OSHA Inspection: NUTRO PRODUCTS INC

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Penalty

Initial $2,100 · Current $1,900 Reduced

Hazardous substances 8880

General-duty citation text

T.C.A. 50-3-105(1):  The employer did not furnish employment and a place
of employment
which were free from recognized hazards that were likely to cause death or
serious physical
harm to an employee, in that an employee was potentially exposed to an
oxygen-deficient
atmosphere in the oil room.
On 4/17/06, a QC Clerk indicated that he entered the oil room for about 5
minutes, 3 times per
week.  The room had two oil tanks that were covered by a nitrogen gas
blanket.  The nitrogen
gas was fed to the room from an outside storage tank, and employer
representatives indicated
that no means were in place to ensure that a nitrogen overfeed of any
amount would not occur.
The employer relied on a portable oxygen monitor, attached to a rail
inside the oil room
doorway, to alert the employee of the existence of an oxygen-deficient
atmosphere in the event
of an excess nitrogen release into the room.
There was inadequate (non-existent) calibration of the portable oxygen
monitor.  The oil tanks
were in a room that was 32,500 cubic feet in volume, and the outside
storage tank that fed the
nitrogen to the oil room tanks held liquid nitrogen that would yield over
470,000 cubic feet of
nitrogen gas.  Release of enough of the nitrogen into the oil room could
create a potentially-
deadly oxygen-deficient atmosphere, to which employees' must be alerted so
that exposure could
be prohibited.
The Biosystems ToxiPro oxygen sensor "Reference Manual" recommended that
calibrations (or
"bump tests"), initially on a daily basis - and in no case greater than 30
days, be performed to
ensure the accuracy of the meter.  No calibrations had been performed
since the meter was
purchased and put into use about 9 months previously.  The manual also
included warnings, such
as: "given the fact that dependable sensors can be key to survival in a
hazardous environment,
frequent verification of sensor performance is paramount" (Appendix C:
Calibration Frequency,
p. 17).  The signs on the oil room entrance door indicated that the
employer recognized the
potential hazard, but he had not ensured that he could identify the
problem and prohibit
employee exposure (if an oxygen-deficient atmosphere developed) due to no
system for testing
the accuracy of the oxygen meter.
Among other methods, one feasible and acceptable abatement method for
correcting this hazard
is:
a.Verify the accuracy of the ToxiPro oxygen meter by following the
calibration procedures
given in its "Reference Manual," paragraph 3. through 3.1.1.  3.1.1 states
that if fresh
air readings are not accurate, then a "fresh air/zero calibration
adjustment must be made
as discussed...in section 3.4."  Section 3.7.1.2 states that if a "fresh
air/zero calibration
[in fresh air] fails," a "forced...fresh air calibration" must be
performed,
as described
in that section.  If the sensor fails a forced fresh air calibration in
fresh air, then there
is a failed oxygen sensor, and the instrument is not accurate for use
until a new sensor
has been installed and calibrated.  In that case, employee safety must be
ensured by
prohibiting entry into any potential oxygen-deficient area (such as the
nitrogen-fed oil
room); andb.Verify the alarm point accuracy by applying oxygen-deficient
(or oxygen-less) gas to the
sensor air intake and ensure that the instrument alarms below the 19.5
oxygen alarm
set-point.  If not, further servicing is necessary before the instrument
alarms can be
considered reliable.

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 8880

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 888019000560

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 8880

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 88800560

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Penalty

Initial $2,100 · Current $1,900 Reduced

Hazardous substances 81108111

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 81108111

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 81108111

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 81108111

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 81108111

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 81108111

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 81108111

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 81108111

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 81108111

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 81108111

Issued

Jun 2, 2006

Abate by

Jul 12, 2006

Hazardous substances 81108111

Issued

Jun 2, 2006

Abate by

Jun 8, 2006

Penalty

Initial $600 · Current $200 Reduced

Hazardous substances 81108111