Today's Environmental Daily Advisor Tip: Manufacturer May Pay $41K OSHA Fine for Poor PPE

OSHA has recently cited an Illinois bumper manufacturing plant with 6 serious safety violations for failing to protect workers from exposure to hazardous materials and provide adequate emergency response plans and training. OSHA conducted an inspection of the facility in July 2012 after the agency received a complaint alleging workers were being exposed to high levels of hydrochloric acid after a release of the acid during refilling operations. Proposed fines total $41,200.

Three of the violations involve failing to ensure that workers used personal protective equipment (PPE) when exposed to hazards capable of causing injury and impairment. These included a lack of hand, eye, and face protection for workers exposed to liquid chemicals, acids, or caustic liquids.

The remaining violations involve failing to include evacuation routes and procedures in the company’s emergency response and contingency plan and to ensure that workers engaged in emergency response involving inhalation hazards were provided with breathing apparatus for respiratory protection and trained on adequate emergency response.
OSHA cites a serious violation when there is substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known.
The company employs more than 12,450 people at 50 manufacturing and 9 product development and engineering facilities throughout the United States, Canada, Mexico, Argentina, Brazil, and Spain. The Illinois plant was previously cited by OSHA in May 2012, which resulted in 6 serious violations.

What OSHA Says About Eye and  Face Protection

Employers are responsible for requiring employees to wear proper eye or face protection when working in areas with the potential for hazards caused by:

• Flying particles (impact hazards)
• Molten metal
• Liquid chemicals
• Acids or caustic liquids
• Chemical gases or vapors
• Potentially infected material
• Harmful light radiation

OSHA requires that employers assess the hazards faced by their employees in order to determine the appropriate eye and face protection for the job. Employers must also pay for most PPE, with some exceptions.
OSHA mandates that eye and face protection must satisfy the requirements of any of the following ANSI standards: ANSI Z87.1-2003, ANSI Z87.1-1989 (R-1998), or ANSI Z87.1-1989, unless the employer can demonstrate that the protection is as least as effective as those constructed in accordance with these ANSI standards.

Choosing the Right Eye and Face Protection

When choosing appropriate eye and face protection for your workers, you should think about:

• Specific hazards
• Proper fit
• Comfortable fit
• Not obstructing vision
• Not hindering movement
• Not interfering with the proper use of other PPE
• Durability
• Ease of cleaning and maintaining

Regardless of the specific PPE selected, information identifying the manufacturer must appear on the eye or face protection.
For employees who work in areas where there may be flying objects, employers must require eye protection that also protects from the side. To satisfy this requirement, employees may use detachable side shields.
Employees who wear everyday prescription glasses are not properly shielded from eye hazards when wearing only those glasses. If employees who are exposed to eye hazards have prescription lenses, they must have prescription eye protection or appropriate eye protection that fits properly over their lenses. Wearers of contact lenses also need to use eye or face protection.
Recognizing the hazard of potentially injurious light radiation, OSHA mandates that employers must require employees to wear PPE with filter lenses that provide proper shade protection depending on the light radiation. OSHA has created a chart detailing the minimum protective shade number that should be used according to the work being done.