Document KJ2m4qbN0rqjzaYgOrBnmwjgr

i\ *vr i* To: C. F. Rush cc T. J. Harmon D. M. Josef, M.D. J. Pettigrew H. T. Procter Subject: Health and Safety Audit of Lorain Asaeobly Plant The combined health and safety audit of Lorain Assembly Plant was conducted on June 8, 9 and 10, 1983. The team Included Ms. C. B. Gdula, R.N., Corporate Medical Administration, Mr. J. W. Dillard, Corporate Safety Engineer, and Mr. R. L. Wabeke, Supervisor, Industrial Hygiene Services. Mr. J. Pettigrew, Division Safety Engineer, attended the audit. The audit consisted of an entrance interview, audit and'closing conference. We regret that a plant walk through was cancelled by the Assistant Plant Manager because of his time constraints. Individual plant tour6 were made by the Corporate Safety Engineer and the Supervisor of Industrial Hygiene Services. MANAGEMENT SUMMARY AND RECOMMENDATIONS . The medical staff is knowledgeable and efficient. Patients are processed through the Medical Department quickly. Nurses are given considerable respect and admiration by other employees. . The Medical Department is well organized and time is well utilized. The plant physician sees many patients and evaluates many job6. . The nursing staff is below corporate staffing recommendations. Per corporate standard, there shoifld' one R.N. to six hundred employees. , . Medical surveillance exams are beinfe properly conducted. Because of the recent selection and scheduling of several departments for audiometric exams, a large number of these will be shown as overdue. These audio exams are currently being performed. . Storage of records and supplies is Inadequate. Due to the small facility, records and supplies are stored in any available location -- treatment rooms, etc. A number of records are stored in the plant with other departments' records (Compensation and Personnel). This procedure does not assure confidentiality and, in addition, some records have been stolen. 3007 C7=>6 PRODUCED BY FORD SCF-FORD-3339 IT*" Page Tiro July 5, 1963 Summary (continued) . S' . Extremely good rapport is present with medical and other departments of Industrial Relations and the Union. An ln-plant alcohol/drug abuse program Is being successfully conducted at Lakeland Institute. . With the exception of five minute safety talk6, documented training Is provided at required intervals. . Safety Nontechnical Bulletin #12, Factors to Consider In Staffing Safety Engineers, should be reviewed as the current staffing of Bafety engineers 18 Inadequate In view of current production levels and plant employment population; ' . Plant management support and Involvement In the safety program Is commendable. . General and local exhaust ventilation deficiencies are present. . Potential for exposure to asbe6t06 fibers exlst6 In the hl-lo and tug tractor maintenance area becauae of unsatisfactory dust cleanup practices. . Bird droppings In the plant constitute a potential health problem. . Bearing protection devices are Inconsistently worn In hazardous noise areas. . Some employees are wearing Improper respirators or, In some csse6, no respirators for specific hazardous exposures. . Inadequate posting of confined space entry and corrosive chemical use areas wa6 Identified. . A portion of the Caustic Building Is under-illuminated. . Some employees are wearing Inappropriate eye protection when handling corrosive chemicals. RECOMMENDATIONS Medical . Addition of nursing staff to conform with the corporate standard la recommended. When case load exceeds 50 ca6e6/nurse, additional staffing should be considered. . Expansion of the medical department, as planned In 1979, should be considered to allow for proper storage of records and supplies. 3DC7 07*7 PRODUCED BY FORD Page Three July 5, 1983 RECOMMENDATIONS (continued) . Fora 15130's, the Case Secord of Occupational Illness and Injury, should be filed separately - not In the medical jacket. Through this method, confidentiality is preserved and records remain at the location where the Injury or illness occurred. Dispose of outdated narcotics in proper manner. . Provide double lock containers for control drugs. . Send Inactive records to Highland Park as outlined In the Corporate Records Retention Manual. . Perform dally biologic audiometric check. Obtain background 6ound measurement of audio booth. . Maintain log of these procedures. . Post "Standards of Protection Against Radiation" in x-ray. . Replace missing emergency lights. . Illness and injuries that sre treated with prescription medication must be reported on the OSHA Log. . Locate and correct oxygen leak present in vail between EKG and storage rooms. . Purchase of an automatic x-ray processor would be time