OSHA Inspection: THE KEEBLER COMPANY

Issued

Apr 15, 1988

Abate by

Apr 21, 1988

Penalty

Initial $700 · Current $700

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  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 in that employees were exposed to:
a) The hazard of an oxygen-deficient atmosphere due to the products of
the decomposition of sugar within the sugar Silo (#19) being cleaned
or repaired by employees on or about February 8 through February 10,
1988. The Silo constitute confined spaces for which the company did
not have safe procedures for  entry and continued work; and the
hazard of falling eleven feet for an employee inside the sugar silo
standing on a platform between the augers due to lack of fall
protection and the hazard of being struck from above by falling
material causing the employee to fall into the bottom of the Silo.
Among other methods, one feasible and acceptable abatement method to
correct this hazard is to establish and enforce a safe confined space
entry procedure.  Essential elements of a confined space entry
procedure and would include:
1) Written procedures covering a permit system, ventilation, atmospheric
testing, rescue procedures and employee training .
2) The completion and posting of a confined space entry permit which
requires authorization and approval in writing that specifies the
location and type of work to be done and certifies that all existing
hazards have been evaluated by qualified person and necessary
measures have been taken to ensure the safety of each worker.
3) Mechanical ventilation of the confined space prior to entry and
continued ventilation to provide a safe atmosphere, when determined
necessary as described in (2) above.
4) Testing the atmosphere of the confined space prior to entry and on a
regular basis for presence of sufficient oxygen (19.5%) and absence
of hazardous levels of toxic or combustible gases or vapors, when
determined necessary as described in (2) above.
5) Emergency rescue procedures with a requirement that trained personnel
are available and are stationed outside the confined space with
proper equipment to provide for the rescue of persons entering the
space as determined necessary as determined in (2) above. Such
equipment must include safety harness and life lines with provisions
for hoisting employees from the confined space. If entry is required,
for rescue, the rescuing employee must be equipped with approved air
supplied respiratory equipment and other appropriate personal
protective equipment.
6) Training of any and all employees required to enter the confined
spaces. This training shall include procedures required prior to
entry and the hazards associated with work in confined spaces.