Document RjywK8enEGebGp2v2wggyG9gE

October 26,1990 TO: Glenn Higby FROM: Dan Gleghom LOUISVILLE -INDUSTRIAL HEAl^H'AUDIT Enclosed is the final report of the Industrial Health Audit conducted in your facility by Herra tfalternate, Mike DeMent and myself during the period of August 20 through August 24, 1990. I would like to thank you for the hospitality afforded us during our visit to your facility. You are fortunate to have Ron Martin on your staff. His leadership has brought your Industrial Health Program a long way. The ground work laid by Alice Simpson is a good basis for a continuing Industrial Health Program in your facility. I believe Susan Panas is a capable person who needs some Industrial Hygiene Training in order to continue this work and expand upon it. During our audit, we pointed out conditions that violated BFGoodrich or OSHA Standard or were inconsistent with good health practices. It should be noted, even though you may he taking corrective action on an Item, if the item is considered to be in violation at the time of the Audit it will be indicated as such. The facility was rated with 73 "satisfactory", and 12 "needs attention" items. The report format is laid out for you to write in your abatement program and indicate the status as Complete, In-Progress or Ho Action. A progress report giving the status of items IH-1990-7 and IH-1990-9 requires attention and are due 60 days after receipt of the report and all other items are due as indicated. The report included the following: I II III IV V Favorable Observations 1990 Items to be Corrected Industrial Health Program Rating Hearing Conservation Audit Checklist Facility Inspection Tour Dan Gleghom DEG/JS audlvle cc: D. Dimas - CHQ R. J. Grahek/C. J. No sal G. F. Krcmar/K. H. Lee, Jr. E. C. Martinelli/W.. F. Patient M. DeMent H. Waltemate 12478 LOUISVILLE INDUSTRIAL HEALTH AUDIT August 20 - August 24, 1990 Favorable Observations 1. Your Industrial Health Training Strategy is outstanding. The use of the Safety and Training Supervisors is an excellent idea which should give each area more responsibility for and ownership of the health concerns. 2. Your Contractor and Visitor Orientation Program is outstanding. The fact that every visitor must receive the orientation, including the Auditors, speaks well of your approach to this issue. 3. The Medical Surveillance Programs for potentially hazardous exposures are administered very carefully by Mary Duffy with follow-ups and corrective action when questionable or high biological results are reported. The Medical Records are some of the best I have seen during my audits. 4. It appears you have a good working relationship with Dr. Creech. He understands your facility and is interested in providing care for your employees. 5. Your Laboratories are in excellent condition and are well along their way to meeting the, OSHA 29 CFR 1910.1450, "Occupational Exposures to Hazardous Chemicals in the Laboratory" Standard. 6. Your Breathing Air System appears to be in excellent condition. It meets all OSHA and BFG Engineering Standards and I was pleased to see the condition of your units and overall program. II. 1990 Items to be Corrected 4 IH-1990-1 Response Your Quarterly Industrial Health Reports must be brought up to date and continued on a regular basis. The next report should be submitted no later than January 15, 1991. IH-1990-2 Response S tatus Completed ___ In-Progress No Action Your revised strategies for Industrial Hygiene Monitoring need to be implemented. The plan you submitted to me looks like a positive approach. Please advise me your initiation of the plan and time table for completion of the first Priority Group by December 15, 1990. S tatus ___ Completed ___ In-Progress No Action -fjGC IH-1990-3 Response There is a new Audiometer and Acoustical Ear on order for your Audiometric Testing Program. Please indicate that this equipment has been installed, calibrated and is functional by November 30f 1990. IH-1990-4 Response Status ___ Completed ___ In-Progress No Action Mary Duffy needs her Training and Certification in Spirometry and Audiometric Technician renewed. This training should be completed prior to your annual Respiratory and Audiometric Physical Examination Programs. Please advise the schedule for providing this training and certification by November 30, 1990. S ta tus __ Completed ___ In-Progress No Action NGC 12481 IH-1990-5 Response 6 The results of the Audiometric Examinations, including Standard Threshold Shifts, need to be communicated to the Safety and Training Supervisors so that they can inform