Document 6b2zBJv2dRJGoXkdqVE3E3kwd
CJ^V.ICALS
nCS JUN 2 0 1974
INTEROFFICE / LAKE CHARLES
TO r ROM
Aar Car
I 97*
DATE CF INSPECTION: COMPLIANCE OFFICER: CAUSE OF INSPECTION: UNTO:! REPRESENTATIVE:
MANAGEMENT REPRESENTATIVE:
Routine - (',CM "Yocess)
M'fcchell Andrews BiM Andreas
3oo _yncn Bryant Walker
OPENING CONFERENCE
Mr. Steven D. Herron, Industrial Hygienist with the Department of Labor, arrived at the Lake Charles Plant on Jure 12, 1S74. He requested to see a management representative and was referred to Murry Davis, Safety and Security Director. An opening conference was established at Dewey Duncan's office with the Compliance Officer, D. L. Duncan, R. E. Hanna, J. M. Davis and B. W. Walker present at the conference. A questionaire concerning VCM and PVC was given to Mr. Duncan to be filled out by his choice of personnel. Another questionaire was given to R. E. ganna concerning routine information, i.e,, number of employees, names of PPG Officials, address, etc. Mr. Herron asked questions from another questionaire which established whether PPG is covered by the law and other routine cuestions. Mr. Herron was asked for some identification and he presented his Department Of Labor Credentials. Mr. Herron stated that his primary purpose was :o inspect our VCM process and VCM snipping. He also stated that r.s would like to inspect our asbestos insulation shop and storage area if he -ad time. Mr. Herron requested an interview with an employee representative. Micchell Andrews was called to Mr. Duncan's office for the interview with vr. Herron. After the interview, Mitchell Andrews stated that Bill Andreas w:culd accompany Mr. Herron on the inspection. Mr. Duncan informed Andrews tnat the employee representative would not be paid by PPG during the inscection. Mr. Duncan appointed Bob Lynch and Bryant Walker as the employer representatives for the inspection.
INSPECTION
The inspection began in the Safety Director's office so that Mr. Herron could review our accident records. All recorckeepirg was in compliance with OSHA.
SL 084971
* R. E. Hanna OSHA Inspection ?2 Page 2
Mr. Herron also reviewed our exposure.
After inspection of Lie records,
c area ~ c
ing resu'Its
sample so tnat an air sample of nis excssure to VCM could be taken. Cur lab personnel took air samples an me sa~e time. A picture was taken of Jordan as he attached a sample c;-'tai^e^ co the VCM sample line. Jordan was also monitored as he analyzed tne VCM sample in the VCM plant lab. Another picture was taken in the plant 'ab. 3efore leaving the VCM plant, John Jordan explained that he has operao-d the wrong valve on the sampling job which caused VCM to spray out onto "is hards. Mr. Herron stated that this will not cause the sample co be in.alid due to the probability of this type of incident occuring at any time.
Mr. Herron then requested to be taken to the Shipping Department VCM Tank Car Loading Rack for inspection. After arriving at the loading rack, Mr. Herron determined that monitoring would not be necessary due to new inovations which eliminated exposure. His conclusion was reached after a discussion of the loading procedure with Dean Tnibcdeaux, Shipping Department Loader, and Charles Burns, Shipping Department Foreman.
After leaving the loading rack, Mr. Herron requested to see our asbestos operation in the Cell Repair Area. Mr. Herron inspected the asbestos storage area first and then walked through the Cell Repair Area. The following proposed violations were noted by Mr. Herron on his first inspection of the Cel 1 Repair Area.
1. Failure to post appropriate asbestos hazard warning signs in the asbestos storage and handling areas and cn containers which contained asbestos.
2. Failure to keep a safety shower unobstructed for use. (A floor fan had been placed under the safety shower.)
3. Failure to utilize eye wash fountains in place of hose attached to safety shower.
4. Failure to maintain bench grinder in compliance with standards.
a. The tool rest was not adjusted within 1/8" of the wheel.
b. The top of the guard opening was greater than 1/4" between the wheel and the guard.
5. Failure to provide a safe walking surface around a wet operation. (Water on floor around cathode dip tanks and around cement mixing operation.)
SL 084972
R. E. Hanna m OSHA Inspection i2
Page 3
When Mr. Herron noticed the lead pouring operation, the asbestos fluffing
operation, and the solder wiping coe'-ation, he deciced to return the following
day to obtain personnel monitoring samples
eac" operation. Before weaving
he stated that he would conduct a closing conference and would like to review
our monitoring records on the above mentioned operations.
