost to employees, does not maintain that equipment properly, and/or does not ensure that employees use that equipment properly:
A) the employer does not provide atmospheric testing and monitoring equipment to employees who enter permit spaces, such as the heat treating furnace# 8 (Type THN(TFC)-80-ERT; Serial # 031560) located in the CRT Area. Employees conducting maintenance work inside the furnaces are exposed to atmospheric hazards. This violation most recently occurred on or about October 15, 2018.
Citation 3 Item 2d
Type of Violation: Willful
29 CFR 1910.146(d)(5): Permit-required confined space(s) are not evaluated as required under (d)(5)(i) through (d)(5)(vi) of this paragraph when entry operations are conducted:
A) the employer does not perform atmospheric testing and monitoring to evaluate the conditions in the permit spaces, such as the heat treating furnace # 8 (Type THN(TFC)-80- ERT; Serial# 031560) located in the CHT Area . Employees entering the furnaces without atmospheric testing and monitoring are exposed to atmospheric hazards.
Citation 3 Item 2e
Type of Violation: Willful
29 CFR 1910.146(e)(1): Before entry is authorized, the employer does not document the completion of measures required by 29 CFR 1910.146(d)(3) by preparing an entry permit:
A) the employer does not document the completion of the measures required for safe permit space entry. Entry permits are not completed prior to entering into the heat treating furnace # 8 (Type THN(TFC)-80-ERT; Serial # 031560) located in the CHT Area, exposing employees to atmospheric, mechanical, thermal and engulfment hazards.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 3 Item 3a
Type of Violation: Willful; $119,338
29 CFR 1910.146(d)(3)(iii): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer does not develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including isolating the permit space:
A) the employer does not implement the means, procedures, and practices necessary for isolating permit. spaces, such as the heat treating furnace# 1 (Type THN-80-HR ; Serial# 025480) located in the CHT Area. Employees conducting maintenance work inside the furnaces are exposed to atmospheric, mechanical, thermal and engulfment hazards.
Citation 3 Item 3b
Type of Violation: Willful
29 CFR 1910.146(d)(3)(iv): Under the permit space program, the employer does not develop and implement the means, procedures, and practices necessary for safe permit entry operations, including, but not limited to, purging, inerting, flushing or ventilation the permit spaces as necessary to eliminate or control atmospheric hazards:
A) the employer does not ensure that atmospheric hazards are eliminated or controlled while employees are working inside the heat treating furnace# 1 (Type THN-80-HR; Serial# 025480) located in the CRT Area.
Citation 3 Item 3c
Type of Violation: Willful
29 CFR 1910.146(d)(4): The employer does not provide the equipment specified in paragraphs (d)(4)(i)-(d)(4)(ix) of this section at no cost to employees, does not maintain that equipment properly, and/or does not ensure that employees use that equipment properly:
A) the employer does not provide atmospheric testing and monitoring equipment to employees who enter permit spaces, such as the heat treating furnace# i (Type THN-80-HR; Serial# 025480) located in the CRT Area. Employees conducting maintenance work inside the furnaces are exposed to atmospheric hazards.
Citation 3 Item 3d
Type of Violation: Willful
29 CFR 1910.146(d)(5): Permit-required confined space(s) are not evaluated as required under (d)(5)(i) through (d)(5)(vi) of this paragraph when entry operations are conducted:
A) the employer does not perform atmospheric testing and monitoring to evaluate the conditions in the permit spaces, such as the heat treating furnace# 1 (Type THN-80-HR ; Serial# 025480) located in the CHT Area. Employees entering the furnaces without atmospheric testing and monitoring are exposed to atmospheric hazards.
