OSHA Inspection: ROBERTSON MANUFACTURING, INC.

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $918.00 · Current $918.00

General-duty citation text

29 CFR 1910.106(d)(3)(ii):     "Fire resistance." Storage cabinets were not designed and constructed to limit the internal temperature to not more than 325 deg. F. when subjected to a 10-minute fire test using the standard time-temperature curve as set forth in Standard Methods of Fire Tests of Building Construction and Materials, NFPA 251-1969, which is incorporated by reference as specified in Sec. 1910.6. All joints and seams shall remain tight and the door shall remain securely closed during the fire test. Cabinets shall be labeled in conspicuous lettering, "Flammable - Keep Fire Away."    a. First Floor, Shipping and Receiving - The employer did not mark a flammable liquids storage cabinet with the conspicuous lettering, Flammable  Keep Fire Away.   The employer stored several flammable liquids inside this metal storage cabinet.  Some of these flammable liquids were:  approximately fifteen 32 oz. (948 liter) containers of HH-66 Vinyl Cement, two 1 gallon containers of S-L-X Denatured Alcohol, seven containers of Marsh Spray Stencil Ink, and two containers of 3M Foam Fast 74 (Orange) Spray Adhesive.  Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.106(d)(3)(ii)(a):     Metal cabinets constructed in the following manner were not deemed to be in compliance. The bottom, top, door, and sides of cabinet were not at least No. 18 gage sheet iron and double walled with 1 1/2 - inch air space. Joints were not riveted, welded or made tight by some equally effective means. The door was not provided with a three-point lock, and the door sill was not raised at least 2 inches above the bottom of the cabinet.    a. First Floor, Shipping and Receiving - The employer did not provide the door of the flammable liquids storage cabinet with a three point latch arrangement.  The employer stored several flammable liquids inside a metal storage cabinet.  Some of these flammable liquids were: approximately 15 32 oz (948 liter) containers of HH-66 Vinyl Cement, two 1 gallon containers of S-L-X Denatured Alcohol, seven containers of Marsh Spray Stencil Ink, and two containers of 3M Foam Fast 74 (Orange) Spray Adhesive.    A three point latching system ensures that the door or doors will close tightly, securing liquids safely inside. Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $918.00 · Current $918.00

General-duty citation text

29 CFR 1910.107(b)(1):     Construction. Spray booths were not substantially constructed of steel, securely and rigidly supported, or of concrete or masonry except that aluminum or other substantial noncombustible material may be used for intermittent or low volume spraying. Spray booths shall be designed to sweep air currents toward the exhaust outlet.      a. Outdoor Shed - The employer did not design and construct the spray booth in accordance with the standard.  An employee sprayed Hentzen Coatings Tan 686A, 33446 VHF 1.5 VOC Zenthane (MIL-DTL-53039C, Type II, 08609TUZ-LVOC-1) onto blackout frames and sight protections.  According to the material safety data sheet for this product, the flash point was 40 F, the lower flammable limit was 0.9%, and the upper flammable limit was 10.5%.  The spray booth was not substantially constructed of steel or of concrete or masonry.  The interior surface was not smooth and continuous without edges and designed to prevent pocketing of residues and facilitate cleaning and washing without injury.  The wooden floor of the spray booth was a combustible material.    Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.107(b)(10):     Illumination. When spraying areas were illuminated through glass panels or other transparent materials, only fixed lighting units were not used as a source of illumination. Panels shall effectively isolate the spraying area from the area in which the lighting unit is located, and shall be of a noncombustible material of such a nature or so protected that breakage will be unlikely. Panels shall be so arranged that normal accumulations of residue on the exposed surface of the panel will not be raised to a dangerous temperature by radiation or conduction from the source of illumination.    a. Outdoor Shed - The employer did not install overhead fluorescent light fixtures where the bulbs were enclosed to prevent breakage or from falling.   An employee sprayed Hentzen Coatings Tan 686A, 33446 VHF 1.5 VOC Zenthane (MIL-DTL-53039C, Type II, 08609TUZ-LVOC-1) onto blackout frames and sight protections.  Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.107(c)(5):     Combustible residues, areas. Unless specifically approved for locations containing both deposits of readily ignitable residue and explosive vapors, there shall be no electrical equipment in any spraying area, whereon deposits of combustible residues may readily accumulate, except wiring in rigid conduit or in boxes or fittings containing no taps, splices, or terminal connections.    a. Outdoor Shed, Rear of the Spray Area - The employer placed a pedestal mounted electric fan inside the spray area.  It was used to exhaust the spray vapors through two rear openings to the outside.   This fan was covered with visible combustible residue from the paint over-spray.  An employee sprayed Hentzen Coatings Tan 686A, 33446 VHF 1.5 VOC Zenthane (MIL-DTL-53039C, Type II, 08609TUZ-LVOC-1) onto blackout frames and sight protections. According to the material safety data sheet for this product, the flash point was 40 F, the LEL was 0.9%, and the UEL was 10.5%.   Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.107(c)(6):     Wiring type approved. Electrical wiring and equipment not subject to deposits of combustible residues but located in a spraying area as herein defined were not explosion-proof type approved for Class I, group D locations and shall otherwise conform to the provisions of subpart S of this part, for Class I, Division 1, Hazardous Locations. Electrical wiring, motors, and other equipment outside of but within twenty (20) feet of any spraying area, and not separated therefrom by partitions, shall not produce sparks under normal operating conditions and shall otherwise conform to the provisions of subpart S of this part for Class I, Division 2 Hazardous Locations.    a. Outdoor Shed, Spraying Area - The flexible power cords of the both the pedestal mounted fan and the overhead fluorescent light fixtures were plugged into a relocatable power tap.  The electrical wiring was not in rigid conduits and the switches and the relocatable power tap were not explosion-proof. An employee sprayed Hentzen Coatings Tan 686A, 33446 VHF 1.5 VOC Zenthane (MIL-DTL-53039C, Type II, 08609TUZ-LVOC-1) onto blackout frames and sight protections.  According to the material safety data sheet for this product, the flash point was 40 F, the LEL was 0.9%, and the UEL was 10.5%.  Contact between electric sparks and flammable vapors can lead either fire or an explosion.  Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $918.00 · Current $918.00