efficient. . Purchase of pocket panic button for nurses for personal protection and emergency assistance, if needed. . Suggest purchase of numerous emergency supplies. Basic drugs that are nece66ary to treat all medical emergencies according to the standard of medical practice expected In the community should be standard In the medical department. The purchase of a defibrillator and training of the medical Btaff in its proper uBe is recommended. Saf ety . Five minute safety talks must be given on a periodic basis and documented. Additional emphasis must be given to machinery guarding and utilisation of existing machinery safeguards. Thl6 should Include development and implementation of a program requiring dally Inspection by supervisors, periodic inspection by the safety engineer, and a means to assure that all new and reconditioned machinery and equipment Is properly guarded before U6e. S00? 079S ' PRODUCED BY FORD Page Pour July 5, 1983 RECOMMENDATIONS (continued) Industrial Hygiene . Correct general and local exhaust ventilation deficiencies (see attachment). . Vet clean up methods and a vacuum cleaner dust removal must be utilised In the hl'lo and tug tractor maintenance area. Brake maintenance employees must be placed on the asbestos medical surveillance program If exposures have exceeded the OSHA standard. . Eliminate the bird population in the plant. . Enforce the wearing of hearing protective devices in noise hazardous areas. Prohibit the wearing of radio headsets. Measure nol6e levels at the exit of the van water test spray booth. . Ensure that appropriate respiratory protection is used and worn properly. A written respiratory protection program must be developed In accordance with OSHA and Company directives. . Confined space entry and corrosive chemical handling areas should be clearly posted. . Poor lighting of the catwalk near the lye tank In the Caustic Building must be improved. Specific safety, medical and industrial hygiene details are included in this report as attachments. Your time bound action plan for correcting any deficiencies snd responding to the recommendations should be submitted to Carole B. Gdula, R.N., Employee Health Services Department, Suite 900, Parklane Towers West, by August 5, 1963 and, if necessary, each 30 days thereafter until all items are corrected. Attachments Duane L. Block, M.D Medical Director o007 0799 ' PRODUCED BY FORD Lorain Assembly Plant Medical Overview of Operation the medical facility at Lorain Assembly vaa the original one designed in 1959 for a population of 5,000. Plana for expansion were made several years ago but tbeae plans were postponed due to economic conditions. Current plant population is about 6,000. The medical department la extremely congested. Supplies and records are stored In various areaB, Including patient treatment rooms. EKG's are taken in a small room used for supplies and Inactive record storage. Numerous medical records have been stolen while patients waited for ERG*a. Splints, supplies and a wheel chair are stored in an emergency treatment room. The suture room has an outside entry thst the ambulance uses. The addition of nursing staff to conform with the corporate standard of one R.N. to six hundred employees is recommended. When the case losd exceeds 50 cases/nurse, additional staffing should be considered. The current plant population and patient census 1b: Shift Hourly Salary Total Population Case Load # 1 Shift # 2 Shift I 3 Shift 104 2,873 2,319 7 329 182 111 3,202 .2,502 5,814 100 200 150 Nursing staff are scheduled at 10 hours/day at the hours: #2 Shift #3 Shift 1 R.N. 1 R.N. 1 R.N. 1 R.N. 5:30 a.m. 7:30 a.m. 4:00 p.m. 6:00 p.m. - 4:00 P - 6:00 P D s - 2:30 a.m. - 4:30 a.m. Lorain Assembly Plant views extended medical leaves, mainly psychiatric related, as the most serious problem. During March, 1983 the plant had 37 employees on medical leave due to "nerves" (3 of these have been on medical leave since 1979). labor Relatlone/Hourly Personnel state the employees become ill when reduction in force is anticipated and recover when funds expire or the plant reaches the employees* recall seniority. The plant expressed a need for advice in correction of this problem. Charting on records la well documented. Multiple cases were treated with prescription drugs that were never reported on the 0SHA Log. Other omissions on the Log were occupational dermatitis cases and injuries with chipped teeth. Form #5130, the Case Record of Occupational Illness and Injury, is filed in the medical jacket. Physician reports for medical leaves are sent directly to Dr. Josef. However, the personnel department ha6 access to the medical jacket when determination for justification of time is necessary; this practice is a breach of medical confidentiality. ' An incident occurred 6/9/83 where a cleaner entered medical via use of his own key. The night nurse was leaving the x-ray room and preparing to lock the facility when the cleaner appeared. Management was unaware as to the possession of the cleaner's key or hie need for entry at that time. Closer control will be instituted. 