Text For Citation: 01 Item/Group: 004B Hazard:

29 CFR 1910.1027(f)(2)(i): Where the PEL is exceeded, the employer shall establish and implement a written compliance program to reduce employee exposure to or below the PEL by means of engineering and work practice controls, as required by paragraph (f)(1) of this section. To the extent that engineering and work practice controls cannot reduce exposures to or below the PEL, the employer shall include in the written compliance program the use of appropriate respiratory protection to achieve compliance with the PEL. On or about November 7, 2023, the employer failed to develop and implement a written compliance program to help train employees and help them identify exposures to cadmium below the Permissible Exposure Limit (PEL) for cadmium of 0.005 milligrams per cubic meter across an 8-hour Time Weighted Average (TWA) for welding operations that generated cadmium fumes. Welders use products including but not limited to carbon and alloy steels and zirconium and carbon steel solid wire and rods for operations that generate respiratory hazards including welding the catalytic converter cages to the bolts of the trucks. These products and operations generated respirable hazards where employees were found on December 5, 2023, to be over the Permissible Exposure Limit (PEL) including but not limited to cadmium during work operations. Two welders were discovered to have an exposure of 0.016 milligrams per cubic meter and 0.021 milligrams per cubic meter for cadmium fumes.