Document mvyebLZGebG4vOVNxGOer7d

45. Hazard Communication Program (Regulatory/Company Policy) In reviewing the plant's hazard communication program and through tours of the plant and interviews with plant employees, we noted the following: a. A technician in the Paste area had not received hazard communication training prior to initial assignment. (Other employees could not recall having hazard communication training.) In addition, training records did not include content of the training or when the training occurred. [29 CFR 1910.1200(h)(1)(i-iii) and (h)(2)(i-iv)] / ^c t * Our written program requires that hazard communication training be conducted upon initial assignment and annually thereafter. We will review training records and assure that all employees have received hazard communication training for 1991. 12/31/91 b. The written hazard communication program lists the National Fire Protection Association (NFPA) as being the warning system utilized to convey hazard warning to employees. Six of eight employees interviewed could not explain the system. [29 CFR 1910.1200(e)(l)(i-ii)] * The NFPA labelling system is used for bulk storage labelling. New Jersey Right To Know labelling is used for all other materials. Knowledge and understanding of these systems is an ongoing training and review issue. Training content will be assessed and revised to enhance trainee awareness and understanding. 12/31/91 c. The written program does not define the NFPA labeling system which is used for hazard warning. [29 CFR 1910.1200(e)(1)] * The written program does have a general definition for the NFPA labelling system. The program will be revised to include a more detailed definition. t -r % * 8/31/91 30 NGC 12694 Audit Findings Several products were identified that were not on the Hytox Computer system or plant inventory. [29 CFR 1910.1200(g)(1)] * This item refers to two drums of lubricating oil found adjacent to Building 524. They have been added to the plant inventory and steps were initiated to have them added to the Hytox system. The plant has plans to add a '`Buyer" position. This position will provide more control over the entry of new chemicals into the plant. co-^t 9/30/91 e. At total of eight employees in Compounding, Large Poly, Paste Poly, Lab, Waste Treatment Plant, Maintenance, and Utilities could not readily use the BFGoodrich MSDS system without having access to BFGoodrich product code names and could not correctly locate information when asked. [BFGoodrich Company Policy] * The BFGoodrich MSDS system catalogs chemicals by an "AN" number, a number assigned by the Hytox System. Part of the MSDS sets available to all employees is an MSDS index which catalogs chemicals by AN number, product name, chemical name and BFG code number. You can't effectively use the BFG MSDS system without the index. Training in the use of the MSDS system is conducted annually. Complete 46. Acrylonitrile Training Program (Regulatory) In reviewing acrylonitrile training programs at the plant, we noted the following: a. Not all appropriate employees have received annual training; and [29 CFR 1910.1045(o)(l)(ii)] * Annual training for appropriate employees was scheduled for November and December, 1990. Completed in December 1990. Complete b. Annual training records were not available for all years in which the training was conducted. [29 CFR 1910.1045(o)(l)(ii)] * Some historical records were discovered after the audit. A personnel change occurred in 1990 and the location of all training records was not communicated to the person now responsible for maintaining them. Our training recordkeeping system will be overhauled. 12/31/91 31 NGC 12695 Audit Findings 47. Respiratory Protection Program (Regulatory/Good Management Practice) In reviewing the plant's respiratory protection program and through interviews with employees and tours of areas where respirators are used and stored, we noted the following: a. Employees are allowed to have facial hair (e.g.,sideburns, beards) when being fit tested and when wearing air-purifying negative pressure respirators. [29 CFR 1910.134(e)(5)(i)] * A facial hair policy will be developed, communicated and implemented 10'* } 9/1/91 b. Numerous respirator units were found face down, in plastic bags that were not sealed, and in an unclean condition. [29 CFR 1910.134(b)(6), .134 (b)(7), and .134(f)(5)(i) and (ii)] * Upon investigation, the