Citation 3 Item 3e
Type of Violation: Willful
29 CFR 1910.146(e)(1): Before entry is authorized, the employer does not document the completion of measures required by 29 CFR 1910.146(d)(3) by preparing an entry permit:
A) the employer does not document the completion of the measures required for safe permit space entry. Entry permits are not completed prior to entering into the heat treating furnace # 1 (Type THN-80-HR; Serial # 025480) located in the CRT Area, exposing employees to atmospheric, mechanical, thermal and engulfment hazards.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 3 Item 4a
Type of Violation: Willful; $119,338
29 CFR 1910.146(d)(3)(iii): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer does not develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including isolating the permit space:
A) the employer does not implement the means, procedures, and practices necessary for isolating permit spaces, such as the heat treating furnace# 5 (Type TFC-80-ERT-QSQ; Serial # 0254 30) located in the CHT Area. Employees conducting maintenance work inside the furnaces are exposed to atmospheric, mechanical, thermal and engulfment hazards.
Citation 3 Item 4b
Type of Violation: Willful
29 CFR 1910.146(d)(3)(iv): Under the permit space program, the employer does not develop and implement the means, procedures, and practices necessary for safe permit entry operations, including, but not limited to, purging, inerting, flushing or ventilation the permit spaces as necessary to eliminate or control atmospheric hazards:
A) the employer does not ensure that atmospheric hazards are eliminated or controlled while employees are working inside the heat treating furnace# 5 (Type TFC-80-ERT-QSQ; Serial# 025430) located in the CHT Area.
Citation 3 Item 4c
Type of Violation: Willful
29 CFR 1910.146(d)(4): The employer does not provide the equipment specified in paragraphs (d)(4)(i)-(d)(4)(ix:) of this section at no cost to employees, does not maintain that equipment properly, and/or does not ensure that employees use that equipment properly:
A) the employer does not provide atmospheric testing and monitoring equipment to employees who enter permit spaces, such as the heat treating furnace # 5 (Type TFC-80-ERT-QSQ; Serial # 025430) located in the CHT Area. Employees conducting maintenance work inside the furnaces are exposed to atmospheric hazards.
Citation 3 Item 4d
Type of Violation: Willful
29 CFR 1910.146(d)(5): Permit-required confined space(s) are not evaluated as required under (d)(5)(i) through (d)(5)(vi) of this paragraph when entry operations are conducted:
A) the employer does not perform atmospheric testing and monitoring to evaluate the conditions in the permit spaces, such as the heat treating furnace# 5 (Type TFC-80-ERT-QSQ; Serial# 025430) located in the CHT Area. Employees entering the furnaces without atmospheric testing and monitoring are exposed to atmospheric hazards.
Citation 3 Item 4e
Type of Violation: Willful
29 CFR 1910.146(e)(1): Before entry is authorized, the employer does not document the completion of measures required by 29 CFR 1910.146(d)(3) by preparing an entry permit:
A) the employer does not document the completion of the measures required for safe permit space entry. Entry permits are not completed prior to entering into the heat treating furnace #5 (Type TFC-80-ERTQSQ; Serial # 025430) located in the CHT Area, exposing employees to atmospheric, mechanical, thermal and engulfment hazards.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 3 Item 5a
Type of Violation: Willful; $119,338
29 CFR 1910.146(d)(3)(iii): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer does not develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including isolating the permit space:
A) the employer does not implement the means, procedures, and practices necessary for isolating permit spaces, such as the heat treating furnace# 23 (Type TFC-80-ERT; Serial# DKD-FN000760) located in the CHT Area. Employees conducting maintenance work inside the furnace s are exposed to atmospheric, mechanical, thermal and engulfment hazards.
Citation 3 Item 5b
Type of Violation: Willful
29 CFR 1910.146(d)(3)(iv): Under the permit space program, the employer does not develop and implement the means, procedures, and practices necessary for safe permit entry operations, including, but not limited to, purging, inerting, flushing or ventilation the permit spaces as necessary to eliminate or control atmospheric hazards:
A) the employer does not ensure that atmospheric hazards are eliminated or controlled while employees are working inside the heat treating furnace# 23 (Type TFC-80-ERT; Serial# DKD-FN000760) located in the CRT Area.