We proceeded to the Safety Director's office to look at the records and have the closing conference. M. Davis produced the monitoring records as requested and Mr. Herron asked for a copy of each. Copies of the records that were given to Mr. Herron are attached as attachments #1, 2, and 3. The closing conference was conducted and will oe ciscussed in a later paragraph.
The following day, June 13, 1974, Mr. Herron obtained personnel monitoring samples from Dennis Clifton and Sydney Clemet on the lead pouring operation; from Peter Carrier on the asbestos fluffing operation; and from Robert Hartman on the solder wiping operation. After Hartman completed the solder wiping operation, Mr. Herron requested an examination of the respirator due to Hartman coughing during the operation. Upon examining the MSA Comfo Respirator it was found to contain two Mersorb cartridges on it instead of the required GMA organic vapor cartridges. This resulted in another proposed violation and possible citation.
6. Failure to provide proper respiratory protective equipment.
CLOSING CONFERENCE
A closing conference was conducted on June 12, 1974, with Mr. Herron, Bob Lynch, J. M. Davis, B. W. Walker and Bill Andreas present at the conference. I should point out that it was the employer's prerogative to allow the employee representative to be present at the closing conference. Mr. Herron explained the proposed violations and the employers responsibility in handling any citations resulting from such proposed violations. He also explained that due to a delay in receiving his sample results, it may be six weeks to two months before any information on the sampling would be available. If the results of the samples indicate a violation of the allowable concentrations, we could receive additional proposed violations which could result in citations In reviewing the proposed violations, it was pointed out to Mr. Herron that the specific standard covering safety showers and eye wash facilities allowed the use of a hose attached to the safety shower. Mr. Herron stated that it was the Area Director's interpretation that "eye wash fountains" must be installed. He remarked that he would check this proposed violation with the Area Director and call us on the decision if it results in a proposed violation.
CONCLUSION
All violations noted by the Compliance Officer are only proposed violations that may or may not result in a citation. Issuing citations and establishing
SL 084973
R. E. Hanna OSHA Inspection #2 Page 4
penalties is the prerogative of the Area Director for the Louisiana Office. If a citation is issued, the violation is considered as alleged until a 15 working day waiting period ends after issuance. During this 15 day period, the employer has an opportunity to contest the proposed violations._ If they are not contested, the proposed violations are considered as violations and must be corrected within the prescribed abatement period.
Personnel "onitoring samples were taken by our lab personnel each time the Compliance Officer took samples. The results of our sampling are as follows with the TLV indicated n0r each chemical.
ITEM VCM - Process Operator VCM - VCM Lab Lead - Feed Pot Lead - Pourer Lead - Soldering Job
RESULTS 5.0 ppm 2.2 ppm 71 ug/m3 34 jjg/m3 169 >jg/m3
TLV *515 ppm
50 ppm 200 jjg/m3 200 jug/m3 200 Jjg/m3
BWW/bc
Attachment (3)
cc: A.T. Raetzsch D.L. Duncan R.E. Baker T.G. Taylor J.M. Davis L. Krause J.H. Morgan R.P. Lynch R.E. Eakin J.C. Lafleur H.J. Hoenes C.A. Bums E.L. Cook H.C. Underwood R.E. Sourwine
SL 084974
lead-if-aip pat;. sr.'ci 1969
Monitored Personnel or Area
:0 TCZ Sol lor Too Or orator Colder Pod Croreior 1 L-' z O 0 ^ IT cL v '>-> i Dodder Pot Operator
Solder Pot Orarator Fo Pot Area Solder Wiping Area Fo Pot Area Solder Wiping /area Fb Pot Area Solder Wiping Area Solder Wiping Area Fo Pot Area
Fo Pot Area
Fo Pot Area Fo Pot Area boiaer wiping Area Solder Wiping Area Fo Pot Area Solder Wiping Area Fo Pot Area Solder Wiping Area
D:; te
Cr"srts
Fd Idethod Cone. , ij-.
A- 2-69 4-21-6? 5- 2-69 10- 7-69 10- 7-69
10- 7-69 2- 4-71 2- 4-71 3-15-71 3-15-T1
11- 8-71 11- 8-71 11- 6-71 n-10-71
3-14-72
3-14-72 3-14-72 '3-14-72 3-14.72 11-10-72 U-lO-72 6-21-73 6-21-73
A
A
A
A
Sampled Rill while wiping
A
Ins tars with roller solder.
