OSHA Inspection: RAMM PLUMBING COMPANY

Issued

Jan 21, 1992

Abate by

Mar 13, 1992

Penalty

Initial $3,000 · Current $1,800 Reduced

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:
Hazard to which employee was exposed:
(a)  On November 7, 1991 an employee entered a confined space,
a sanitary sewer, to take measurements of an existing horizontal
sewer pipe.  A confined space entry procedure had not been
developed for worker use.  Employees were exposed to hazard of
asphyxiation.  Among others a feasible method to correct this
hazard is:
A confined space entry procedure shall be developed, implemented
and enforced which is specific for the worker exposures to
confined space hazards specific for the cleaning, sludging and
relining operations performed.  Procedures shall follow ANSI
Z117.1-1989 and shall include at least the following:
(1)  Written procedures covering a permit system,
ventilation, atmospheric testing, rescue procedures, employee
training, designation of a qualified person for standby and
emergency procedures.
(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 a
qualified person  and hte necessary protective measures have
been taken to ensure the safety of each worker.
(3)  Mechanical ventilation of the confined space prior to
entry and continued ventilation of the space during
operations to provide a safe atmosphere.
(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.
(5)  Emergency procedures with requirements that trained
personnel are available and are stationed outside the con-
fined space with proper equipment to provide for the rescue
of persons entering the space.  Such equipment must include
safety harness of lifelines 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/self-contained breathing apparatus or other
appropriate respiratory protection and other appropriate
personal protective equipment.
(6)  Training shall be provided to all employees required
to enter the confined space or assist in rescue/emergency
activities.  The training shall include the procedures
required prior to entry and the hazards associated with work
in the confined space, use of protective, testing and rescue
equipment.
Section 5(a)(1) elements.
1.  Hazard to which employee was exposed:
(a)  The employer had made a prior arrangement with the
Metropolitan Sanitary District to test the environment prior
to the employee entering the sewer, due to scheduling
difficulties the Metropolitan Sanitary District did not
arrive to test the atmosphere in the sewer, and the employee
entered the sewer without wearing personal protective
equipment.
(b)  The Company did not have a confined space entry program,
however the manager informed the CSHO that he was aware of
the requirement to test the atmosphere.
(c)  The Company did not have a method to retrieve the
employee from the sewer in the event the employee was
overcome by gasses or insufficient oxygen.
(d)  The Company did not have a written method to communicate
with a local paramedic or rescue team (Fire Department).  A
body harness or stretcher was not provided on the site.
(e)  Mechanical ventilation was not provided to ventilate
the sewer.
(f)  The employee used a bare bulb 110 VAC attached to a
metal reflector in the sewer
2. Hazard must be recognized:
(a)  the employer informed the CSHO that he was aware of the
hazardous environment to which his employee was exposed and
had contacted the Metropolitan Sanitary District to sample
the confined space.
3.  Hazard was causing or was likely to cause death or serious
physical harm.
(a)  Due to the lack of testing of the sewer for an explosive
gas level (LEL) or sufficient oxygen (19.5%) a condition may
have existed that could cause death by asphyxiation or
explosion.
4. Hazard may be corrected by a feasible and useful method.
The development, implementation and enforcement of a con-
fined space entry procedure as outlined in the OSHA-1B for
the 5(a)(1) violation would provide the employees protection
from the possible fire and asphyxiation hazards.

Issued

Jan 21, 1992

Abate by

Mar 13, 1992