Hazardous substances 1377

General-duty citation text

29 CFR 1910.134(c)(1):     In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer did not establish and implement a written respiratory protection program with worksite-specific procedures. The program shall be updated as necessary to reflect those changes in workplace conditions that affect respirator use. The employer shall include in the program the following provisions of this section, as applicable:    a. First Floor and Basement  The employer did not develop and implement a written respiratory protection program, with workplace-specific procedures addressing the major elements of the program.  Employees used R-H Products Co., Inc.  HH-66 Vinyl Cement, a fast drying MEK-Toluene-Acetone blend adhesive, to bond Velco strips onto vinyl coated and vinyl laminated fabrics.  The employer required these employees to use either disposable 3M particulate respirators 8210 (N95) or disposable 3M particulate respirators 8577, P95 (TC-84A-1166).  The material safety data sheet for R-H Products Co. Inc. HH-66 Vinyl Cement stated that Breathing - Extreme overexposure to vapors may cause nervous system damage.  Observed On or About November 29, 2012    b. Outdoor Shed  The employer did not develop and implement a written respiratory protection program, with workplace-specific procedures addressing the major elements of the program.  The employer required an employee to wear a 3M air-purifying half-mask respirator equipped with 6001 organic vapor cartridges and 3M 5P71/07194 P95 particulate filters while spraying Hentzen Coatings Tan 686A, 33446 VHF 1.5 VOC Zenthane (MIL-DTL-53039C, Type II, 08609TUZ-LVOC-1) onto blackout frames and sight protections.  This product contained Hexamethylene Diisocyanate (HDI).  This chemical can sensitize employees, making them subject to severe asthma attacks if they are exposed again--even at low concentrations.  Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.134(d)(1)(ii):     The employer shall select a NIOSH-certified respirator. The respirators were not used in compliance with the conditions of its certification.    a. First Floor and Basement - The employer required employees to use disposable 3M particulate 8210 (N95) (TC-84A-0007) and 3M particulate 8577 (P95) (TC-84A-1166) respirators.  These respirators were not used in accordance with the conditions of their NIOSH certification.  This type of air-purifying filtering facepiece (dust masks) respirators, protect by filtering particles out of the air that the users are breathing.  The material safety data sheet for R-H Products Co. Inc. HH-66 Vinyl Cement stated that this product's physical state is a clear liquid and "Breathing - Extreme overexposure to vapors may  cause nervous system damage".  Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.134(e)(1):     General. The employer did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.    a. First Floor,  Basement, and Outdoor Shed - The employer did not ensure that employees were medically evaluated prior to fit testing and initial use of their respirators.  The employer required an employee to wear a 3M air-purifying half-mask respirator equipped with 6001 organic vapor cartridges and 3M 5P71/07194 P95 particulate filters while spraying Hentzen Coatings Tan 686A, 33446 VHF 1.5 VOC Zenthane (MIL-DTL-53039C, Type II, 08609TUZ-LVOC-1) onto blackout frames and sight protections.  This product contained Hexamethylene Diisocyanate and it was flammable.   Employee exposure to this chemical can lead to sensitization (chemical asthma).  Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances D668