50C7 C300 ' PRODUCED BY FORD -2- We have found that early opinions on psychiatric cases are an invaluable Mans of retaining control of caaea. Rehabilitation hoapltala are uaeful In evaluating psychiatric problems. Ve mould encourage the use of hospitals in the Cleveland area, e.g. Cleveland Clinic, for third party consultations. 3007 0801 PRODUCED BY FORD Lorain Assembly Plant SAFETY PROGRAM REVIEW AND RECOMMENDATIONS Thla review was not an In-depth Inspection of each operation but rather a general progran review and plant walk-through to determine the adequacy of plant programs and to obaerve work practices and conditions within the plant for compliance with established Company, division and governmental safety program guidelines. Messrs. D. Obrlnger, Safety Engineer, and J. Pettigrew, Division Safety Engineer, accompanied and provided assistance to this part of the review. Aspects of the plant program which were Impressive and which are concurred in as being Important follow: 1. Documented training In the following subjects has been provided at the designated Intervals: . Power Lockout . Boxcar and Bulkhead Safe Practices . Servicing of Gas Fired Equipment . Confined Space Entry Safe Practices ' Further review of safety related training programs revealed that "Safety Review for Supervisors" was presented to supervisory personnel during 1962 downtime and that "Messages" was presented at individual group meetings a6 well as continuous viewings within the plant cafeteria at lunch periods. 2. The excellent safety program support and Involvement by you and your managerial Btaff members are to be commended. Examples of support and Involvement are: I . Participation of the Assistant Plant Manager, Industrial Relations Manager, and safety engineer In the Good and Welfare Committee to resolve health and safety issues. . . Plant safety tour6 performed by you and the assistant plant manager. . Periodic presentations by the safety engineer and routine safety presentations by the Industrial Relations Manager to the plant Operating Committee. 3. Housekeeping throughout the plant vas very good and no permanent encroachments were observed in the well designated aisles. 4. Inclusion of the safety engineer In the review/approval of new equipment and processes or modification of existing system la to be commended. Discussion vlth Mr. Obrlnger Indicated that the plant uses a plant developed "Tooling Check-Off Sheet" for documentation of this program. In addition, many basic program elements have been Implemented to provide a safe work environment for employees of the Lorain Assembly Plant. Individual safety items observed during the plant walk-through which require local actions were noted by Mr. Obrlnger. Additionally, a cassette tape c>007 0oD2 ' PRODUCED BY FORD i' -2- detailing y review findings will be forwarded to Mr. Obrloger for plant retention. The following items end recoaaendatlone, while not prioritised by nunber, are cooaldered necessary for a sore effective program at the Lorain Assembly Plant) 1. Currently, the plant la operating two ten-hour production shifts six days a week with a plant population that approaches 6,000 employees. The plant safety progran is being administered by a single safety engineer on the day shift and on the afternoon shift by a labor relations representative on an as needed basis. Attached Industrial Halations Non-Technlcal Safety Bulletin No. 12, Factors To Consider In Staffing Safety Engineer Positions, provides the guidelines for safety engineer staffing requirements. Based upon these guidelines and current production < schedules, it is strongly recommended that additional full-time safety engineering personnel with denonetrated capabilities within the safety engineering profession be assigned to administer the Lorain Assembly Plant safety progran. , 2. Additional emphasis oust be given to aachinery guarding and the utllltlatlon of existing aachinery safeguards. Examples to be corrected are: a. The use of a single two-hand controls for work stations with two employees potentially exposed to equipment operation near Columns NN-19 and JJ-25. b. The use of a single control button to cloBe three clamping fixtures for spotwelding operations at Column NN-19. c. The trim press located at Column 0-13 