Document 6wGrKby9pyoY3kbaK1oBykqDo

To: Chuck Bush Jim Griffin Bob Kissling Bob Krebs Steve Williams From:Dan Gleghorn March 1, 1990 AIiTC INDUSTRIAL HEALTH AUDIT Enclosed is the final report of the Industrial Health Audit conducted at your facility by Paul Zakriski and myself during the period of January 22 - 25, 1990. Your program has taken a leap forward since Jim Griffin came aboard. Many strategies are being implemented which will continue to strengthen your overall program. During our audit, we pointed out conditions that violated BFGoodrich and OSHA standards or were inconsistant with good health practices. The facility was rated with 73 items "Satisfactory", and 20 Items "Need Attention" The report format is laid out for you to write in your abatement program and indicate the status as Complete, In-Progress or Incomplete. A progress report giving the status of the items requiring attention is due 60 days after receipt of the report. The report includes the following: I. Favorable Observations II. 1990 Items to be Corrected III. Facility Inspection Tour IV. Industrial Hygiene Program Rating V. Hearing Conservation Audit Checklist Dan Gleghorn cc: R. J. Grahek/C. J. Nosal H. Waltemate P. M. Zakriski - Brecksville D. Dimas - Bath NGC 12974 AVON LAKE TECHNICAL CENTER INDUSTRIAL HEALTH AUDIT JANUARY 22-25, 1990 FAVORABLE OBSERVATIONS 1. Excess chemical amnesty days are in progress. Old lab chemicals are being collected and disposed of. This should help the Hazard Communications Program. 2. Safety showers, eye washes and SCBA are inspection tagged similar to fire extinguishers. This is an excellent idea. 3. Building 414 a. We were advised by Jerry Bialko that a simulated vessel rescue last week, with a manikin, took 2.5 minutes from alarm to person out of the vessel and on the stretcher. b. There will be a four-hour safety and training meeting this Saturday for all employees. c. MSDS's are in the Control Room. The index is updated with a write-in procedure. The person receiving the MSDS registers it. This system has some good points. 4. All lab hood6 in the facility are being checked and up-graded by Professional Balance Company. The documentation is impressive. 5. Immersion Lab: When the operator was questioned, he understood . the hazards of a Brabender. This was a good test of Hazard Communication. 6. Extruder Building: a. Three new ventilation systems are being installed. should have a positive effect on this building. This b. SOP's for this area are about 95% complete. Employees are required to sign them to verify they received training. c. MSDS's are stored by Raw Material Number and Alpha. 7. THA 1 and THA 2: GC and HNU's are calibrated every Monday morning. 8. Estane Lab: Barbara Kantola's MSDS system is the best in the facility. 9. Rupture Disc and Calibration: This is an excellent program. NGC 12975 AVON LAKE TECHNICAL CENTER INDUSTRIAL HEALTH AUDIT JANUARY 22-25, 1990 II. ITEMS TO BE CORRECTED IH-1990-1 Engineering and/or maintenance efforts need to be directed to reducing noise in those areas/jobs with an eight-hour TWA exposure of 90 dbA or greater (100% dose) OSHA. Note: Details of this effort must be documented. (Although noise enclosures and other treatments are used, noise must be engineered out of equipment.) Response STATUS____________ ______ Completed ______ In-Progress ______ Incomplete IH-1990-2 Personnel working at noise hazardous jobs must training which includes at least the following (OSHA). a. The effect of noise on hearing. receive annual information b. The purpose of hearing protectors, the advantage/disadvantage and attenuation of various types, and instruction on selection, fitting, use and care. c. The purpose of audiometric testing and explanation of the test procedures. The past training program in your facility was not acceptable. Send me a copy of your program which you intend to implement in the 2nd. quarter, 1990. Response NGC 12976 3651j/2 STATUS_________ Completed In-Progress Incomplete IH-1990-3 Care must be exercised to insure a proper initial fit and correct use of all hearing protectors (OSHA). Note: With insert type hearing protectors (ear plugs), it is important that the ear canal be clear and free of impacted wax. The ears should be examined for impacted wax before plugs are fitted. If impacted wax is found, it should be removed by a nurse or physician. Any employee complaining of an ear problem should be referred to medical personnel for examination. Avon Lake medical is qualified to handle, but fitting has not been done. Advise when this program is being implemented during annual physicals. Response STATUS__________ Completed In-Progress Incomplete IH-1990-4 Audiometric examinations must be provided for employees transferring to noise hazardous jobs. Provide me a list of the Noise Hazardous Jobs you