General-duty citation text

29 CFR 1910.134(f)(2):     The employer did not ensure that an employee using a tight-fitting facepiece respirator is fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.    a. First Floor,  Basement, and Outdoor Shed - The employer did not ensure that employees were fit tested for their respirators prior to initial use of the respirators.  The employee required an employee wore a 3M air-purifying half-mask respirator equipped with 6001 organic vapor cartridges and 3M 5P71/07194 P95 particulate filters while spraying Hentzen Coatings Tan 686A, 33446 VHF 1.5 VOC Zenthane (MIL-DTL-53039C, Type II, 08609TUZ-LVOC-1) onto blackout frames and sight protections.  This product contained Hexamethylene Diisocyanate (HDI).  This chemical can sensitize employees, making them subject to severe asthma attacks if they are exposed again-even at low concentrations.  Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-15 00:00:00

Penalty

Initial $0.00 · Current $0.00

General-duty citation text

29 CFR 1910.134(h)(2)(i):     All respirators were not stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and they shall be packed or stored to prevent deformation of the facepiece and exhalation valve.    a. Basement - The employer did not ensure that an employee's respirators was properly stored.  The employer required an employee to wear a 3M air-purifying half-mask respirator while spraying "Hentzen Coatings Tan 686A, 33446 VHF 1.5 VOC Zenthane (MIL-DTL-53039C, Type II, 08609TUZ-LVOC-1)" onto blackout frames and sight protections.  His 3M air-purifying half-mask respirator was improperly stored on a dirty table.  Proper respirator maintenance and care are essential to the proper functioning of respirators for the continuing protection of employees.  Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 00401377

General-duty citation text

29 CFR 1910.134(k):     Training and information. This paragraph required the employer to provide effective training to employees who were required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary. This paragraph also requires the employer to provide the basic information on respirators in Appendix D of this section to employees who wear respirators when not required by this section or by the employer to do so.    a. First Floor,  Basement, and Outdoor Shed - The employer did not provide effective training for employees who were required by the employer to wear respirators.  The employer required an employee to use a 3M air-purifying half-mask respirator equipped with 6001 organic vapor cartridges and 3M 5P71/07194 P95 particulate filters while spraying Hentzen Coatings Tan 686A, 33446 VHF 1.5 VOC Zenthane (MIL-DTL-53039C, Type II, 08609TUZ-LVOC-1) onto blackout frames and sight protections.  This product contained Hexamethylene Diisocyanate (HDI).  This chemical can sensitize employees, making them subject to severe asthma attacks if they are exposed again even at low concentrations. Observed On or About November 29, 2012

Issued

2013-03-11 00:00:00

Abate by

2013-03-28 00:00:00

Penalty

Initial $918.00 · Current $918.00

General-duty citation text

29 CFR 1910.1200(h)(1):     Employers shall 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 physical or health hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets.    a. First Floor and Basement - The employer did not ensure employees were provided effective information and training pertaining to hazardous chemicals used in the workplace.  Employees used R-H Products Co., Inc.  HH-66 Vinyl Cement, a fast drying MEK-Toluene-Acetone blend adhesive, to bond velcro strips onto vinyl coated and vinyl laminated fabrics.. This product can cause eye and skin irritation.   Observed On or About November 29, 2012    b. Outdoor Shed - The employer did not ensure employees were provided effective information and training pertaining to hazardous chemicals used in the workplace.  An employee wore a 3M air-purifying half-mask respirator equipped with 6001 organic vapor cartridges and 3M 5P71/07194 P95 particulate filters while spraying Hentzen Coatings Tan 686A, 33446 VHF 1.5 VOC Zenthane (MIL-DTL-53039C, Type II, 08609TUZ-LVOC-1) onto blackout frames and sight protections.  This product was flammable.   Observed On or About November 29, 2012