OSHA Inspection: TRAFA PHARMACEUTICAL INC

Issued

2024-08-06 00:00:00

Abate by

2024-09-23 00:00:00

Penalty

Initial $3687.00 · Current $3000.00 Reduced

Hazardous substances 9135

General-duty citation text

29 CFR 1910.134(c)(1): A written respiratory protection program (RPP) that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented where respirators were necessary to protect the health of employees:  In the mixing station at 140 Padgette Street, MA:   On and before May 9, 2024, the employer did not implement a RPP for employees who are required to wear half-face elastomeric respirators while grinding and mixing organic vitamins and minerals.  ABATEMENT NOTE:  A respirator program shall include the following elements:    -Procedures for selecting respirators  -Medical evaluations for employees required to use respirators  -Procedures for fit testing tight fitting respirators  -Procedures for proper use of respirators  -Procedures and schedules for cleaning, storing, inspecting, and maintaining respirators  -Training of employees about respiratory hazards in the workplace  -Training on proper use of respirators  -Procedures for regularly evaluating the effectiveness of the program  *Abatement notes are intended only to provide clarity regarding existing requirements under the law or agency policies. Abatement notes do not create (or diminish) legal obligations under the Occupational Safety and Health Act.

Issued

2024-08-06 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 9135

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer shall identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.  At the mixing station at 140 Padgette Street, MA:   On and before May 9, 2024, the employer did not identify, and evaluate, nuisance dust as a respirable hazard in any form, during the mixing and grinding process.

Issued

2024-08-06 00:00:00

Abate by

2024-09-23 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 9135

General-duty citation text

29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee's ability to use a respirator before the employee was fit tested or required to use the respirator in the workplace:  In the mixing station at 140 Padgette Street, MA:   On and before May 9, 2024, two employees were not provided a medical evaluation prior to being required to wear an elastomeric half face respirators to conduct mixing and grinding.

Issued

2024-08-06 00:00:00

Abate by

2024-09-23 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 9130

General-duty citation text

29 CFR 1910.134(f)(1): The employer did not ensure that employees using a tight-fitting facepiece respirator pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT) as stated in this paragraph.  In the mixing station at 140 Padgette Street, MA:   On and before May 9, 2024, the employer did not ensure that two employees where quantitatively or qualitatively fit-tested for respirators prior to usage for mixing and grinding of pure organic chemicals.

Issued

2024-08-06 00:00:00

Abate by

2024-09-23 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 9130

General-duty citation text

29 CFR 1910.134(g)(1)(i)(A): Respirators with tight-fitting facepieces were worn by employees who had facial hair that came between the sealing surface of the facepiece and the face or that interfered with valve function:  140 Padgette Street. Chicopee, MA: On March 7, 2024, and at times prior, the employer did not ensure that employees, required to use respirators, did not have facial hair which came between the sealing surface of a half-face elastomeric respirator while performing mixing/grinding of pure organic ingredients.

Issued

2024-08-06 00:00:00

Abate by

2024-09-23 00:00:00

Penalty

Initial $3687.00 · Current $0.00 Reduced

Hazardous substances 1560

General-duty citation text

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 will be met:  In the mixing room and at stations in the warehouse at 140 Padgette Street, MA:   On and before May 9, 2024, the employer did not develop a written HAZCOM program for various hazardous chemicals including but not limited to 70% and 99% isopropyl alcohol.

Issued

2024-08-06 00:00:00

Abate by

2024-09-23 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 1560

General-duty citation text

29 CFR 1910.1200(e)(1)(i): The employer did not compile a list of the hazardous chemicals known to be present using a product identifier that was referenced on the appropriate safety data sheet.  In the mixing room and at stations in the warehouse at 140 Padgette Street, MA:   On and before May 9, 2024, the employer did not compile a list of hazardous chemicals known to be present such as, but not limited to, 70% and 99% isopropyl alcohol.

Issued

2024-08-06 00:00:00

Abate by

2024-09-23 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 1560

General-duty citation text

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 with the information specified under paragraphs (f)(6)(i) through (ii):  In the mixing room and at stations in the warehouse at 140 Padgette Street, MA: On May 9, 2024, and at times prior, the employer did not ensure that secondary containers for chemicals are labeled according to the universal classification and labeling requirements.  Isopropyl alcohol was stored in unmarked spray bottles at various stations within the warehouse.

Issued

2024-08-06 00:00:00

Abate by

2024-09-23 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 1560

General-duty citation text

29 CFR 1910.1200(g)(8): The employer did not maintain in the workplace copies of the required safety data sheets (SDS) for each hazardous chemical and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s).  In the mixing room and at stations in the warehouse at 140 Padgette Street, MA:   On and before May 9, 2024, the employer did not ensure that SDS's are made available to employees who use hazardous chemicals such as, but not limited to, 99% isopropyl alcohol and bleach during the respirator sanitation and facility maintenance cleaning process.

Issued

2024-08-06 00:00:00

Abate by

2024-09-23 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 9135

General-duty citation text

29 CFR 1910.134(h)(1)(i): Respirators issued for the exclusive use of an employee were not cleaned and disinfected as often as necessary to be maintained in a sanitary condition:   At 140 Padgette Street, MA:   On and before May 9, 2024, the employer did not ensure that required-use respirators are maintained in a sanitary condition.   Two respirators were observed in the mixing area and on a desk and the respirators were damaged and in unsanitary condition.

Issued

2024-08-06 00:00:00

Abate by

2024-09-23 00:00:00

Penalty

Initial $0.00 · Current $0.00

Hazardous substances 9130

General-duty citation text

29 CFR 1910.134(j): The employer did not ensure all respirator filters, cartridges and canisters used in the workplace were labeled and color coded with the NIOSH approval label and that the label was not removed and was legible:  At 140 Padgette Street, MA:   On and before May 9, 2024, the employer did not ensure that required-use respirator filter cartridge labeling was legible.  An unknown half-face respirator and unknown brown cartridge filter was used that contained Chinese lettering without an expiration date.  A 3M half-face elastomeric respirator was used with filter cartridges containing damaged labeling.