Citation 3 Item 5c
Type of Violation: Willful
29 CFR 1910.146(d)(4): The employer does not provide the equipment specified in paragraphs (d)(4)(i)-(d)(4)(ix) of this section at no cost to employees, does not maintain that equipment properly, and/or does not ensure that employees use that equipment properly:
A) the employer does not provide atmospheric testing and monitoring equipment to employees who enter permit spaces, such as the heat treating furnace# 23 (Type TFC -80-ERT; Serial# DKD-FN000760) located in the CHT Area. Employees conducting maintenance work inside the furnaces are exposed to atmospheric hazards.
Citation 3 Item 5d
Type of Violation: Willful
29 CFR 1910.146(d)(5): Permit-required confined space(s) are not evaluated as required under (d)(5)(i) through (d)(5)(vi) of this paragraph when entry operations are conducted:
A) the employer does not perform atmospheric testing and monitoring to evaluate the conditions in the permit spaces, such as the heat treating furnace# 23 (Type TFC-80-ERT; Serial# DKD-FN000760) located in the CHT Area Employees entering the furnaces without atmospheric testing and monitoring are exposed to atmospheric hazards.
Citation 3 Item 5e
Type of Violation: Willful
29 CFR 1910.146(e)(1): Before entry is authorized, the employer does not document the completion of measures required· by 29 CFR 1910 .146( d)(3) by preparing an entry permit:
A) the employer does not document the completion of the measures required for safe permit space entry. Entry permits are not completed prior to entering into the heat treating furnace # 23 (Type TFC-80-ERT; Serial # DKD-FN000760) located in the CHT Area, exposing employees to atmospheric, mechanical, thermal and engulfment hazards.
Citation 3 Item 6
Type of Violation: Willful; $119,338
29 CFR 1910 .146(d)(6): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer does not provide at least one attendant outside the permit space into which entry is authorized for the duration of entry operations:
A) the employer does not ensure that at least one attendant is outside the permit spaces for the duration of the entry into equipment such as, but not limited to, the heat treating furnace # 10 (Type TFC-80-ERT) located in the CHT Area. The entrants are exposed to atmospheric, mechanical, thermal and engulfment hazards.
B) the employer does not ensure that at least one attendant is outside the permit spaces for the duration of the entry into equipment such as, but not limited to, the heat treating furnace # 8 (Type THN (TFC)-80- ERT; Serial # 0315 60) located in the CHT Area. The entrants are exposed to atmospheric, mechanical, thermal and engulfment hazards.
C) the employer does not ensure that at least one attendant is outside the permit spaces for the duration of the entry into equipment such as, but not limited to, the heat treating furnace # 1 (Type THN-80-HR; Serial# 025480) located in the CHT Area. The entrants are exposed to atmospheric, mechanical, thermal and engulfment hazards.
D) the employer does not ensure that at least one attendant is outside the permit spaces for the duration of the entry into equipment such as, but not limited to, the heat treating furnace # 5 (Type TFC-80-ERT-QSQ; Serial# 025430) located in the CHT Area. The entrants are exposed to atmospheric, mechanical, thermal and engulfment hazards.
E) the employer does not ensure that at least one attendant is outside the permit spaces for the duration of the entry into equipment such as, but not limited to, the heat treating furnace # 23 (Type TFC-80-ERT; Serial# DKD-FN000760) located in the CHT Area. The entrants are exposed to atmospheric, mechanical, thermal and engulfment hazards.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 3 Item 7a
Type of Violation: Willful; $119,338
29 CFR 1910.146(g)(1): The employer does not provide training so that all employees whose work is regulated by 29 CPR 1910.146 (permit required confined spaces) acquire the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under 29 CFR 1910.146:
A) the employer does not provide adequate permit space training to employees who are required to perform work in multiple heat treating furnaces located in the CHT Area. Employees conducting maintenance work inside the furnaces are exposed to atmospheric, mechanical, thermal and engulfment hazards.