units described here were obsolete and spare parts for respirators in Compound. They were disposed of or were stored in the proper manner. / ... Complete c. The breathing air system does not have low pressure alarms, and no records were available to verify that Grade D breathing air is supplied. [29 CFR 1910.134(d)(1) arid .134(d)(2)(ii)] * The plant breathing air system is currently supplied by two oil-free, centrifugal compressors. It is equipped with local and computer console low pressure alarms and a five minute reserve capacity for egress purposes. We will request breathing air quality certification from the compressor manufacturers 8/31/91 d. Respirators are not selected according to the guidance of American National Standard Practices for Respiratory Protection Z88.2-1969, which bases respiratory selection on hazard potential, efficiency of collection, immediate danger to life and health levels, and warning properties of contaminants to which the employee is exposed. [29 CFR 11910.134(c)]* c * The current selection criteria for respiratory protection omitted one type of respiratory protection. It has been revised. Complete 32 NGC 12696 Audit. Findings e. The respiratory protection program is outdated in that it does not reflect current job responsibilities for program administration. [Good Management Practice] * Written program will be revised and reissued to reflect current job responsibilities for program administration. Cen^f t*' 8/1/91 f. Fit testing records do not indicate the manufacturer or model number of the masks being tested. [Good Management Practice] * Fit testing recordkeeping form has been revised to include manufacturer and model number. <2.<W "*"7^ Complete A8. Hearing Conservation Program (Regulatory/Company Policy/Good Management Practice) In reviewing the facility's hearing conservation program and during tours of the facility, we noted the following: a. Several employees were observed not wearing hearing protection in areas that required hearing protection [29 CFR 1910,95(i)(2)(ii)] * The employees involved were contractors in Building 513. Contractors are required to comply with BFG Safety Procedures. This is an on-going enforcement issue and is being addressed through a new contractor evaluation process. 9^ Complete. b. * Noise Reduction Ratings (NRR) have not been calculated or evaluated for hearing protectors used in the plant. [29 CFR 1910.95(1)(2>] Noise reduction ratings have been calculated for hearing protectors in use in the plant. oV~> (0 Complete c. The current Noise Standard and Hearing Conservation Amendment was not present at the dispensary for the physician's use. [29 CFR 1910.95(1)(2)]* * The current Noise Standard and Hearing Conservation Amendment is now available in the dispensary. Complete 33 isiGC 12697 Audit Findings d. Data on file for the measurement of sound pressure levels inside the audiometric booth are incorrect. This makes exhaustive calibration also suspect. [29 CFR 1910.95(h)(1-5)) * The audioraetric technician who performed the calibration was consulted. He verified the sound pressure level measurements are correct and are in compliance with 29 CFR 1910.05(h)(1-5). e. The Hearing Conservation/Noise Method (.dated March 1982) lists employee sound exposure threshold at 90 dBA instead of the current BFGoodrich policy of 85 dBA. [BFGoodrich Company Policyl * Our recognized employee sound level exposure threshold is 85 dBA in accordance with current BFGoodrich policy. The "Hearing Conservation/Noise Method" dated March 1982, referred to in this item is BFG corporate industrial hygiene method 9.80. It lists both the OSHA threshold of 90 dBA and BFG's threshold of 85 dBA. f. The nurse does not have a current list of hearing protection devices (HPD) issued with calculated noise reduction ratings for use in counseling employees on the effectiveness of HPDs. [Good Management Practice] * The nurse now has a listing of hearing protection devices used in the plant with noise reduction ratings for use in counselling employees. g. Employee overexposures are not forwarded to the employee's medical file. [Good Management. Practice] * Our environmental technican has been maintaining monitoring records in his work area. Copies will be sent to the dispensary for inclusion in employee medical files 49, Monitoring Program (Regulatory/Company Policy/Good Management Practice) During our review of the plant's monitoring programs, we noted the following: a. The asbestos procedure does not use 0.2 fibers per cubic centimeter time weighted average (TWA) for permissible employee exposure limit. [29 CFR 1910.1001(c)(1) and 29 CFR 1926.58] Complete v Complete o<c Complete 8/1/91 fit 9v 24 NGC 12698 Audit Findings The asbestos removal procedure will be updated to reflect a 0.2 fiber per cubic centimeter time weighted average. 