OSHA Inspection: CLARKE CORPORATION

Issued

Sep 18, 1989

Abate by

Oct 19, 1989

Penalty

Initial $300 · Current $120 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
a variety of hazards associated with oxygen deficient, toxic and/or
explosive atmospheres during confined space entry of process equipment
and associated structures such as 500 barrel frac tanks while performing
maintenance and/or repairs.  During such operations, employees were
potentially exposed to the hazards of asphyxiation due to the presence
of low concentrations of oxygen inside the process equipment; illness
including but not necessarily limited to nervous system damage, cyanosis
and death from exposed to atmospheres containing less than 19.5% oxygen;
death resulting from fires and/or explosionsdue to the potential
presence of combustible/explosive mixtures of gases/vapors and oxygen in
the atmosphere.
One feasible and acceptable abatement method, among others, to correct
this hazard is to institute a formal confined space entry program such
as is contained in ANSI Z117.1-1977,  Safety Requirements for Working in
Confined Spaces.  A minimally acceptable confined space entry procedure
consists of the following elements:
1) Written procedures covering a permit system, personal protective
equipment, 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
and potential hazards have been evaluated by a 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 safe atmosphere, when determined
necessary as described in (2) above. Isolation/lockout procedures
with a requirement that the confined space be completely isolated
from all systems by physical disconnection, double block and bleed,
or blanking off all lines when determined necessary in (2) above.
Electrical isolation, by locking circuit breakers and/or disconnects
in the open (OFF) position with a key-type padlock. Mechanical
isolation, by disconnecting linkages or removing drive belts and
chains, with moving parts being blocked where there can be no
accidental rotation. If complete isolation is not possible, specific
written safety procedures approved and enforced by employer.
4) Testing the atmosphere of the confined space prior to entry and
on a regular basis for presence of sufficient oxygen a minimum
of 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 described in (2)
above.  Such equipment must include safety harness and lifelines
with provisions for hoisting employees from the confined space.
If entry is required, the rescuing employees 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 for entry,
the hazards associated with work in confined spaces, and rescue
training procedures.
DISCLAIMERS:
1) The employer is not limited to the abatement methods suggested
above.
2) The methods explained are general and may not be effective in all
cases.
3) The employer is responsible for selecting and carrying out an
appropriate abatement method.

Issued

Sep 18, 1989

Abate by

Oct 19, 1989

Penalty

Initial $240 · Current $96 Reduced

Issued

Sep 18, 1989

Abate by

Sep 27, 1989

Penalty

Initial $120 · Current $48 Reduced

Issued

Sep 18, 1989

Abate by

Oct 19, 1989

Penalty

Initial $180 · Current $72 Reduced

Issued

Sep 18, 1989

Abate by

Oct 19, 1989

Issued

Sep 18, 1989

Abate by

Oct 19, 1989

Issued

Sep 18, 1989

Abate by

Oct 19, 1989

Penalty

Initial $120 · Current $48 Reduced

Issued

Sep 18, 1989

Abate by

Oct 19, 1989

Issued

Sep 18, 1989

Abate by

Oct 19, 1989

Issued

Sep 18, 1989

Abate by

Oct 19, 1989

Issued

Sep 18, 1989

Abate by

Sep 22, 1989

Issued

Sep 18, 1989

Abate by

Sep 22, 1989