Citation 3 Item 7b
Type of Violation: Willful
29 CFR 1910.147(c)(7)(i)(A): Authorized employee(s) do 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) the employer ‘does not adequately train employees to lockout/tag-out equipment such as, but not limited to, heat treating furnaces located in the CHT Area. Employees do not control all hazardous energy sources such as, but not limited to, electrical, gravitational, and combustible gases before conducting maintenance activities such as, but not limited to, unjamming the product from the furnaces, repairing brick inside the furnaces, and replacing fan shafts. Employees are exposed to atmospheric, mechanical, electrical and thermal hazards while all hazardous energy sources are not controlled prior to conducting work.
Citation 3 Item 8
Type of Violation Willful; $119,338
29 CFR 1910.147(c)(4)(i): Procedures are not developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in activities covered by this section:
A) the employer does not develop, implement, and utilize specific procedures to control hazardous energy of the heat treating furnace # 10 (Type TFC-80-ERT) located in the CHT Area. Employees do not control all hazardous energy sources before conducting maintenance activities such as, but not limited to, removing bricks from the furnace. Employees are exposed to atmospheric, mechanical, electrical and thermal hazards while all hazardous energy sources are not controlled prior to conducting work.
B) the employer does not develop, implement, and utilize specific procedures to control hazardous energy of the heat treating furnace # 10 (Type TFC-80-ERT) located in the CRT Area. Employees do not control all hazardous energy sources before conducting maintenance activities such as, but not limited to; repairing the brick wall inside the furnace. Employees are exposed to atmospheric, mechanical, electrical and thermal hazards while all hazardous energy sources are not controlled prior to conducting work.
C) the employer does not develop, implement, and utilize specific procedures to control hazardous energy of the heat treating furnace # 8 (Type THN(TFC) -80-ERT; Serial# 031560) located in the CHT Area. Employees do not control all hazardous energy sources before conducting maintenance activities such as, but not limited to, conducting inspections and cleaning out parts that fall off inside the furnace. Employees are exposed to atmospheric, mechanical, electrical and thermal hazards while all hazardous energy sources are not controlled prior to conducting work.
D) the employer ·does not develop, implement, and utilize specific procedures to control hazardous energy of the heat treating furnace# 1 (Type THN-80-HR; Serial# 025480) located in the CHT Area. Employees do not control all hazardous _energy sources before conducting maintenance activities such as, but not limited to, removing bricks that fall off inside the furnace. Employees are exposed to atmospheric, mechanical, electrical and thermal hazards while all hazardous energy sources are not controlled prior to conducting work.
E) the employer does not develop, implement, and utilize specific procedures to control hazardous energy of the heat treating furnace# 5 (Type TFC-80-ERT-QSQ; Serial# 025430) located in the CRT Area. Employees do not control all hazardous energy sources before conducting maintenance activities such as, but not limited to, conducting inspections and replacing the fan shaft. Employees are exposed to atmospheric, mechanical, electrical and thermal hazards while all hazardous energy sources are not controlled prior to conducting work.
F) the employer does not develop, implement, and utilize specific procedures to control hazardous energy of the heat treating furnace _# 23 (Type TFC-80-ERT; Serial# DKD-FN00076q) located in the CRT Area. Employees do not control all hazardous energy sources before conducting maintenance activities such as, but not limited to, replacing the fan shaft. Employees are exposed to atmospheric, mechanical, electrical and thermal hazards while all hazardous energy sources are not controlled prior to conducting work.
Citation 3 Item 9
Type of Violation: Willful; $119,338
29 CFR 1910.332(6)(1): Employees are not trained in and familiar with the safety-related work practices required by 1910.331 through 1910.335 that pertained to their respective job assignments:
A) the employer does not ensure that employees are provided with adequate training on electrical safety-related work practices such as, but not limited to, the use of personal protective equipment for the hands, heat, and body to protect against electrical hazards. Employees, working on or near energized or potentially energized electrical parts, are exposed to 480 volts.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 3 Item 10a
Type of Violation: Willful; $119,338
29 CFR 1910.333(a): Safety-related work practices are not employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts, when work is performed near or on equipment or circuits which are or can be energized:
A) the employer does not ensure that employees use safe electrical work practices in order to be protected from electrical hazards such as, but not limited to, electric shock and arc flash. Employees are exposed to 480 volts while replacing the fan shaft of the heat treating furnace # 5 (Type TFC-80-ERT-QSQ; Serial# 025430) located in the CHT Area.