8/31/91 b. Vinyl Chloride samples are not being analyzed at an American Industrial Hygiene Association (AIHA) ' accredited laboratory or a laboratory that is equivalent by demonstrated means. [BFGoodrich Company Policy] * Vinyl chloride samples are analyzed at BFGoodrich1s industrial hygiene laboratory at Brecksville in accordance with a method validated by Andrew Fairlee and John Bom in 1985. Pam Lane is our current contact at Brecksville. 7^ Complete c. Hazard rankings are not utilized for developing a sampling regimen. (BFGoodrich Company Policy] * Hazard rankings will be included in Job Exposure Surveys to be completed. 9/30/91 d. The environmental technician performing industrial hygiene sample collection could not explain or demonstrate the use of the primary standard ' calibration device. (Good Management Practice] * New calibration and monitoring equipment has been ordered. The environmental technician will be trained in its use. 9/30/91 e. The primary standard for calibrating personal sampling pump flow was not a calibrated burette. [Good Management Practice] * The primary standard for calibrating personal sampling pump flow is a calibrated vessel. It was purchased specifically for the pump flow rates we use for personal sampling. New equipment has been ordered for sampling and calibration. 9^ 9/30/91 35 NOC 12699 Audit Findings I. Sampling and analyt-Lcal methods for vinyl chloride and acrylonitrile (NIOSH Method S-156) are not readily available at the facility to ensure that correct analytical techniques are utilized. In addition, the internal BFGoodrich sampling and analytical method for acrylonitrile is not current. [Good Management Practice] * Current sampling and analytical methods for vinyl chloride and acrylonitrile have been obtained. g. Vinyl chloride samples collected in 1989 and 1990 show 31 out of 284 samples above the permissible exposure limit (PEL); however, no trend analysis is being plotted on personal samples. [Good Management Practice] * Past personal sample results have been trended; new results will be trended annually. h. Gas chromatography results show averages above the PEL as well as high standard deviation in two locations in Building 513 for November. [Good Management Practice] * Two continuous monitoring points in Building 513 measure vinyl chloride concentrations in the main ventilation stack and above the building waste water sump. These points are measured to alert employees to potential fugitive emission problems so corrective action can be taken. i. Sampling and analytical methods used for polyvinyl chloride (PVC) dust were not signed or dated. [Good Management Practice] * The methods referenced here were written and used in the mid 1970's when we were doing nuisance dust monitoring. Vie no longer do this based on measured exposures and engineering improvements. These methods have been discarded. 50. Records Retention (Company Policy) The plant does not have a records retention policy that includes preservation of employee medical and exposure records, [BFGoodrich Company Policy] $f * We use the Corporate Records Retention Policy. Copies have been provided to the nurse and the safety department to insure compliance. 0^ 9Z- Complete <p? Complete Complete I>/C jv - ^ tJOv '9^ Complete 10 Complete 36 NOC 12700 Audit Findings 51. Laboratory Safety Standard (Good Management Practice) The plant laboratory has not developed a chemical hygiene plan to comply with 29 CFR 1910.1450, which becomes effective on January 31, 1991. * The laboratory is in compliance with the Laboratory Safety Standard as of 1/91. LOSS PREVENTION AND EMERGENCY RESPONSE 52. Fire Prevention Plan (Regulatory) During our review of the facility's fire prevention plan and fire prevention training records, we noted the following: a. The plan does not include a list of major workplace fire hazards and their proper handling and storage procedures, potential ignition sources,, control procedures and the type of