requires ring guards and appropriately color coded actuation buttons for the two hand controls. d. The Cinclnnatl-Mllacron Bpot welding line (Column LL-20) and other automated lines have inadequately guarded points of operation and/or Inadequately restricted aeans of access. e. Numerous power transmission guards were removed and lying adjacent to the drive systems within the second floor area of the Comnerclal Department. f. The Niagara power shear located in the sheet metal shop is not of the anti-repeat type and doea not have guarding for the cutter blade, hold down clamps or the foot treadle. To improve upon the plant machinery guarding program, the following items are recommended: a. A program should be developed and Implemented to require dally inspections by esch supervisor of equipment and conditions within their area of responsibility. Results should be documented and appropriate corrective actlon(s) taken to eliminate noted discrepancies. ?007 ce?3 ' PRODUCED BY FORD 3 b. A program should be developed and Implemented to require the safety engineer to perform periodic detailed inspections of machinery, processes and modifications when they occur. c. Aa an interim program objective, the plant should continue correction of machinery guarding deficiencies as noted In Mr. Pettlgrev's July 1, 1982 Safety Program Review correspondence. 3. The formalised five-minute safety talk program has been discontinued as a part of the routine safety program. This program should be relnstltuted and appropriately documented. SCO? C?CH ' PRODUCED BY FORD INDUSTRIAL RELATIONS BULLETIN AMI------------- WLLnW^m* * 06/06/63 Safety - Son-Technical Factors To Consider In Staffing Safety Bsgineer Positions ' TKSOwiALrbgn--------------- ------ Employee Bealtb Services UPC*KDt* * DATVa> lev j - ....... .........- J ivLLftm *6 IP Ibis bulletin it intended to provide ettifing guidelinet for safety engineer position* to assure that each component ia staffed vith the number of pertonnel required to comply vith all government regulations and effectively adminiater Company polieiea, programa and procedurea. Functions of a full-time aafety engineer may include performing environmental sampling and monitoring materials usage, hut generally exclude fire control and security responsibilities. It ia recommended that: All Company facilities, regardless of the number of employees, have an individual who is assigned employee safety responsi bilities for the plant. This duty may be full or part-time as circumstances warrant. Plants vith 600 or more hourly employees have one full-time safety engineer. Facilities vith fever than 600 hourly employees consider a full-time safety engineer where extensive monitoring is required due to potential health and/or environmental hazards. Depending upon the nature of operations, an additional safety engineer be considered for the day shift (#2) vith a population of 1,500 or more hourly employees. . An additional full-time safety engineer be considered for other shifts vith 600 or more hourly employees. Considering die change schedules, stamping plants should evaluate the need for a safety engineer on the dl shift even though population may be below 600. Plant site, complexity and nature of operation, hazard of manufacturing or assembly processes, and potential health and/or environmental hazards are among the many factors warranting consideration in determining safety engineer staffing. 5007 C305 ' PRODUCED BY FORD lorain Assembly Plant .'t Industrial Hygiene Audit An Industrial hygiene audit v*i conducted at Lorain Aaeeably Plant on June 8*10) 1983. The purpose of this audit vae to evaluate environmental conditions, work practices, and processes In the plant that could adversely affect employee health or contribute to worker discomfort. Nr. San Obrlnger, Plant Safety Engineer, very cooperatively assisted during this audit. Elements of the audit Included appraisal of general plant and process ventilation, chemical handling practices, air quality, bearing conservation, respiratory protection, corrosive chemical vision conservation practices, Illumination, skin protection practices, sanitation, and heat stress protection. Overall, the plant's Industrial hygiene programs are excellent. Noteworthy are the local exhaust ventilation systems and control of employee exposures to airborne contaminants. Exposures to overspray mlBt and solvent vapors In paint booths were controlled as was exposure to fine-wire welding fume and gases. ` Deficiencies in some Industrial hygiene programs were noted, however, and should receive attention. Ventilation Whereas overall plant ventilation Is excellent, a slight negative pressure condition