B. Opening Conference
An opening was conducted with all five CSHOs, [REDACTED] (all mgt., Tyler Pipe), [REDACTED] (union). Credentials were presented and the purpose and scope of the inspection were explained. The OSHA 200 log was reviewed and the LWDI/LWDII rates were calculated. All required elements for the FIRM were covered.
C. Workplace Observations
Tyler Pipe is a gray iron foundry. Throughout the plant, molten metal is seen spilling from the cupolas, bulls and ladles. The forklift trucks transport the metal, and the ground behind the trucks often smokes with puddles of molten metal. Workers are covered with black residue from the foundry sand. Many work areas are dark, due to poor lighting and clouds of sand. Despite all the ignition and fuel sources, exit paths are not obvious. Many workers have scars or disfigurations which are noticeable from several feet away. Burns and amputations are frequent. This facility is located in a relatively small town where jobs are not plentiful. Throughout the plant, in supervisors offices and on bulletin boards, next to production charts and union memos, is posted in big orange letters: REDUCE MAN HOURS PER TON.
Process Information: following is a summary of the plant buildings and the activities conducted in these buildings:
South Plant: a natural gas powered cupola is the center activity. Other activities include iron pouring, shakeout, shot blast, grinding, core setting using formaldehyde, sulfuric acid
Impact Millroom: includes shakeout, grinding, milling
Impact Molding: Molds for the metal are stamped out of sand and resin. Includes return sand system pit, iron pouring operation
ABC Core building: molds are finished and sealed. The process involves the use of isocyanates.
Core Room: storage of cores.
Wade warehouse: includes metal machine shop, work order area and supply area.
Production Finishing Gustin-Bacon Wade: final product finish, machining, drilling
Gustin Bacon Bldg: storage
North Plant: center activity is the cupola. Other activities include iron pourer, shakeout, grinding, shot blast
Mill Room: grinding and milling on cores
Herman Unit Moldmaster: Manufacture molds, milling and drilling
Mold Shop: manufacture of cores using resins, isocyanates, core sand
Water Treatment: treats the waste water from the plant
Machine Shop: mills, lathes, grinders, miscellaneous operations; some maintenance, some production
Electric Shop: plant electricians store supplies and conduct any maintenance that can be done in shop.
Construction Shop: storage area for construction supplies
Pattern Storage: core patterns stored
Engineering Lab: computers and offices
Many violations were found. See OSHA 1-Bs. Upon review of the OSHA 200 logs and 101s, it was noticed that the lost days plummeted in July of 1997. The union was asked about this issue. [REDACTED] stated that this was due to an agreement with Tyler Pipe to assign injured workers to light duty jobs.
Written programs: at this time, there were no currently exposed employees. The company stated that outside services would be used for first aid.
Lockout/Tagout: there were significant inadequacies found. See OSHA 1Bs.
Electrical Safe Work Practices: inadequacies found. See OSHA 1Bs.
Hazard Communication: See OSHA 1B-lack of training.
Emergency Evacuation/Response: significant inadequacies found. See OSHA 1-Bs.
Confined Space: significant inadequacies found. See OSHA 1-Bs.
There were significant inadequacies in training. See OSHA 1-Bs.
Audiometric exams were adequate, but inadequacies were found in medical surveillance for respirator wearers.
CSHOs [REDACTED] and [REDACTED] conducted sampling during the initial walkaround 3/29-3/31. Additional sampling was conducted 4/19-4/21/99 and 6/23/99. This was done to allow time for various sampling media to arrive. The 6/23/99 sampling was done in response to an employee complaining of exposure to metals. The CSHOs sampled for ammonia, silica, cobalt, beryllium, molybdenum, cadmium, chromium, copper, zinc, iron, manganese, nickel, lead, antimony, vanadium, zinc, triethylamine, formaldehyde, toluene, xylene and ethyl benzene.
Results: Overexposure to noise: engineering controls cited for levels over 600% dose.
Excessive silica: cited for respirator deficiencies
Most of the other sampled chemicals were found above detection limits, but none were above the permissible exposure limits. No citations were proposed regarding these exposures.
D. Closing Conference
A preliminary closing was held 3/31/99 with all five compliance officers and [REDACTED]. Potential violations were discussed at this time. Rights and responsibilities were covered. All elements required by the FIRM were covered during this meeting.