have developed and your implementation procedure. Response 3651j-3 STATUS________ Completed In-Progress Incomplete NGC 12977 IH-1990-5 Jim Griffin is conducting walk-through audits of your facility. It is recommended that Bob Krebs establish a management walk-through program. Response STATUS_________ Completed In-Progress Incomplete IH-1990-6 Equipment in the Medical Department should have certification/ calibration procedures and programs. a. Audiometer is okay. b. Spirometer receives a nurse check only. This instrument should be calibrated at least every two to three years. c. Develop a procedure to assure accuracy of the EKG unit. Response 36513-4 STATUS_________ Completed In-Progress Incomplete NGC 12978 IH--1990--7 It is recommended that nurses be supported to attain certification as Occupational Health Nurses. Response STATUS_________ Completed In-Progress Incomplete IH-1990-8 A Hazard Inventory for Chemical and Physical Exposures by Department and job must be completed. (Per BF6 SH&E Policy). This will satisfy the first step in the 1989 PEL project. Response 3651j-5 STATUS_________ Completed In-Progress Incomplete NGC 12979 1H--1990-9 An annual review, update and goals projection for Job Hazard Exposures is necessary. I reviewed some of the draft documents Steve Williams has prepared and they look very good. Please send me copies of these reports. Response STATUS________ Completed In-Progress Incomplete IH-1990-10 Review your Hazard Review and Use Process and Committee structure. Advise where you wish to modify either the procedure or committee structure. Response 3651j-6 STATUS_________ ______ Completed ______ In-Progress ______ Incomplete HGC 12980 IH-1990-11 Vinyl chloride training has to be more than giving an employee a report and having them read it. This was the previous approach in your facility. Provide me a copy of your new training criteria and implementation program. Response STATUS_________ ______ Completed ______ In-Progress ______ Incomplete IH-1990-12 Send me your training criteria and implementation program for lead. Response STATUS_________ ______ Completed ______ In-Progress ______ Incomplete IH-1990-13 Submit your strategy to comply with the OSHA PEL'S. I know you are working on this project. I would like a step-by-step strategy. Response NGC 12981 3651j-7 STATUS_________ Completed In-Progress Incomplete IH--1990--14 Provide me with your criteria and implementation program for Respiratory Protection Training. Response STATUS_________ Completed In-Progress Incomplete IH-1990-15 Provide me with your criteria and implementation program for Respirator Fit Testing. I know testing is being scheduled for February 22, 1990. Please advise its completion and your future implementation plan. Response 3651J-8 STATUS_________ Completed In-Progress Incomplete NGC 12982 IH-1990-16 Medical Examinations for Respiratory Protection must be performed in accordance with BFG Occupational Health Policies, Section 1.17, except that OSHA (1910.134) requires re-examination annually. A new OSHA standard is in draft form and will probably be published later this year which will make Respiratory Protection Requirements more demanding. Provide me with your criteria and implementation program for Respiratory Protection Medical Surveillance Examinations. Response STATUS_________ Completed In-Progress Incomplete IH-1990-17 Review environmental monito^ng results to determine jobs that have unexpected non-compli^nty exposures. Some monitoring results rnd'icate non-complir^nt Exposure without protection. Advise me how you intend to handle this situation. Response NGC 12983 STATUS_________ Completed In-Progress Incomplete IH-1990-18 Labels indicating ventilation systems rating or flow-rating should be posted on the lab hood or equipment. Response DEGleghorn 2/27/90 STATUS_________ Completed In-Progress Incomplete 3651j-10 NGC 12984 Ill- ALTC INDUSTRIAL HEALTH AUDIT FACILITY INSPECTION TOUR 1. Building 421 a. One SCBA mask not coveted at SW cornet. b. Ed Leeson's storage area needs review and clean-up. Some chemical has spilled on a shelf in the cabinet. c. 2nd floor: Remove face shield box that is empty. d. 3rd floor: (1) The amount of chemicals stored on the production floor should be restricted. (2) Bonding means needs to be provided so grounds are not made to Unastrut. (3) This is the cleanest floor in the building. 2. Safety Showers, Eye Washes and SCBA are tagged like fire extinguishers. This is an excellent idea. 3. Building 414: a. Breathing Air is Instrument Air. There i6 a question as to how users are warned if there is a problem. A System must be developed to handle User Warning. 4. Ice House: a. The building is congested and needs a dual inventory (one in building and one remote.) b. Chemical storage compatibility needs to be reviewed. 