exists. While insignificant during warm months when large doors are open, this could be a problem during vlnter leading to breathing rone air quality problems. Plant engineering should assure provision of sufficient makeup air to balance all supply and exhaust systems to within ten percent of each other. Consideration should be given to Installing silhouette 6lot exhaust ventilation systems at the exit of A and B booth enamel drying ovens. Excessive paint emissions and volatile organic hydrocarbons are emitted producing stains on celling and walls In the area. ThiB Is an Issue of employee concern. Engine exhaust emissions (especially 5.0 liter BO) at the passenger roll test appear excessive In spite of substantial dilution ventilation from a nearby open bay door. It can be expected that this condition will worsen during winter. A recent industrial hygiene study In this area has documented employee exposures to air contaminants. Improved ventilation Is Indicated for this area. The grlllwork on the exhaust system at floor level on the south vail should be periodically cleaned of the substantial dust accumulations. Two exhaust ventilation systems were Inoperative In the Paint and Oil Bouse. One of these was at the laboratory testing area and the other was In the large paint tank mixing area. It la Imperative that these systems operate at all times to control combustible/flammable solvent vapors and employee exposures to toxic airborne contaminants. Installation of an alarm system Is suggested to Indicate when ventilation systems malfunction. iOZ7 !>S06 ' PRODUCED BY FORD An excessive Mount of vster vapor Is emitted from the wash booth at V-22. Better enclosure and ventilation is indicated to control exceaslve humidity and eaployee heat atresa discomfort in adjacent work areas. local exhaust ventilation at the commercial line vheel rim apray painting operation was poor. Paint overspray mist and vapor vaa insufficiently captured requiring the operator to wear a respirator. It was stated that inappropriate solvents had been selected for paint formulation that day leading to extreme eye, naBal, and upper respiratory irritation. Ventilation must be sufficient to control exposures in event of Improper paint solvent mixing. Installation of a ventilated drying tunnel is Indicated to capture fugitive solvent vapor emissions from vheel rims as they dry and exit the spray booth. Asbestos Potential for exposure to asbestos fiber exists in the hi-lo and tug tractor maintenance area. A vacuum sweeper approved for asbestos fiber should be purchased to remove residual asbestos from brake drums before new brake shoes are Installed. Thl6 vacuum sweeper should be made available to maintenance personnel who repair and Install new brakes in the hi-lo and tug tractor vehicle maintenance area. Employees must be instructed not to use compressed air wands to blow residual asbestos dust and fiber off brake shoeE and drums. Vet methods! vacuuming, respiratory protection, and ventilation must be used to control exposure to asbestos. Brake maintenance employees should be on the asbestos medical surveillance program. Illumination No large area deficiencies in plant illumination were observed. However, the catwalk adjacent to the lye tank in the Caustic Building is poorly illuminated. Tripping hazards and corrosive chemicals in thl6 area mandate better lighting on this walkway. Sanitation Overall plant sanitation and hygiene is excellent. No deficiencies other than minor housekeeping were noted in cafeterias, food preparation areas, canteens, locker rooms, and washrooma/toilets. There is an excessive bird population in the Butler Building. Until birds are eliminated, vet cleaning of floors is indicated to minimise airborne spore distribution from bird droppings. Even though this storage facility is not occupied full-time, steps should be taken to control roosting in this area. In our experience, flashing strobe lights, sirens, chemical deterrents, and other commercially available techniques have little effect. It is recommended that someone from plant security kill several blrdE in the building with an air powered pellet rifle. Carcasses should remain on the floor for the shift. Typically, birds will not return. In our experience, other ventures with commercial pest control agencies are expensive and usually unsuccessful. S007 0507 ' PRODUCED BY FORD -3- Hearing Conservation > There was Inconeletent use of hearing protector# at locations where nolae dose waa excessive. For example, an employee In the rough grind booth was not using protection. All employees nuet consistently wear approved Buffs or pluga at designated hearing conaervatlon locations. Several employees