B) the employer does not ensure .that employees use safe electrical work practices in order to be protected from electrical hazards such as, but not limited to, electric shock and arc flash. Employees are exposed to 480 volts while replacing the fan shaft of the heat treating furnace# 23 (Type TFC-80-ERT; Serial # DKD-FN000760) located in the CHT Area.
Citation 3 Item 10b
Type of Violation: Willful
29 CFR 1910.335(a)(1)(i): Employees working in areas where there ·are potential electrical hazards are not provided with electrical protective equipment that is appropriate for the specific parts of the body that need to be protected and for the work being performed:
A) the employer does not ensure that employees, conducting electrical work in the facility, are using proper electrical personal protective equipment for the hands, head, and body. Employees are exposed to 480 volts while replacing the fan shaft of the heat treating furnace # 5 (Type TFC-80-ERT-QSQ; Serial # 025430) located in the CRT Area.
B) the employer does not ensure that employees, conducting electrical work in the facility, are using proper electrical personal protective equipment for the hands, head, and body. Employees are exposed to 480 volts while replacing the fan shaft of the heat treating furnace# 23 (Type TFC-80-ERT; Serial # DKD-FN000760) located in the CHT Area.
Citation 2 Item 1
Type of Violation: Serious; $8,525
29 CFR 1910.28(b)(3)(v)(A): Each employee was not protected from falling through a hatchway and chute floor hole by a hinged floor-hole cover that meets the criteria in 1910.29 and a fixed guardrail system that leaves only one exposed side.
a. the employer did not ensure employees shoveling potassium thiocyanate powder into the salt tanks, were protected from falling into the three foot by two foot floor hole when the floor hole covering was removed.
Citation 2 Item 2
Type of Violation: Serious; $8,525
29 CFR 1910.106(e)(2)(ii)(b)(2): The quantity of liquid that may be located outside of an inside storage room or storage cabinet in a building or in any one fire area of a building exceeded 120 gallons of Category 2, 3, or 4 flammable liquids in containers.
a. On or about November 13, 2018, the employer did not ensure three 55 gallon drums of a category 3 flammable liquid, Daphine Oil Coat RL 55-NB, located adjacent to the oil dipping machine were stored in a properly constructed flammable liquid storage room or flammable liquid storage cabinet.
Citation 2 Item 3
Type of Violation: Serious; $8,525
29 CFR 1910.106(e)(6)(ii): Category 1 or 2 flammable liquids, or Category 3 flammable liquids with a flashpoint below 100 degrees F (37.8 degrees C), were dispensed into containers when the nozzle and container were not electrically interconnected.
a. the employer did not ensure a 55-gallon drum of a category 3 flammable liquid, Daphine Oil Coat RL 55- NB, located adjacent to the oil dipping machine in the repack area, was properly grounded as it was being dispensed into the equipment.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 2 Item 4a
Type of Violation: Serious; $8,525
29 CFR 1910.120(q)(1): An emergency response plan was not developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations. The plan was not in writing and available for inspection and copying by employees, their representatives and OSHA personnel.
a. the employer did not ensure an emergency response plan was developed and implemented to cover employees responsible for responding to chemical releases such as anhydrous ammonia from the onsite piping and storage tank; and sodium bisulfate, potassium hydroxide, and potassium thiocyanate releases from the LS dipping and coating line.
Citation 2 Item 4b
Type of Violation: Serious
29 CFR 1910.120(q)(6): Training was not based on the duties and function to be performed by each responder of an emergency response organization. The skill and knowledge levels required for all new responders, those hired after the effective date of this standard, were not conveyed to them through training before they are permitted to take part in actual emergency operations on an incident.
Employees who participate, or are expected to participate, in emergency response, were not given training in accordance with the following paragraphs. a. the employer did not ensure employees were provided with proper training on how to respond to a hazardous materials release such as anhydrous ammonia from the onsite piping and storage tank; and sodium bisulfate, potassium hydroxide, and potassium thiocyanate releases from the LS dipping and coating line.
