OSHA Inspection: MERCER COATING & LINNING COMPANY

Issued

Sep 18, 1991

Abate by

Nov 8, 1991

Penalty

Initial $1,500 · Current $750 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 the hazard of severe lung damage when entering tank
trailers which may contain residues from various chemical products
which had been carried in the trailer:
a- Mercer Coating & Lining Company - Employees are required to
enter tank trailers to perform visual inspection of the interior,
grinding with a hand grinder, chipping with a chipping gun,
sandblasting, applying a 3 part adhesive, and lining the interior
with rubber sheets.  The tanks, which are constructed of carbon
steel, can range from 18 feet to 39 feet in length, and 4.5 feet
to 5.5 feet in diameter.  The access hatch may range from 16
inches to 24 inches in diameter.  The employer did not correctly
evaluate the hazard of the confined space.  The employer did not
establish a written permit system, to certify that all hazards
have been evaluated.  The employer did not provide training to
employees in order that they may safely work in the tanks.  The
employer did not ensure the proper use of equipment necessary for
safe entry.  The employer did not ensure that procedures and
equipment necessary to rescue employees from the tanks were
provided and implemented.
Condition noted on or about 6/13/91.
Among other methods, one feasible and acceptable abatement
method to correct this hazard is to:  implement a confined space
entry procedure which includes, but is not limited to, the
following items:
(1) Instruction and training as to the nature of the hazards
involved and necessary precautions to be taken relative
to confined space entry.
(2) Posting of written confined space entry procedures adjacent
to tanks.
(3) Issuing a proper entry permit prior to tank entry to ensure
that all hazards have been evaluated.
(4) Conduct atmospheric testing of tanks to determing potential
oxygen deficiency and the presence of air contaminants,
prior to employee entry, and during the time of employee
is working in the tanks.
(5) Where it has been determined that the confined space
contains a hazardous concentration of an air contaminant
and/or an oxygen deficiency, the use of mechanically-induced
ventilation in the confined space/tank before entry and
during occupancy.  The use of respiratory protective
equipment which provides adequate protection against the
hazards encountered.
(6) Provisions and procedures for a standby observer, located
outside the confined space/tank and readily available
standby equipment consisting of a safty line and harness,
which the employee is wearing in the confined space.
(7) Ensure that employees entering the confined space and
attendants are properly trained.  Training should include,
but not be limited to:  hazard recognition, communication,
protective equipment and rescue.

Issued

Sep 18, 1991

Abate by

Oct 2, 1991

Issued

Sep 18, 1991

Abate by

Sep 25, 1991

Penalty

Initial $300 · Current $150 Reduced