A
B
B
B
B
B
B
Sampled CILY while wiping bars .B
Sampled CILY while pouring
lead.
B
Sampled while removing slag
freer Pot Samoled while pouring lead. Sampled while pouring lead.
B b <ri 30 B "B
Sampled while wiping bars.
B
Sampled while pouring Fb.
B
Sampled while wiping bars.
B
Sampled while pouring lead. Sampled while wiping bars.
B B
< 0.05 0.20 0.15 0.05
> o.4o
0.10 < 0.05 < 0.05 < 0.05 < 0.05 < 0.05 < 0.05
0.05
0.10
0.05 < 0.05 < 0.05 <. 0.05 < 0.05 < 0.05
0.05 < 0.05 < 0.05
Method. A: MSA Personnel Monitor, 12 to 43 hn samplings. Method B: MSA Universal Fb Test Kit, arfo-cr''^ tely 2 min sample near personnel.
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To: From:
Dr. K. B. Lovejoi Tommy R, Vizena
EMPLOYEE
DATE OF SAMPLE
VOL. LITERS
Alton Thomas Mur!in Fontenot Emmanuel Gui11ory Robert Hartman John McNabb Charles DoJoan
Clifton Dennis Peter Carrier Jos. Guidry Raymond Landry Wickley Boullard Simon Woods
4/17/74 4/26/74 4/17/74 4/17/74 4/26/74 4/19/74 5/15/74 4/26/74 4/19/74 4/22/74 4/16/74 4/26/74 5/15/74
0.68 0.64 0.56 0.60 1.60 0.06 0.44 0.50 2.08 0.48 0.74 0.34 1.74
SP. GR.
1.024 1.018 1.021 1.017 1.011 1.002 1.030 1.029 1.007 1.026 1.025 1.020 1.012
UNCOR.
Date:
June 3, 1974
Subject: Houston Chemical's results on blood & urine lead.
URINE tng/L QOR.(1.024}
BLOOD mg/100 gin
0.038 0.033 0.057 0.035 0.021 0.027 0.145 0.041 0.034 0.035 0.027 0.033 0.024
0.038 0.044 0.065 0.049 0.047 0,324 0.116 0.034 0.120 0.032 0.026 0.040 0.040
0.033 0.062 0.053 0.050 0.030 0.100
0.045 0.041 0.060 0.050 0.051
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1
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SL 084976
Date 3-06-74 3-06-74 3-08-74 3-08-74 3-13-74 3-13-74
3-13-74 3-14-74 3_li_74 3-15-74 3-15-74 3-15-74
Tyne Per si. Personnel Personnel Personnel Personnel Personnel
Area Personnel Area Personnel Area Personnel
AIR SAMRD1
HUMS AID DUSTS
Fo, 3n, Co
Duration
coo or Area
Concentration, l< g/M^
5 Hours C| Hours 4 Hours 4 Hours 3 Hours 3 Hours
Uncle Pouring C O ,3 - T* 1' ----0 Anode Pouring Solder Wiping' Anode Pouring Solder Wiping
(Eejean) (C-uillory)
(Clifton) (Clement)
(Dejean) (Guillory)
08O 580 170 1,030 340 (310 (280
Fo Yd Fd Fc Fo Fb Sn
3 Hours 3 Hours 3 Hours 3 Hours* 6:3 Hours 2.5 Eours
Lunch Table Lead Pot Addition
(McITatTb)
East Wall on Temperature Recorder
Maintenance Welder-Copper (Hayes)
Between ro Pots
Cathode Hand Tinning
(Hartman)
7T Fb 500 Fb
25 Fb 450 Cu
69 Fb
( 35
Fd
( l4
Zn
((29 as ZnCl2)
Threshold Limit Values for
Above Metal ?r--s and Dusts (from OSSA Tables)
Fb (Lead, inorganic)
200 p.g/l43
Sn (Tin, inorganic)
2.000 pg/M3
Cu (Copper, fume)
100 pg/M3
Cu (Copper, dusts and mists)
1.000 pg/M3
Zn (Zinc chloride fume)
1,000 p.g/M3
* 3 hours continuers cutting o copper with copper rod. This type of work done appro: matsly once in two weeks (3 hours).
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