5. Bunker Building: a. A dual inventory is needed. b. Catalyst jugs must be triple washed and slashed. c. The small chest freezer should be replaced. d. Housekeeping is poor. 6. Analytical Lab: a. MSDS book should have an index. b. Oven operator was wearing an air purifying respirator with a beard. This device will not provide protection to the user and it should be discontinued. c. Steve Williams will monitor this operation to determine whether respirator protection is needed. 3624j/l r jgleghorn 2/27/90 NGC 12985 7. Immersion: a. Haste Solvent Can is not labeled. 8. Physical Test Lab: a. Should have SOP on filling Liquid Nitrogen containers. b. Dave Marshall's portion of Lab needs housekeeping improvement. 9. Latex Labs: a. Emergency Exit was blocked. The exit should be cleared or the signs removed showing it as an emergency exit. 10. Latex Applications Lab: a. Should have inventory of chemicals and an index in the MSDS books. 11. Extruder Building: a. Need MSDS's on Tide, Ajax, etc. the home. They are not used as in 12. THA 1 & THA 2: a. Need Warning for users of breathing air when there is a problem with the breathing air. 13. Medical: a. The nursing staff/employee ratio should be reviewed. 14. Estane Lab: a. An SOP on filling Nitrogen Containers is needed. b. There is a need to review Training and Shielding on the Laser in the Monsanto Processability Tester. The present operators appear to be well trained and aware of the hazard. 15. A.E.D.L.: a. Twin Sheet Oven must have heat limiting protection (against product degradation) or be vented outside scrubbed. or b. Comet Vacuum Former needs electrical panel labeled. 16. Power House: a. Breathing Air/Instrument Air System. 1) Calibration of CO monitor is now be weekly. 2) The Breathing Air System must be standards (Eng. Std. 404) annual. brought Should up to BFG 3) The Dew Point instrument has been dismantled. 4) There must be an SOP to notify user if there is a problem in the system. 5) 3624j/2 r ini nrrVin r n / O / C / O r\ This situation was brought to the attention of Bob Sandfry. Vic Goode was with him. NGC 12986 IV, CHEMICAL GROUP INDUSTRIAL HYGIENE PROGRAM RATING LOCATION: Avon Lake Technical Center Date of Audit: January 22 - 25, 1990 RATING INDUSTRIAL HYGIENE PROGRAM ADMINISTRATION Industrial Hygiene Coordinator S Named S Knowledgeable S Walk-throughs Periodic Industrial Hygiene Program Reports S Timely S Content S Year-end Summary S Goal for Next Year Medical Services S Physical Examination NA Medical Equipment Certification/Calibration NA Training S Illness and Complaint Investigation Hazard Inventory NA Complete NA Annual Review and Update Chemical Hazard Review and Use NA Committee Established MSDS S Available s Employees Trained in Use Reply to Industrial Hygiene Audits NA Initial NA Final Report Training S Hazard Communication NA Viny1 Chloride NA Lead S Acrylonitrile s ETO s Butadiene NGC 12987 2- - Compliance with OSHA PEL's by Area From NA Vinyl Chloride S Acrylonitrile NA Lead S Noise S ETO S Butadiene Respiratory Procedure S Written S Selected per Hazard NA Training NA Fit Testing NA Medical Examination S Cleaning S Storage S+ Inspection S Approval NA Usage Asbestos Handling and Disposal S Sources Identified S Monitoring S Medical Examination S Demolition and Removal S Protective Clothing S Written Industrial Hygiene Sampling NA OSHA Compliance NA Hazard Evaluation S Special Requests NA Sample Procedures S Analytical Procedures/Cross Check Program S Employee Interview Hearing Conservation S 20 Total (See Checklist Attached) NA 4 Total ( M '' ") Radiation S Hazards Identified and Labeled S License Requirements S Records NGC 12988 -3- S Dosimetry Program S Periodic Leak Check S Radiation Protection Officer Ventilation for Health Hazard Control S Periodic Flow or Maintenance Checks Lab Hoods S Yearly Flow Checked NA Rating or Flow-Rate Posted S Modifications Reviewed S New Systems Reviewed Leak Detection DNA DNA DNA Written Area Monitoring Response Leak Repair Control I.H. Equipment Calibration Audiodocimeters S Daily Calibration S Laboratory Calibration Sound Level Meters DNA Daily Calibration DNA Laboratory Calibration/Three Years S Acoustic Field Calibrators Every three Years S Radiation Detection Device - Annually S Area Monitoring Devices S Personnel Monitoring Pumps Laboratory Safety S Lab Hoods Adequate for Hazards S Lab Procedures Reviewed S Personnel Protective Clothing and Equipment NGC 12989 Total Satisfactory: 73 Needs Attention: 23 Dose Not Apply: 5 * The Status of the Individual Program Elements will be Indicated by: S - Satisfactory NA - Needs Attention DNA - Does Not Apply deg 02-22-90 V. HEARING CONSERVATION AUDIT CHECKLIST LOCATION _______________3613 PLANT Avon Lake Tech. Center O.K. Needs Attn. 1. All jobs with an eight hour TWA exposure _X of 65 dBA (50% does), have been identified. 