OSHA Inspection: HAGUE TN WWTP

Issued

Mar 17, 2015

Abate by

Jul 24, 2015

General-duty citation text

NYSLL Article 2, Section 27-(a)(3)(a)(1):  The employer did not
furnish to each of its employees, employment and a place of
employment which was free from recognized hazards that were causing
or were likely to cause death or serious physical harm to its
employees and which will provide reasonable and adequate protection
to the lives, safety or health of its employees.  In applying this
paragraph, fundamental distinctions between private and public
employment have been recognized:
a) Hague Town Wastewater Treatment Plant (WWTP) - The employer did
not keep the workplace free from the lifting/lowering hazards
created by the lack of effective hazard control measures while
removing/replacing one hundred pound grinder pumps at various
locations throughout the sewer system, such as, but not limited to,
the Graphite Mountain Road grinder pump station, Hollman Hill Road,
and the Lake Shore Drive grinder pump stations. The town sewer
sytem contains approximately 300 such pumps maintained by the
employees. On or about 5/9/2013, an employee suffered lower back
injuries while two employees were removing an inoperable grinder
pump (Environment One, model DH071-93) from its four foot deep well
on Graphite Mountain Road. On 5/28/2014, the same employee suffered
lower back injuries while removing a grinder pump (Environment One,
model DH071-93) on Hollman Hill Road.
Alleged hazard:  The lifting hazard created by inadequate control
measures during manual lifting procedures to remove grinder pumps
from service and replace them with operable units.
Conditions observed:  According to information from illness and
injury records and employees who were present when the injuries
occurred, an employee's lower back was injured while removing
grinder pumps from their wells.
Determination:  Section 27-a(3)(a)(1) of the PESH Act requires that
"Every employer shall: (1) Furnish to each of its employees,
employment and a place of employment which was free from recognized
hazards that were causing or were likely to cause death or serious
physical harm to its employees and which will provide reasonable
and adequate protection to the lives, safety or health of its
employees." In this instance, the hazard described below may cause
serious physical harm, but is unlikely to cause death. The employer
was in violation of the General Duty Clause for the following
reasons:
(1) The employer failed to keep the workplace free from a hazard to
which employees were exposed;
Hague Town WWTP did not keep the workplace free from the back
injury hazards created by the lack of effective hazard control
measures while lifting/replacing grinder pumps for service. On or
about 5/9/2013, an employee suffered lower back injuries while two
employees were removing an inoperable Environment One grinder pump,
model DH071-93, from its 4 foot deep well on Graphite Mountain
Road. Also, on 5/28/2014, the same employee suffered lower backinjuries
while removing the same model of grinder pump on Hollman
Hill Road.
An evaluation of this lifting task was conducted using the
guidelines explained in the U.S. Department of Health and Human
Services (DHHS) and National Institute for Occupational Safety and
Health (NIOSH) January 1994 joint publication "Applications Manual
for the Revised NIOSH Lifting Equation" (DHHS/NIOSH publication No.
94-110). These guidelines include the impact of epidemiological,
biomechanical, physiological, and psychophysical criteria expressed
in algebraic form. The NIOSH 1991 lifting calculator was downloaded
from the OSHA ergonomics website and used to do the calculations.
The evaluation results indicate that both employees were exposed to
a significant lifting hazard that would be likely to cause serious
back injury.
(2) The hazard was recognized;
The U.S. Department of Health and Human Services (DHHS) and
National Institute for Occupational Safety and Health (NIOSH) both
recognize and provide a way to quantify the hazard created from
lifting heavy objects such as these pumps. In January 1994, DHHS
and NIOSH jointly published "Applications Manual for the Revised
NIOSH Lifting Equation" (DHHS/NIOSH publication No. 94-110). These
guidelines include the impact of epidemiological, biomechanical,
physiological, and psychophysical criteria expressed in algebraic
form.
The wastewater industry recognizes the hazard created by lifting
pumps and other heavy equipment because the industry commonly
installs mechanical lifting aides for heavy equipment movement
tasks, such as grinder pump removal, in WWTPs and field locations.
The Hague Tn WWTP was provided a davit crane to assist with lifting
pumps at the plant. Since the same task is accomplished at field
locations, it is foreseeable that the same potential hazards would
exist when those tasks are accomplished at field locations.
(3) The hazard was causing or likely to cause death or serious
physical harm;
The manual, two-man lifting procedures used to remove the grinder
pumps from service resulted in lower back injury to the same
employee on two seperate occassions.
(4) A reasonable and adequate method to abate the hazard exists;
A reasonable and adequate method to correct the hazard includes,
but is not limited to, developing and implementing grinder pump
removal/replacement procedures with adequate engineering or
administrative control strategies to prevent these types of
injuries, such as: stair access to repair pump in place, placing
the pumps at grade, using appropriate lifting equipment, or using
contractors with appropriate lifting equipment.

Issued

Mar 17, 2015

Abate by

May 1, 2015

Issued

Mar 17, 2015

Abate by

Jul 24, 2015

Issued

Mar 17, 2015

Abate by

Jul 24, 2015

Issued

Mar 17, 2015

Abate by

Jul 24, 2015

Issued

Mar 17, 2015

Abate by

Mar 20, 2015

Issued

Mar 17, 2015

Abate by

Apr 10, 2015