Citation 2 Item 5
Type of Violation: Serious; $8,525
29 CFR 1910.124(f): The employer did not ensure employees were knowledgeable of the first-aid procedures that are appropriate to the dipping or coating hazards to which they are exposed.
a. the employer did not ensure employees working on the LS dipping and coating line were train ed on the first aid procedures associated with corrosive potassium hydroxide, potassium thiocyanate, and sodium bisulfate chemical contact to the eyes, face, and skin.
Citation 2 Item 6
Type of Violation: Serious; $8,525
29 CFR 1910.124(g)(2): An emergency shower and eye-wash station was not located close to the dipping or coating operation.
a. the employer did not ensure a working emergency eyewash and shower located on the LS dipping and coating line platform was operational. Employees were exposed to chemical splashes from substances such as potassium thiocyanate, sodium bisulfate, and potassium hydroxide when making chemical additions and taking chemical samples from the process tanks.
Citation 2 Item 7
Type of Violation: Serious; $8,525
29 CFR 1910.124(h)(3): When employees work with liquids that may burn, irritate, or otherwise harm their skin the employer did not provide appropriate first-aid supplies that were located near the dipping or coating operation.
a. the employer did not provide appropriate first aid supplies near the LS dipping and coating line to treat chemical bums caused by exposure, to corrosives such as potassium hydroxide, sodium bisulfite, and potassium thiocyanate.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 2 Item 8a
Type of Violation: Serious; $8,525
29 CFR 1910.132(a): Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, was not provided, used, and maintained in a sanitary and reliable condition wherever it was necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.
a. the employer did not ensure employees were provided with protective equipment for the arms and torso when making chemical additions and taking samples from the tanks on the LS dipping and coating line. Employees were exposed to substances such as potassium thiocyanate, sodium bisulfite, and potassium hydroxide which can cause severe skin burns.
Citation 2 Item 8b
Type of Violation: Serious
29 CFR 1910.132(d)(1): The employer did not assess the workplace to determine if hazards were present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).
a. the employer did not perform a protective equipment assessment of the LS dipping and coating line. Employees were exposed to potassium hydroxide and sodium sulfite splash hazards to the face and were not provided with face shields when making chemical additions and taking samples from the process tanks.
Citation 2 Item 8c
Type of Violation: Serious
29 CFR 1910.132(f)(1): The employer did not provide training to each employee who is required by this section to use PPE.
a. the employer did not ensure employees were provided with information and training on the face shields needed to be worn when working on the LS dipping and coating line. Employees are exposed to substances such as sodium bisulfite and potassium hydroxide when making chemical additions and taking chemical samples from the process tanks. Protective equipment training did not include the following topics:
1. When PPE is necessary;
2. What PPE is necessary;
3. How to properly don, doff, adjust, and wear PPE;
4. The limitations of the PPE;
5. The proper care, maintenance, useful life and disposal of the PPE.
Citation 2 Item 8d
Type of Violation: Serious
29 CFR 1910.133(a)(1): The employer did not ensure that each affected employee used appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.
a. the employer did not ensure employees were provided with protective equipment for the face when making chemical additions and taking samples from the tanks on the LS dipping and coating line. Employees were exposed to substances such as sodium bisulfite and potassium hydroxide which can cause severe skin and eye burns.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 2 Item 9a
Type of Violation: Serious; $10,229
29 CFR 1910.147(c)(7)(i): The employer did not provide training to ensure that the purpose and function of the energy control program was understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees.
a. the employer did not ensure employees unjamming the #1 and #2 clutch guide machines, located in the heat treat department, were provided with training on the company’s lockout program regarding the following:
1. Recognition of applicable hazardous energy sources;
2. The type and magnitude of the energy available in the workplace;
3. The methods and means necessary for energy isolation and control.
Citation 2 Item 9b
Type of Violation: Serious
29 CFR 1910.147(d): The established procedures for the application of energy control (the lockout or tagout procedures) did not cover the following elements and actions and were not done in the following sequence.