2. Noise hazardous areas have been posted. __________________ 3. A formal list is available at the plant specifically designating hazardous and non-hazardous noise exposure jobs. _X 4. Records are available showing monitoring _X results for those jobs that were monitored. NOTE: A copy of monitoring results should be sent to D/0020 in Akron. The plant must retain its records for at least two years (OSHA). 5. When employees working on noise hazardous jobs are monitored, they are informed of the monitoring results (OSHA). _X 6. Engineering and/or maintenance efforts have _________X been directed to reducing noise in those areas/jobs with an eight hour TWA exposure of 90 dBA or greater (100% dose) (OSHA). NOTE: Details of this effort must be documented. (Although noise enclosures and other treatments are used, noise should be engineered out of equipment.) 7. Hearing protection is worn in all noise hazardous areas. _X 8. Hearing protectors in use are capable of X ______ ____ reducing employee noise exposures to below 85 dBA (NOTE: "NRR" or attenuation factor on hearing protector package. Consult with D/0020 in Akron if more information is needed). 9. Employees are provided a choice of two or _X three different types/varieties of hearing protection (OSHA). Need Help 3623j-1 NGC 12990 V. HEARING CONSERVATION AUDIT CHECKLIST (continued) 10. Personnel working at noise hazardous jobs receive annual training which includes at least the following information (OSHA). ______ a. The effect of noise on hearing b. The purpose of hearing protectors, the advantage/disadvantage and attenuation of various types, and instructions on selection, fitting, use, and care c. The purpose of audiometric testing and an explanation of the test procedures (The past training program was not acceptable. A program covering all aspects has been drafted and will be implemented in the 2nd quarter of 1990.) 11. Care is exercised to insure a proper initial ______ fit and correct use of all hearing protectors (OSHA). NOTE: With inset-type hearing protectors (ear plugs), it is important that the ear canal be clear and free of impacted wax. The ears should be examined for impacted wax before plugs are fitted. If impacted wax is found, it should be removed by a nurse or physician. Any employee complaining of an ear problem should be referred to medical personnel for examination. (Avon Lake medical is qualified to handle, but more staff is needed in order to accomplish. This program is being implemented during annual physicals.) 12. Audiometric examinations are provided for: a. All new hires (pre-employment) X b. Transfers to noise hazardous jobs. Jobs have been identified and program has been implemented. ______ c. Employees working on noise hazardous jobs (annually) X NOTE: Details for conducting proper audiometric exams are provided in BFG's OHP Manual, Section 5.05. X X ___ _X ___ 2- - Noe 12991 13. Audiograms are permanently retained for each employee. X ______ ______ 14. Employees with audiograms showing a standard threshold shift (STS) are notified of this fact in writing within 21 days (OSHA). NOTE: Employees showing a STS can be cetested within 30 day6. X _______ ______ 15. Employees exhibiting a STS are refitted with hearing protection and retrained in its use (OSHA). NOTE: Hearing protectors with greater attenuation may be needed. X ______ ______ 16. Employees showing shifts in their hearing are provided follow-up counseling based on the BFG quarterly Audio Action Report and Section 5.0-5 of the OHP manual. X ______ ______ 17. * The audiometer in use satisfies requirements of the ANSI standard S3.6-1969. x ______ ______ IB.* A biological calibration is performed daily on the audiometer before use. NOTE; Results of these tests must be kept on record for at least one year. (Electronic is used and this is appropriate.) X ______ ______ 19.* An accoustic check is performed on the audiometer annually. NOTE: Audiometer must meet requirements of ANSI S3.6-1969. (daily) x ______ ______ 20.* An exhaustive calibration of the audiometer is performed at least every two years by the manufacturer or his approved agent. NOTE: (#18, #19, #20) Results of all checks and calibrations must be kept on record. X ______ ______ 21. A copy of the OSHA noise standard is posted in the workplace or is available to employees. A notice of availability has been posted on the bulletin board (OSHA). x ______ ______ 22. Any information provided by OSHA pertaining to the standard is made available to affected employees. X ______ ______ 23. Questionnaire answered by: Name Jim Griffin Title Supervisor Safety and Health Plant # Avon Lake Technical Center *Numbers 17. 18. 19. 20 - Where an outside audioaetric testing service is employed, it must be established that these requirements are satisfied. 36233-3 NGC 12992