fire protection equipment of systems that can control them. [29 CFR 1910.38(b)(2)(i)] b. Housekeeping procedures are not detailed to minimize fire risks and ease evacuation. [29 CFR 1910.38(b)(3)] c. Maintenance procedures for equipment and systems installed on heat producing equipment are not detailed to prevent accidental ignition of combustible materials. [29 CFR 1910.38(b)(5)] d. Three hundred and two out of 331 BFGoodrich employees and contractors have not received instruction in the fire prevention program. [29 CFR 1910.38(b)(4)] * All of the fire prevention elements referenced in items a. - d. exist and will be formally documented and consolidated into a single written plan. 53. Fire Protection Training (Regulatory) In reviewing training records and interviewing personnel, we noted that 323 out of 331 BFGoodrich employees and contractors did not receive annual fire extinguisher training to respond to incipient fires in the workplace. [29 CFR 1910.157(g)] * Fire Protection Training for all employees will be conducted. Complete j ^ / *^ 9/30/91 11/1/91 u * e_ 37 TSTOC 12701 .\ September 30, 1993 To: Herman Waltemate Cleveland From: Bill Fultz Pedricktown Subject: Pedricktown Industrial Health Audit - October 5-9, 1992 Attached is our fourth audit progress report. It gives the status of the items that Dan identified during the October audit as requiring attention. Our next progress report is due by 10/31/93. All items will be completed by then. (jJs C' cc: JoeBlackburn Pat Ferraro John Fletcher Jim Kiel Al Matyger Ed McKinley Art McMillian Dennis O'Keefe Carl Stolfo Bill Wagner Tom Worrell NGC 12702 PEDRICKTOWN 1992 INDUSTRIAL HEALTH AUDIT 1992 Items To Be Corrected IH--1992--2 OSHA 29 CFR 1910.1200 (f) (5)r Hazard Communication/ requires that each container of Hazardous Material be labeled. The following items must be corrected: 3. NFPA markings on the Resin Silos do not correspond to GVD MSDS requirements. Please advise your time table for correction of this item. Response 3. A purchase order was issued on 7^16/93 to change the NFPA markings on the resin silos. To be com pleted bv the end October Status __________ Complete X________ Incomplete _________ No Action IH--1992-4 IH-101 "Ventilation Section" deals with ventilation equipment designed for control of health hazards and requires annual ventilation flow and maintenance checks which are documented. Engineering Standard "ST--411" gives engineering and design standards for ventilation equipment. This item could be added to your maintenance PM system. Please advise me your method for handling this matter and the time table for initiation. Response An inventory of ventilation equipment designed to control health hazards has being developed. _Flow_ __ measurements have been completed and PM*s have been, entered into the system.________________________________________________ Status X________ Complete __________ In-Complete ____ No Action NOC 12703 HERM WALTEMATE BOB GRAHEK IWTO MAftailA&L JAN SUHAY November 1. 1993 To: Herman Waltemate Cleveland From: Bill Fultz Pedricktown Subject: Pedricktown Industrial Healths Audit - October 5-9f 1992 Attached is our final audit progress report. It gives the status of the items that Dan identified during the October audit as requiring attention. All items have been completed. / cd^ cc: Joe Blackburn Pat Ferraro John Fletcher Jim Kiel A1 Matyger Ed McKinley Art McMiIlian Dennis O'Keefe Carl Stolfo Bill Wagner Tom Worrell NGC 12704 PEDRICKTOWN 1992 INDUSTRIAL HEALTH AUDIT 1992 Items To Be Corrected IH-1992-2 OSHA 29 CFR 1910.1200 (f) (5), Hazard Communication, requires that each container of Hazardous Material be labeled. The following items must be corrected: 3. NFPA markings on the Resin Silos do not correspond to GVD MSDS requirements. Please advise your time table for correction of this item. Response 3. Markinas on the silos have been corrected. Status X Complete Incomplete No Action //V yv /Y)/f\ Zr$ June 30. 