the affected employees and take corrective action in their areas. Please indicate your procedure and time schedule to implement this program by November 30, 1990. IH-1990-6 Response Status ___ Completed ___ In-Progress No Action A copy of the Hearing Conservation Standard, OSHA 29 CFR 1910.95 (or the Kentucky equivalent), must be Posted. Please indicate that you have Posted this or instructions on where the document can be found by November 16, 1990. Status Completed In-Progress No Action IH-1990-7 7 The OSHA Hazard Communication Standard, 29 CFR 1910.1200 (f), requires that hazardous chemical materials be Labelled. This includes Hand Weighs. Your system of Labelling Hand Weighs appears to be in compliance when the materials are first weighed out. Materials returned to the weigh area from the. production area had lost their identity. Please advise your strategy for correcting this item. Response S tatus ___ Completed ___ In-Progress No Action IH-1990-8 Mike Warfield is updating your VCM Training. Please indicate your schedule for the training update and Training completion by December 15, 1990. Response Status ___ Completed ___ In-Progress No Action IH-1990-9 You have done considerable work on your Job Exposure Inventory. Please provide me an update on your Job Exposure Inventory. Response S tatus ___ Completed ___ In-Progress No Action IV. CHEMICAL GROUP INDUSTRIAL HYGIENE PROGRAM BATING LOCATION: Louisville Date of Audit: August 20-24, 1990 RATING INDUSTRIAL HYGIENE PROGRAM ADMINISTRATION Industrial Hygiene Coordinator S Named NA Knowledgeable S Walk-throughs Periodic Industrial Hygiene Program Reports NA Timely NA 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 MSDS S Committee Established S Available S Employees Trained to Use Reply to Industrial Hygiene Audits S Initial S Final Report s NA DNA DNA Training Hazard Communication Vinyl Chloride Lead Acrylonitrile S S S S S S s s s s s s s DNA s DNA S NA S S s DNA S S Respiratory Procedure Written Selected per Hazard Training Fit Testing Medical Examination Cleaning Storage Inspection Approval Usage Asbestos Handling and Disposal Sources Identified Monitoring Medical Examination Demolition and Removal Protective Coating Written Industrial Hygiene Sampling OSHA Compliance Hazard Evaluation Special Requests Sample Procedures Analytical Procedures/Cross Check Program Employee Interview Hearing Conservation 21 Total (See Checklist Attached) 3 Total (See Checklist Attached) Radiation Hazards Identified and Labelled License Requirements Records Dosimetry Program Periodic Leak Check Radiation Protection Officer ww S S S S S S S DNA Ventilation for Health Hazard Control Periodic Flow of Maintenance Checks Lab Hoods Yearly Flow Checked Rating of Flow-Rate Posted Modifications Reviewed New Systems Reviewed Leak Detection Written Area Monitoring Response Leak Repair Control I. H. Equipment Calibration Audiodosimeters Daily Calibration Laboratory Calibration S S DNA S S S S -S S Sound Level Meters Daily Calibration ' Laboratory Calibration/Three Years Acoustic Field Calibrators Every Three Radiation Detection device - Annually Area Monitoring Devices Personal Monitoring Pumps Years Laboratory Safety Lab Hoods Adequate for Hazards Lab Procedures Reviewed Personnel Protective Clothing and Equipment 11 Total Satisfactory: 83 Needs Attention: 12 Does Not Apply: 8 The status of the individual program elements will be indicated by: S - Satisfactory NA - Needs Attention DNA - Does Not Apply V. HEARING CONSERVATION AUDIT CHECKLIST LOCATION 1802 PLANT LOUISVILLE 1. All jobs with an eight hour TWA exposure of 85 dBA (50% does), have been identified. Needs Needs O.K. Attn Help X _________ ____ 2. Noise hazardous areas have been posted. X _____ _____ 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 results for those jobs that were monitored. NOTE: A copy of monitoring result should be sent to D/0020 in Akron. The plant must retain its records for at least two years (OSHA). X _____ _____ 5. When employees working on nose hazardous jobs are monitored, they are informed of the monitoring results (OSHA) X _____ _____ 6. Engineering and/or maintenance efforts have been directed to reducing noise in those areas/jobs with an eight hour TWA of 90 dBA or greater (100% dose)(0SHA). X _____ _____ NOTE: Details of this effort must be documented. 