OSHA Inspection: BORDERLINE SERVICES, LLC

Issued

Aug 23, 2017

Abate by

Sep 27, 2017

Penalty

Initial $2,390 · Current $1,419 Reduced

General-duty citation text

29 CFR 1910.95(d)(1): A representative monitoring program was not developed and implemented when information indicated that an employee's exposure may equal or exceed an 8-hour time weighted average of 85 dBA.    a) At the facility, in the wash bay, the employer did not conduct representative personal noise exposure monitoring when employees used a 5000 psi pressure washer and angle grinder to clean the interior of steel tanker trailers, exposing employees to noise hazards.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $3,585 · Current $2,151 Reduced

Hazardous substances 03201080177418102037

General-duty citation text

29 CFR 1910.132(d)(1)(i): The employer did not select, and have each affected employee use, the types of PPE that would protect the affected employee from the hazards identified in the hazard assessment.    a) At the facility, on March 8, 2017, the employer did not select the type of PPE to protect employees cleaning chemical waste inside Fort tank trailer 3122RI, containing EPONT resin 1007-CT contents including toluene and methyl isobutyl ketone.    b) At the facility, on March 10, 2017, the employer did not select the type of PPE to protect employees cleaning chemical waste inside Sprint tank trailer F0484, containing Slop Oil contents including hexane, xylenes, toluene, benzene, ethyl benzene, isobutane, isohexane, and 2-methyl butane.    c) At the facility, on February 14, 2017, the employer did not select the type of PPE to protect employees cleaning chemical waste inside Rain for Rent tank trailers 251925, 259416, and 251366, containing Gas Oil Straight Run contents including crude oil petroleum distillates.    d) At the facility, on February 22, 2017 the employer did not select the type of PPE to protect employees cleaning chemical waste inside Sprint tank trailers 30-1227, 35-1214, and 40-1715, containing Waste, Corrosive Liquids contents including methyl methacrylate.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $4,183 · Current $2,510 Reduced

General-duty citation text

29 CFR 1910.134(d)(1)(iii): When the employer was unable to identify or reasonably estimate the employee exposure, the employer did not consider the atmosphere to be IDLH:     a) At the facility, on March 8, 2017, during opening, assessment and cleaning of EPONT resin 1007-CT waste inside Fort tank trailer 3122RI, the employer did not identify and estimate employee exposure to toluene and methyl isobutyl ketone, and did not consider the atmosphere to be IDLH.        b) At the facility, on March 10, 2017, during opening, assessment and cleaning of Slop Oil waste inside Sprint tank trailer F0484 the employer did not identify and estimate employee exposure to hexane, xylene, toluene, benzene, ethyl benzene, isobutane, isohexane, and 2-methyl butane, and did not consider the atmosphere to be IDLH.          c) At the facility, on February 14, 2017, during opening, assessment and cleaning of Gas Oil - Straight Run waste inside Rain for Rent tank trailers 251925, 259416, and 251366 the employer did not identify and estimate employee exposure to petroleum distillates and naphthalene and did not consider the atmosphere to be IDLH.          d) At the facility, on February 22, 2017, during opening, assessment and cleaning of Corrosive Liquid waste inside Sprint tank trailers 30-1227, 35-1214, and 40-1715 the employer did not identify and estimate employee exposure to methyl methacrylate, sulfuric acid, lead and chromium and did not consider the atmosphere to be IDLH.       e)  At the facility, on February 24, 2017, during opening, assessment and cleaning of Hazardous Solid waste inside Sprint roll top container RT250344 the employer did not identify and estimate employee exposure to chromium, cadmium, and crystalline silica (quartz), and did not consider the atmosphere to be IDLH.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $2,988 · Current $1,793 Reduced

General-duty citation text

29 CFR 1910.134(d)(3)(iii)(B)(2): The employer did not implement a change schedule for canisters and cartridges that was based on objective information or data that would ensure that canisters and cartridges were changed before the end of their service life:    a) At the facility, on March 10, 2017, the employer did not implement a chemical cartridge change schedule for 3M air purifying respirators used during opening, assessing and cleaning Slop Oil waste from Sprint tank trailer F0484 containing hexane, xylene, toluene, benzene, ethyl benzene, isobutene, isohexane, and 2-methyl butane, exposing employees to an inhalation hazard.    b) At the facility, on February 22, 2017, the employer did not implement a chemical cartridge change schedule for 3M air purifying respirators used during opening, assessing and cleaning corrosive liquid waste from Sprint tank trailers 30-1227, 35-1214, and 40-1715 containing methyl methacrylate, exposing employees to an inhalation hazard.    c) At the facility, on February 22, 2017, the employer did not implement a chemical cartridge change schedule for 3M air purifying respirators used during opening, assessing and cleaning corrosive liquid waste from Rain for Rent tank trailers 251925, 259416, and 251366 containing crude oil petroleum distillates and naphthalene, exposing employees to an inhalation hazard.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $3,585 · Current $2,151 Reduced