were observed wearing radio headsets although not In hearing conservation areas. Concerted management effort must be undertaken to eliminate uae of these devices In compliance with issues raised In Industrial Hygiene Bulletin No. 36. Nolae exposure should he reevaluated at the exit of the van water test spray booth and at the exit of the passenger water leak test spray booth at Column G-3. The noise dose at these operations appeared excessive for employees Involved In hand wlpe*-off operations. If Indicated, they should be Included In a hearing conservation program. Respiratory Protection Appropriate approved respirators are available for employee use. However, all elements of a respiratory protection program In compliance with OSHA standards and industrial hygiene guidelines are not In effect. Specifically, written programs must be developed for respirator use areas, and a procedure must be established to assure that the correct respirator Is dispensed to employees for the air contaminants of concern. In this respect. It should be noted that the paint sprayer at the eotmerclal rim line was using a particulate respirator for protection against paint solvent vapors. He was not aware that the respirator provided no protection against these contaminants. This serlouB deficiency must be corrected. Furthermore, the employee did not use both straps on his respirator. This prevents an effective face'to-mask seal. The Importance of a good seal must be reemphasised during respirator education and training sessions. Provision of organic vapor respirators to maintenance personnel In the Paint and Oil Bouse is advised during swabbing and cleaning operations. Brief exposures to high concentrations of solvent vapor in thl6 area could produce transient narcosis with possible Injury to employees. Vision Conservation Bye protection of choice Is the chemical splash goggle which Is superior to a face ableld for vialon conservation when handling or working near corrosive chemicals. Employees must be instructed to wear goggles when splashing of corrosive chemicals could occur. Such areas should be ao designated. The emergency chemical eyewash fountain In the Caustic Building collapsed during testing. Water supply must be restored to this fountain and corroded pipe replaced. It must be emphasized that eyewash fountains are secondary to consistent use of splash goggles In vision conservation areas. Employees who handle strong acids, alkalies, oxidizers, corrosion Inhibitors, mlcroblocides, and scale removers must wear splash goggles. We see little need for face shields In chemical handling areas at Lorain Assembly Plant. Air Quality Other than conditions mentioned In recent industrial hygiene reports, no obvious air quality problems were noted with exception of solvent vapor In the b0u7 ObGS ' PRODUCED BY FORD 4 Paint and Oil Bouse. It ia adviaable to document exposures to aolvent vapora in the paint kitchen. Arrangements will be made to have plant peraonnel conduct thia monitoring. Air sampling ia alao recommended to document aolvent vapor expoaurea of maintenance employeea who clean paint akimmera and aludge filtera. Confined Space Entry Confined apace labela on top of paint mixing tanka are illegible. Solvent haa washed paint off labels as a result of repeated cleaning. Labels should be relocated on the paint mixing ahaft motor houaing or on the aide of each tank. Skin Protection There was no evidence of excessive dermatitis at Lorain Assembly Plant in spite of potential contact with a vide variety of dermal irritants and aensitisers. One employee installing upper rear deck insulation on the passenger trim line at T-ll has skin irritation which might be associated with handling this fibrous glass product. This was discussed with Dr. Josef. Industrial hygiene practices for control of fibrous glass dermatitis as specified in Bulletin Mo. 31 should be reviewed. If these measures are unsuccessful, it is recounended that the supplier be contacted to topcoat their product so fibers are not released. Heat StTeBB No significant heat stressful work environmental conditions were observed. The area adjacent to the exit of enamel paint baking ovens va6 brought to our attention as an area of potential heat stress. Employees do not work in this immediate environment and, unless maintenance personnel must spend long periods at this location, we aee no need for environmental controls. Host heat at this area is radiant and would not be adequately controlled by exhauEt ventilation. The Industrial Hygiene Services Section will, as requested, assist in implementing these recommended industrial hygiene programs at Lorain Assembly Plant. SDC7 "09 PRODUCED BY FORD