1993 To: Herman Waltemate Cleveland From: Bill Fultz P edrickt own Subject: Pedricktown Industrial Health Audit - October 5-9, 1992 Attached is our third audit progress report. It gives the status of the items that Dan identified during the October audit as requiring attention. Our next progress report is due by 9/30/93. All items will be completed by October, 1993. cc: Joe Blackburn Pat Ferraro John Fletcher Jim Kiel A1 Matyger Ed McKinley Art McMillian Dennis O'Keefe Carl Stolfo Bill Wagner Tom Worrell NGC 12706 PEDRICKTOWN 1992 INDUSTRIAL HEALTH AUDIT 1992 Items To Be Corrected IH--1992-2 OSHA 29 CFR 1910.1200 (f) (5), Hazard Communication, requires that each container of Hazardous Material be labeled. The following items must be corrected: 3. NFPA markings on the Resin Silos do not correspond to GVD MSDS requirements. Please advise your time table for correction of this item. Response 3. A purchase order has been written to change the NFPA markings on the resin silos - to be completed by the end of the third quarter. Status __________ Complete X________ Incomplete __________ No Action IH--1992-4 IH--101 ''Ventilation Section" deals with ventilation equipment designed for control of health hazards and requires annual ventilation flow and maintenance checks which are documented. Engineering Standard "ST-411" gives engineering and design standards for ventilation equipment. This item could be added to your maintenance PM system. Please advise me your method for handling this matter and the time table for initiation. Response An inventory of ventilation equipment designed to control health hazards is being developed- Flow_______ measurements have been completed in the Compound_______ area. Still need to do Drver and Maintenance areas. Once completed. PM's will be established. To be completed bv September 15. 1993. Status __________ Complete X________ In-Complete No Action NGC 12707 PEDRICKTOWN 1992 ( NDUSTRIAL HEALTH AUDIT ted l 1910.1200 (f) (5), Hazard Communication, lat each container of Hazardous Material be The following items must be corrected: rkings on the Resin Silos do not correspond MSDS requirements. ise your time table for correction of this c' lase order has been written /to change the V J' NFPA markings on the resin silos pleted by the end of the third quarter. IH--1992--4 IH--101 "Ventilation Section" deals with ventilation equipment designed for control of health hazards and requires annual ventilation flow and maintenance checks which are documented. Engineering Standard "ST-411" gives engineering and design standards for ventilation equipment. This item could be added to your maintenance PM system. Please advise me your method for handling this matter and the time table for initiation. Response An inventory of ventilation equipment designed to control health hazards is beina developed. Flow measurements have been completed in the Compound are.a. still, need to do Drver and Maintenance areas. Once completed. PM's will be established. To be completed bv September 15. 1993. Status __________ Complete X__________In-Complete _______ No Action NGC 12708 INTEROFFI MEM O R A N D U M Date: From: Dept: Tel No: 13-Sep--1993 04:31pm Jan Suhay SUHAY, JAN D/5450 216 447-7690 EDT TO: TO: KASWELL, GREG 0KEEFE, DENNIS ( KASWELLG@PED2 60MRGATE ) ( OKEEFED@PED26@MRGATE ) CC: BOB GRAHEK ( GRAHEK, BOB ) Subject: PEDRICKTOWN AUDIT RESPONSE THIS IS JUST A REMINDER, YOUR FOLLOW-UP AUDIT RESPONSE IS DUE TO HERM WALTEMATE BY SEPTEMBER 30, 1993. THANKS MUCH, JAN CC: HERM WALTEMATE NGC 12709 INTEROFFICE MEMORANDUM TO: FULTZ, WILLIAM CC: CC: CC: BOB GRAHEK DANIEL E. GLEGHORN HERM WALTEMATE Subject: Reminder Date: From: Dept: Tel No: 18--Dec--1992 03:56pm EDT Jan Suhay SUHAY, JAN D/5450 216 447-7690 ( FULTZW@PED26@MRGATE ) ( GRAHEK, BOB ) ( GLEGHORN, DAN ) ( WALTEMATE, HERM ) Please be informed that your initial response audit report is due December 30, 1992. Please forward the Pedricktown Safety Audit Report to Herm Waltemate and the Pedricktown Industrial Hygiene Audit Report to Dan Gleghorn. Thanks much, Jan NGC 12710 December 30, 1992 To: Dan Gleghorn Cleveland F rom: Bill Fultz Ped rickt own Subject: Pedricktown Industrial Health Audit - October 5-9, 1992 Attached is our first audit progress report. It gives the status of the items that you identified during the October audit as requiring attention. Our next progress report is due by 3/31/93. All items will be completed by October, 1993. cc: Joe B1ackburn Pat Ferraro John Fletcher Jim Kiel A1 Matyger Ed McKinley Art McMiIlian Dennis O'Keefe Carl Stolfo Ron Szmerda Bill Wagner Tom Worrel1 c O v received JAN 0 ** 1993 III. 1992 Items To Be Corrected IH-1992-1 Product specific MSDS were not available for each vinyl resin and compound. This is an issue that must be corrected on a divisional level. You will be advised of the