7. Hearing protection worn in all noise hazardous areas. X _____ _____ 8. Hearing protectors in use are capable of 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 three different types/varieties of hearing protection (OSHA). X _____ _____ X HEARING CONSERVATION AUDIT CHECKLIST - CONTINUED Personnel working at noise hazardous jobs receive annual training which includes at least the following information (OSHA) . X a. The effect of noise on hearing b. The purpose of hearing protectors, the advantage 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 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 employees complaining of an ear problem should be referred to medical personnel for examination. X Audiometric examination are provided for: a. All new hires (pre-employment) X b. Transfers to noise hazardous jobs. _____ 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. Audiograms are permanently retained for each employee. X Employees with audiograms showing a standard threshold shift (STS) are notified of this fact in writing within 21 days (OSHA). X NOTE: Employees showing a STS can be retested within 30 days. V HEARING CONSERVATION AUDIT CHECKLIST - CONTINUED 14 15. Employees exhibiting a SIS 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. 17.* The audiometer in use satisfies requirements of the ANSI standard 3.6-1969. X______________ X______________ 18.* A biological calibration is performed daily on the audiometer before use. (electronic calibration is performed daily) NOTE: Results of these tests must be keDt on record for at least one year. X______________ 19.* An acoustic check is performed on the audiometer annuallv. NOTE: Audiometer must meet requirements of ANSI S3.6-1969. _x_______________ 20.* An exhaustive calibration of the audiometer is performed at least every two years by the manufacturer or his aooroved acent. NOTE: (#18, #19, #20) Results of all checks and calibrations must be kept on record. 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______________ ____ X _____ 22. Any information provided by OSHA pertaining to the standard is made available to affected employees. X______________ 23. Questionnaire answered by: Name: Mary Duffy Title: Nurse Plant: Louisville ^Numbers 17. 18. 20 - Where an outside audiometric testing service is employed, it must be established that these requirements are satisfied. NGC 12490 lb VI. Facility Tour 1. Compounding a. Hand Weighs are not individually labelled. OSHA 1910.1200 (g) requires materials be labelled. b. There are unmarked Hand Weigh bags with no indication what is in them. c. 2nd level - Dust Masks are stored properly. d. 3rd level - Breathing Air line is painted but not labelled. e. 4th level - Breathing Air lines are painted and marked. There are covers over the quick connects to keep the dust out. f. 2nd level - Breathing Air line needs repainted and labelled. g. SW corner - Tank without any indication what is in it. 2. Laboratory a. Laboratory Chemical MSDS Books need a material List [1910.1200 (e)(i)j. b. Butadiene Sample Bombs need Hazard Labels. 3. LPA a. Poly Building has a Laser sign on the door. - The sign should be removed or training and personal protection instituted for persons entering the building. b. Breathing Air lines on the Column Feed Tanks need to be relabeled. (Painting is in progress) c. SCBA (Scott) at Bldg 140 has a dirty mask and no indication of inspection. d. SCBA (Scott) at SW corner of the Dryer Bldg is OK. e. Breathing Air lines at Tank 1G needs Labelled. NGC 12491 16 A. a. The Breathing Air System meets Standard. Air is monitored for Butadiene, Acrylonitrile and Total Hydrocarbons at Bldg 169 and VCM at Bldg 121. This is a good system. 5. Arrowhead a. MSDS Book needs Chemical List. Hazard Warning Labels DEG/JS audlvle I N T E RO F F 1 C E MEMORANDUM Date: From: Dept: Tel No: 12-L>ec-1990 12:04pm EST PANASS panass@lvl.c@mrgate@cle TO: TO: SUHAY, JAN@A1 GLEGHORN, DAN@A1 Subject: Audit response Dan, 1 received a copy A formal response January, however, of the Louisville Industrial Health Audit Report yesterday, to your questions will be submitted to you sometime in I thought you would like to know where we currently stand. IH 1990-3: The new audiometer and acoustical ear were calibrated on May 11, 1990 and installed after the dispensary was completed. IH 1990-4: University audiometry Mary Duffy is scheduled to be retrained in spirometry at the of Cincinnati on February 4-6, 1991. She has scheduled training at the University of Kentucky in March. in IH 1990-5: Effective immediately, a copy of an employee's STS will be forwarded to the Safety/Training Supervisor of his/her department. xH 1990-6: Notice of how to obtain a copy of the Hearing Conservation Standard is posted in the dispensary lobby. If you have any other questions just call. Susan Panas