General-duty citation text

29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee's ability to use a respirator, before the employee was fit tested or required to use the respirator in the workplace:    a) At the facility, the employer directed employees to use 3M negative pressure, tight fitting respirators during cleaning of chemical waste, and did not provide a medical evaluation to determine their ability to use them.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $4,183 · Current $2,510 Reduced

General-duty citation text

29 CFR 1910.134(f)(1): The employer did not ensure that employee(s) required to use a tight-fitting face piece respirator passed the appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT):    a) At the facility, on March 6, 2017 and times theretofore the employer did not ensure employees passed the appropriate qualitative or quantitative fit test when they used 3M and Scott tight fitting face piece respirators during cleaning of chemical waste, exposing employees to an inhalation hazard.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $2,988 · Current $1,793 Reduced

General-duty citation text

29 CFR 1910.134(h)(1)(i): Respirators issued for the exclusive use of an employee were not cleaned and disinfected as often as necessary to be maintained in a sanitary condition:    a) At the facility, respirators being used by tank cleaners were not cleaned and disinfected as often as necessary to be maintained in sanitary condition, exposing employees to chemical absorption and dermatitis hazards.

Issued

Aug 23, 2017

Abate by

Sep 26, 2017

Penalty

Initial $4,183 · Current $2,510 Reduced

General-duty citation text

29 CFR 1910.134(k)(1): The employer did not provide effective training to employees who were required to use respirators:    a) At the facility, the employer did not ensure effective training was provided to employees using respirators during opening, assessment and cleaning of chemical waste containers, exposing employees to chemical hazards.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $4,183 · Current $2,510 Reduced

General-duty citation text

29 CFR 1910.146(f)(13): The entry permit that documented compliance and authorized entry to a permit space did not identify equipment, such as personal protective equipment, testing equipment, communications equipment, alarm systems, and rescue equipment.    a) At the facility, on March 8, 2017, the entry permit that documented compliance and authorized entry to Fort tank trailer 3122RI did not identify rescue, testing and communications equipment to be used.      b) At the facility, on March 10, 2017, the entry permit that documented compliance and authorized entry to Sprint tank trailer F0484 did not identify rescue, testing and communications equipment to be used.          c) At the facility, on February 14, 2017, the entry permit that documented compliance and authorized entry to Rain for Rent tank trailers 251925, 259416, and 251366 did not identify rescue, testing and communications equipment to be used.        d) At the facility, on February 22, 2017, the entry permit that documented compliance and authorized entry to Sprint tank trailers 30-1227, 35-1214, and 40-1715 did not identify rescue, testing and communications equipment to be used.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $4,183 · Current $2,510 Reduced

General-duty citation text

29 CFR 1910.146(i)(4): The employer did not ensure that each attendant remained outside the permit space during entry operations until relieved by another attendant:    a) At the facility, wash bays: On March 6, 2017 the employer did not ensure each attendant remained outside the permit space during entry into Sprint Waste tank trailer ETS N41875, exposing employees to confined space hazards.    b) At the facility, wash bays: On March 6, 2017 the employer did not ensure each attendant remained outside the permit space during entry into Fort tank trailer 3122RI, exposing employees to confined space hazards.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $4,183 · Current $2,510 Reduced

General-duty citation text

29 CFR 1910.146(k)(3): To facilitate non-entry rescue, retrieval systems or methods were not used whenever an authorized entrant entered a permit space:    a) At the facility, wash bays: On March 6, 2017 the employer did not ensure retrieval systems or methods were used when an authorized entrant entered Sprint Waste tank trailer ETS N41875, exposing employees to confined space hazards.      b) At the facility, wash bays: On March 6, 2017 the employer did not ensure retrieval systems or methods were used when an authorized entrant entered Fort tank trailer 3122RI, exposing employees to confined space hazards.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $2,988 · Current $1,793 Reduced