necessary response require of the pi ant . Response We r ecent l_y__r eceived an E-mail from Jan Suhav advisIDS _t hat the system to generate and distribute pro-_ duct specific MSDS has been developed and that we will begin seeing them shortly._____________________ _________ IH-1992-2 St at us _________ Complete X_______ Incomplete No Action OSHA 29 CFR 1910.1200 (f) (5), Hazard Communication, requires that each container of Hazardous Material be labeled. The following items must be corrected: 1. Bulk storage boxes, intended for storing compound, were found in the Dispersion Poly and Mass buildings and are labeled with Hazardous Waste Labels for Vinyl Chloride containing materials. It is important to note that OSHA 29 CFR 1910.1017 (1)(3) requires "containers of polyvinyl chloride resin waste from reactors or other waste contaminated with vinyl chloride shall be legibly labeled: "Contaminated with Vinyl Chloride Cancer Suspect Agent" The OSHA labels were not observed on these boxes. The boxes also retain the Compound Labels. These labels do not indicate the true contents of the containers. 2. Several Fiber Drums, in the Mass Building are not 1abe1ed. 3. NFPA markings on the Resin Silos do not correspond to GVD MSDS requirements. NGC 12712 "lease advise your time table for- correction of this item. Response ,1__. May Johnson is try_i ng to get c 1 ar i fi cat ion on the specific labelling requirements for this waste. __ (To be resolved by 2/28/93) . _________________ ____Dispersion personnel have been instructed to ____paint out the compound labels on the Gaylords. (CompJeteJ__________________ ________ 2. Labels were put on the fiber drums in the Mass Bui l_dj_ng. Dispersion personnel were reminded of ____the._requi rement to do_ this.. (Complete) 3_._ The. NFPA markings on the silos will be changed in the second quart e.r of 1 993._____ ________ ___________________ Status _________ Complete X_______ Incomplete ____ No Action IH-1992-3 The monitoring program to support your monitoring priority strategy is progressing well. Several chemicals found in your monitoring priority strategy are due to be monitored in November and December. Please advise me when this monitoring has been comp!et ed. Response All planned monitoring has been completed with the exception of PVC dust in Building 515. This will be comp 1 et ed__i n January , 11 93_,; Status __ _____ Complete X__ In-Complet e No Action NOC 12713 IH-1 992-4 IK-101 "Ventilation Section" deals with ventilation equipment designed for control of health hazards and requires annual ventilation flow and maintenance checks which are documented. Engineering Standard '`ST-411'` gives engineering and design standards for ventilation equipment. This item could be added to your maintenance PM system. Please advise me your method for handling this matter and the time table for initiation. Response An i nvento ry _of_ventilation equipment designed to _ control health hazards is being developed. Once completed specific PM's will be written to document annual flow and maintenance checks. The specific defect assocoiated with the 1aboratorv fume hood flow rate document ation has been corrected. PM's wi_.ll .be established and initiated by 3/31 793. St at us __ __ Complete X_______ In-Complet e No Action NGC 12714 INTEROFFICE MEMORANDUM Date: From: Dept: Tel No 23-Mar-1993 09:59am Jan Suhay SUHAY, JAN D/5450 216 447-7690 EDT TO: TO: TO: KASWELL, GREG OKEEFE, DENNIS FULTZ. WILLIAM ( KASWELLG0PED260MRGATE ) ( OKEEFED PED2 6 QMRGATE ) ( FULTZWPED26@MRGATE ) CC: BOB GRAHEK ( GRAHEK, BOB ) Subject: REMINDER PEDRICKTOWN AUDIT CONDUCTED OCTOBER 5-9, 1992 JUST WANTED TO LET YOU KNOW THAT YOUR FOLLOW-UP RESPONSE TO THE SAFETY AND HEALTH? AND THE INDUSTRIAL HEALTH AUDIT IS DUE ON MARCH 31ST. PLEASE FORWARD YOUR RESPONSE TO HERM WALTEMATE. THANKS MUCH, JAN CC: HERM WALTEMATE NGC 12715 INTEROFFICE MEMORANDUM To: KASWELL, GREG TO: OKEEFE, DENNIS Date From Dept: Tel No 15-Jun-1993 10:52am Jan Suhay SUHAY, JAN D/5450 216 447-7690 EDT ( KASWELLG@PED2 6@MRGATE ) ( OKEEFED@PED26@MRGATE ) CC: BOB GRAHEK ( GRAHEK, BOB ) subject: REMINDER JUST WANTED TO LET YOU KNOW THAT BOTH OF THE AUDIT RESPONSES ARE DUE JUNE 30TH. PLEASE FORWARD THE SAFETY AND HEALTH, PLUS THE INDUSTRIAL HYGIENE AUDIT RESPONSES TO HERM WALTEMATE. PLEASE ONLY INDICATE THE STATUS OF THE ITEMS THAT ARE NOT YET COMPLETE. THANKS MUCH, JAN CC: HERM WALTEMATE NGC 12716