Text For Citation: 01 Item/Group: 001B Hazard:

OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees a) Employees were exposed to 1,3,5-triglycidyl isocyanurate (TGIC) while powder spray coating trailers in the spray booth. An employee spray painting was exposed to 0.866mg/M3 of TGIC as 8-hour time weighted average, approximately 17 times the American Conference of Governmental Industrial Hygiene (ACGIH) Threshold Limit Value (TLV) of 0.05 mg/M3, or the manufacturer?s recommended exposure limit of 0.025 mg/M3 as a Short Term Exposure Limit on or about April 1, 2016. Feasible methods to protect employees from the hazard of chemical exposure may include, but are not limited to, the following: a. Ensure TGIC exposure levels are maintained below the manufacturers recommended STEL of 0.025 mg/m3. b. Ensure TGIC exposure levels are maintained below the ACGIH TLV of 0.05mg/m3. c. Substitute the current paint for one that contains no, or lower TGIC amount. d. Seek the assistance of a qualified engineer or other professional such as a Certified Industrial Hygienist in the design of a spray booth and ventilation system to maximize capture of powder paint spray and minimize the potential for employee exposure. e. Investigate the use of varying pressure and volume in the paint spray guns to increase paint transfer efficiency and minimize overspray. f. Provide effective local exhaust ventilation, located as close as possible to the point of chemical release, in order to remove TGIC containing paint powder prior to employees being exposed. g. Develop employee work practices, material handling changes, and/or process equipment changes for spray finishing that would minimize employee exposure from powder paint spray generated by co-workers painting in the same booth and provide employee training to ensure application of work practice. h. Develop employee work practices, material handling changes and/or booth design changes for spray finishing that would minimize employee exposure from powder paint overspray due to the employee being positioned between the part being painted and the booth air exhaust and provide employee training to ensure application of work practice. i. Conduct periodic air monitoring to evaluate the continuing effectiveness of control measures. Bwise Manufacturing, LLC OSHA No.(s): 1125064 j. Provide wash stations, vacuums, showers, lockers, change room(s), and other decontamination and/or washing facilities in the painting area to ensure that TGIC-containing paint powder is effectively removed from employees protective equipment prior to the employee removing the garment, eating or leaving the work area or going home. k. Ensure employees correctly remove their protective coveralls and decontaminate before leaving the work area and before each break. l. Ensure employees wash their hands and face prior to eating, drinking or smoking. m. Provide information and training to employees on how to effectively wear their personal protective equipment so that there is no skin contact with the powder. n. Provide personal protective equipment that effectively protects the employee?s hands, wrists, forearms, and shoes from the TGIC-containing paint powder. o. Ensure that all of the elements of 29 CFR 1910.134 are in place and that full compliance with these elements occurs daily. Abatement Certification and Abatement Documentation is required. During an inspection of your workplace at 1086 Wayne Avenue Chambersburg, PA which began on February 12, 2016 the compliance safety and health officer observed the following hazardous conditions, which are not in accordance with recognized safe work practice. The Low Cure Black and Red powder coating paints contain a compound called 1,3,5 triglycidyl isocyanurate (TGIC) that may cause contact dermatitis, hematopoietic effects and heritable genetic damage to human germ cells. Air sampling conducted at your facility on April 1, 2016, resulted in a powder coat painting employee being overexposed to TGIC at a level of 0.087mg/M3. The American Conference of Governmental Industrial Hygiene (ACGIH) has established a Threshold Limit Value (TLV) for TGIC at 0.05mg/M3. The Occupational Safety and Health Administration (OSHA) regards workplace chemical exposure as a serious safety and health hazard. Since this is the second time that an exposure has been documented by OSHA, the purpose of this letter is to again bring your attention to this hazard and to encourage you to address it within your establishment.