OSHA Inspection: ECONO-CLEAN

Issued

Sep 3, 1991

Abate by

Oct 7, 1991

Penalty

Initial $1,500 · Current $900 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:
....employees were engaged in entering railway hopper cars to
clean and inspect the condition of these cars, and proper confined
space entry procedures as outlined in the abatement methods were not
followed.  These hopper cars were confined spaces and had contained
such toxic materials as benzene, sodium tripolyphosphate, anhydrous
ammonia, and sodium phosphate, exposing employees to burns / fire
hazards.
Among other methods, a feasible and acceptable abatement method
to correct the hazards should follow the procedures set forth in
the American National Standards Institute ANSI Z117.1-1977,
'Safety Requirements for Working in Tanks and Other Confined
Spaces', and should include the following:
1. Implementation of the formal confined space entry program
currently in existence at the facility.  The program should
include the following areas:
a)  Establishment of a permit system.  Entry into a confined
space shall be by permit ONLY.  The supervisor or a qualified
person shall be responsible for securing the permit and both
shall sign off when the area has been reviewed and necessary
actions confirmed.  The permit shall include:  location and
description of the work to be done, hazards that may be
encountered,, complete isolation of the confined space
(blanking and/or disconnecting, electrical and mechanical
lockout), protective equipment and clothing required,
atmospheric test readings, standby person, emergency
procedures and the location of first aid equipment.  The
permit shall be dated and carry an expiration time that will
be valid for ONLY ONE SHIFT.
b)  Establishment of a training program which includes the
following areas:  emergency entry and exit procedures, use
of applicable respirators, first aid, lockout procedures,
safety equipment use, rescue and training drills, permit
system, and work practices.  Training shall not be considered
complete until the employee is judged to have attained an
acceptable degree of proficiency for entering and working
in confined spaces.
c)  Mechanical ventilation of the confined space shall be
provided prior to entry and continued to provide a safe
atmosphere.
d)  Entry into a confined space shall be prohibited until
initial testing of the atmosphere has been done from the
outside.  The tests performed shall include those for oxygen
content, flammability, and toxic materials.  Measurements
shall be made with instruments calibrated daily according
to manufacturer's instructions.  Instrument operators shall
be trained in the use and care of the instruments.
e)  All entrances to any confined space shall be posted.
f)  Lockout and tagout procedures shall be used for any
electrical or mechanical equipment to which an employee in
a confined space could be exposed.
g)  Personal protective equipment such as respiratory
protection shall be chosen and provided on the basis of
testing and monitoring.  Users of this equipment shall be
trained in its limitations and use.  Respiratory protection
shall be used in accordance with section 1910.134 of 29 CFR
1910 General Industry Standards.  Additional personal
protective equipment such as gloves, hard hats, and eye
protection shall be chosen when determined to be necessary
by a qualified person.
h)  An individual shall be required to stand by for rescue
outside the confined space to be in immediate contact with
the employee(s) in the confined space.
i)  Emergency rescue procedures shall be established with
a requirement that the standby person is stationed outside
of the confined space with proper equipment to provide for
the resuce of the person(s) in the confined space.  Such
equipment shall include safety harness and lifelines with
provisions for hoisting the employee(s) from the confined
space.  If entry is required for rescue, the rescue employee
shall be equipped with approved air supply respiratory
protection and other appropriate protective equipment.  The
standby person shall have some means of alerting others to
an emergency situation.
2)  Implementation of a training program covering proper confined
space entry and exit procedures, lockout and tagout, emergency
procedures, personal protective equipment available, and work
practices.  Employees should not be allowed to enter a confined
space until s/he displays a thorough understanding of the
procedures necessary for safe entry and the associated hazards.
3)  The elimination of system cross-ties and/or the addition
of a means of isolation for each system.
4)  The elimination of condensate accumulation within the vent
lines.
5)  Complete isolation of the system involved.
6)  Performance of air monitoring surveys for toxic chemicals
(such as Propylene Oxide).  Such surveys would require the
acquisition of monitoring equipment specific for the chemicals
involved.
7)  Ensure the availability of equipment necessary in the event
of an emergency and that it is in proper working order.
DISCLAIMERS:
a)  The employer is not limited to the abatement methods
suggested by OSHA.
b)  The methods explained are general and may not be effective
in all cases.
c)  The employer is responsible for selecting and carrying out
an appropriate abatement method.

Issued

Sep 3, 1991

Abate by

Sep 19, 1991

Penalty

Initial $450 · Current $270 Reduced

Issued

Sep 3, 1991

Abate by

Sep 19, 1991

Penalty

Initial $450 · Current $270 Reduced

Issued

Sep 3, 1991

Abate by

Oct 7, 1991

Penalty

Initial $750 · Current $450 Reduced

Issued

Sep 3, 1991

Abate by

Sep 6, 1991

Penalty

Initial $1,500 · Current $900 Reduced

Issued

Sep 3, 1991

Abate by

Sep 6, 1991

Issued

Sep 3, 1991

Abate by

Sep 6, 1991

Issued

Sep 3, 1991

Abate by

Sep 6, 1991

Issued

Sep 3, 1991

Abate by

Oct 7, 1991

Issued

Sep 3, 1991

Abate by

Oct 7, 1991

Issued

Sep 3, 1991

Abate by

Oct 7, 1991

Issued

Sep 3, 1991

Abate by

Oct 7, 1991

Penalty

Initial $750 · Current $450 Reduced

Issued

Sep 3, 1991

Abate by

Sep 19, 1991

Penalty

Initial $450

Issued

Sep 3, 1991

Abate by

Oct 7, 1991

Penalty

Initial $450

Issued

Sep 3, 1991

Abate by

Oct 7, 1991

Penalty

Initial $750 · Current $450 Reduced

Issued

Sep 3, 1991

Abate by

Sep 12, 1991

Issued

Sep 3, 1991

Abate by

Oct 7, 1991