OSHA Inspection: LEHIGH VALLEY RECYCLING (J.P. MASCARO)

Issued

Jan 4, 1993

Abate by

Feb 5, 1993

Penalty

Initial $1,500 · Current $580 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
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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 hazards including eye and inhalation exposure to leachate
gases associated with improper safety/work practices during the
transfer of leachate liquid/slurry from the underground storage tank
to the tanker truck for disposal:
The alleged violations below have been grouped because they involve
similar or related hazards that may increase the potential for
illness.
a)  Leachate Holding Tank - An employee transferring
leachate slurry while on top of a tanker truck was exposed
to leachate gases and was overcome.  Proper safety
precautions were not developed or followed for transferring
leachate liquid/slurry from underground storage tank to
tank truck, thus exposing employees to unknown levels of
leachate gases.
Among other methods, one feasible and acceptable abatement method
to correct this hazard is to implement and utilize a tank
emptying/processing program which includes at least the following
essentials:
1)  prior to employees conducting such processes formalized
training shall be provided which includes information on the
nature of the hazards likely to be encountered including the
presence of contaminants/gases, the symptoms and consequences of
contaminated overexposure and oxygen deficiency, emergency
procedures, use of applicable respirators, first aid, safety
equipment and safe rescue procedures.
2)  A program of atmospheric testing for oxygen deficiency,
flammable gases and vapors and other hazardous atmospheric
contaminants shall be implemented and performed by qualified
persons who have received formal training using properly
calibrated direct reading oxygen, combustible gas and toxic gas
indicator.  This testing shall be done adjacent to the accessible
areas of the tank opening and shall be carried out prior to and
during each tank opening.
While employees are working in the area, they must carry
atmospheric monitoring devices, with alarms which meet the above
criterion.
3)  There shall be a trained standby person assigned during each
tank processing operation, with a fully charged, positive pressure
self contained breathing apparatus (SCBA) at hand.  Additional
duties of the stand-by person are to maintain unobstructed view
and communications to any worker working around the tank
processing area.  Under no circumstances should the stand-by
person enter the area until he/she is relieved and is assured that
adequate assistance is present.
4)  Appropriate safety equipment and clothing, such as
respirators, head, foot, hand and body protection shall be
available as appropriate for each tank process.
5)  Written processing procedures which address set-up
communication/observation procedures, emergency rescue and safe
work practices shall be developed.
6)  Signs shall be posted, as a means of employee information near
tank processing spaces to notify employees of those hazards which
may be present and serve notice that only authorized employees may
enter areas.
7)  Engineering controls which could significantly reduce or limit
employee exposure shall also be developed.  Examples of such
engineering controls would be:
a)  Development of a system to power ventilate and agitate
materials in the underground storage tank to reduce the
build-up of leachate gases.
b)  Development of a system for filling the tank truck which
would eliminate or greatly reduce the need for employees to
work in the area of the transfer process.  This could include
a permanent rigid piping system under which the tank truck
could be backed for filling.

Issued

Jan 4, 1993

Abate by

Jan 15, 1993

Hazardous substances 1640053019001480

Issued

Jan 4, 1993

Abate by

Jan 15, 1993

Penalty

Initial $1,500 · Current $580 Reduced

Issued

Jan 4, 1993

Abate by

Feb 5, 1993

Penalty

Initial $600 · Current $230 Reduced

Issued

Jan 4, 1993

Abate by

Jan 22, 1993

Issued

Jan 4, 1993

Abate by

Feb 5, 1993

Penalty

Initial $750 · Current $290 Reduced

Hazardous substances 8400

Issued

Jan 4, 1993

Abate by

Jan 22, 1993

Issued

Jan 4, 1993

Abate by

Feb 22, 1993

Hazardous substances 8400

Issued

Jan 4, 1993

Abate by

Jan 15, 1993

Penalty

Initial $750 · Current $290 Reduced

Issued

Jan 4, 1993

Abate by

Jan 12, 1993

Penalty

Initial $600 · Current $230 Reduced

Issued

Jan 4, 1993

Abate by

Jan 22, 1993

Issued

Jan 4, 1993

Abate by

Jan 22, 1993