a. the employer did not ensure employees locked out the equipment on the # 1 clutch guide loading conveyor prior to unjamming parts between the pneumatic conveyor end pushers and the pneumatic parts elevator, exposing employees to shear point hazards and pinch point hazards when performing the unjamming activities.
b. the employer did not ensure employees locked out the pneumatic exit door on the #2 clutch guide last cabinet prior to unjamming parts from the opening, exposing employees to pinch point hazards when performing the unjamming activities.
c. the employer did not ensure employees locked out the pneumatic exit and entry doors on the #2 clutch guide blast cabinet prior to using small tools to activate the proximity sensors, exposing the employees to pinch point hazards when performing the work.
Citation 2 Item 10
Type of Violation: Serious; $10,229
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. the employer did not ensure the LS dipping and coating line transfer car which moves parts racks from the loading area to the potassium hydroxide tank on the LS dipping and coating line, was properly guarded. The chain link fence gate accessing the transfer car was not interlocked to prevent movement the car when employees opened the gate to access the fixed ladder leading to the LS dipping and coating line platform.
b. the employer did not ensure employees operating the #2 clutch guide blasting machine, located in the heat treat department, were protected from pinch point hazards created by the pneumatically operated entry door.
c. the employer did not ensure employees operating the #1 clutch guide loading conveyor, located in the heat treat department, were protected from pinch point hazards and shear point hazards created by the pneumatic pusher mechanism on the end of the inclined conveyors.
The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.
Citation 2 Item 11a
Type of Violation; Serious; $8,525
29 CFR 1910.1200(e)(1): The employer did not develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, safety data sheets, and employee information and training would be met.
a. the employer did not ensure a written hazard communication program was developed and implemented which covered employees exposed to substances-such but not limited to anhydrous ammonia, hydrochloric acid, potassium thiocyanate, sodium bisulfite, and potassium hydroxide when working in the heat treat department and on the LS dipping and coating line.
Citation 2 Item 11b
Type of Violation: Serious
29 CFR 1910.1200(f)(6): The employer did not ensure that each container of hazardous chemicals in the workplace was labeled, tagged or marked.
a. the employer did not ensure the dipping and coating tanks located on the LS dipping and coating line were labeled with information regarding the physical and health hazards of the hazardous chemicals. Employees were exposed to substances such but not limited to potassium thiocyanate, sodium bisulfite, and potassium hydroxide.
Citation 2 Item 11c
Type of Violation: Serious
29 CFR 1910.1200(h)(1): The employer did not provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about was introduced into their work area.
a. the employer did not ensure employees exposed to substances such but not limited to anhydrous ammonia, hydrochloric acid, potassium thiocyanate, sodium bisulfite, and potassium hydroxide when working in the heat treat department and on the LS dipping and coating line, were provided with information and training on the physical and health hazards of the substances.
Citation 1 Item 1
Type of Violation: Repeat; $3,411 (Corrected During Inspection)
29 CFR 1904.41(a)(2): 29 CFR 1904.41(a)(2): Annual electronic submission of part 1904 records by establishments with 20 or more employees, but less than 250 employees. The establishment had 20 or more employees at some time during the previous calendar year, and this part required the establishment to keep records, but the employer did not electronically submit information from OSHA Fo1m 300A Summary of Work-Related Injuries and Illnesses to OSHA or OSHA’s designee. The employer did not submit the information once a year, no later than the date listed in paragraph (c) of this section of the year after the calendar year covered by the form:
the employer did not electronically submit injury and illness records for the calendar year 2018; the OSHA Form 300A or equivalent was not submitted by 03/02/2019.
a) The establishment employed approximately 110 employees and is classified NAICS 332811 during the calendar year 2018. The business was previously cited for a violation of this Occupational Safety and Health Standard (29 CFR 1904.41(a)(2)), which was contained in OSHA Inspection # 1354512 , Citation number 1, Item number 1, and was affirmed as a final order on O 1/07/2 019, with respect to a workplace located in Bowling Green, OH 43402.