General-duty citation text

29 CFR 1910.151(c): Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:    a) At the facility, wash bays: On March 6, 2017 suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use when employees cleaned chemical waste containers using corrosive chemical cleaners, exposing employees to eye and skin chemical hazards.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $2,988 · Current $1,793 Reduced

Hazardous substances 0320

General-duty citation text

29 CFR 1910.1028(e)(1)(i): Determinations of employee exposure were not made from breathing zone air samples which were representative of each employee's average exposure to airborne benzene:    a) At the facility, on March 10, 2017, employees opened, assessed and cleaned  Sprint tank trailer F0484 containing Slop Oil reside, which contains benzene, and the employer did not measure employee exposure to benzene, exposing employees to a carcinogenic inhalation hazard.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $2,988 · Current $1,793 Reduced

Hazardous substances 0320

General-duty citation text

29 CFR 1910.1028(j)(3)(iii)(A): The employer did not provide employees with an explanation of the contents of 29 CFR 1910.1028 including Appendices A and B:    a) At the facility, on March 10, 2017, employees opened, assessed and cleaned Sprint tank trailer F0484 containing Slop Oil reside, which contains benzene, and the employer did not provide employees with an explanation of the contents of 29 CFR 1910.1028 including Appendices A and B, exposing employees to a carcinogenic hazard.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $8,366 · Current $5,020 Reduced

General-duty citation text

29 CFR 1910.146(d)(4)(i): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer did not provide, at no cost to the employees, testing and monitoring equipment needed to comply with 29 CFR 1910.146(d)(5):    a) At the facility, on March 6, 2017 and times theretofore the employer did not provide equipment needed to test permit-required confined space atmospheres for levels of toxic chemicals in waste, including but not limited to benzene, methyl isobutyl ketone, toluene, xylene, ethyl benzene, naphthalene, methyl methacrylate, cadmium, chromium, lead, and petroleum distillate (naphtha).     Borderline Services LLC was previously cited for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 1156115, citation number 01, item number 002 and was affirmed as a final order on 10-25-2016, with respect to a workplace located at 3077 Highway 69 North, Nederland, TX.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $8,366 · Current $5,020 Reduced

General-duty citation text

29 CFR 1910.146(f)(12): The entry permit that documented compliance and authorized entry to a permit space did not identify the communication procedures used by authorized entrants and attendants to maintain contact during the entry:    a) At the facility, on March 8, 2017, the entry permit that documented compliance and authorized entry to Fort tank trailer 3122RI did not identify communication procedures used by authorized entrants and attendants to maintain contact during the entry.       b) At the facility, on March 10, 2017, the entry permit that documented compliance and authorized entry to Sprint tank trailer F0484 did not identify communication procedures used by authorized entrants and attendants to maintain contact during the entry.           c) At the facility, on February 14, 2017, the entry permit that documented compliance and authorized entry to Rain for Rent tank trailers 251925, 259416, and 251366 did not identify communication procedures used by authorized entrants and attendants to maintain contact during the entry.         d) At the facility, on February 22, 2017, the entry permit that documented compliance and authorized entry to Sprint tank trailers 30-1227, 35-1214, and 40-1715 did not identify communication procedures used by authorized entrants and attendants to maintain contact during the entry.    Borderline Services LLC was previously cited for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 1156115, citation number 01, item number 006 and was affirmed as a final order on 10-25-2016, with respect to a workplace located at 3077 Highway 69 North, Nederland, TX.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $1,195 · Current $717 Reduced

General-duty citation text

29 CFR 1910.146(g)(4): The employer did not certify the training required by 29 CFR 1910.146(g)(1) through 29 CFR 1910.146(g)(3):    a) At the facility, the employer did not provide certify that employees making confined space entry received training required by 29 CFR 1910.146(g)(1) through 29 CFR 1910.146(g)(3).    Borderline Services LLC was previously cited for a violation of this occupational safety and health standard, which was contained in OSHA inspection number 1156115, citation number 01, item number 007 and was affirmed as a final order on 10-25-2016, with respect to a workplace located at 3077 Highway 69 North, Nederland, TX.

Issued

Aug 23, 2017

Abate by

Sep 18, 2017

Penalty

Initial $335 · Current $201 Reduced

General-duty citation text

29 CFR 1910.1200(e)(1)(i): The employer did not compile a list of the hazardous chemicals known to be present using a product identifier that was referenced on the appropriate safety data sheet:    a) At the facility, the employer's written hazard communications program did not include a list of the hazardous chemicals using a product identifier referenced on the safety data sheets for the cleaning agents being used and the hazardous chemicals in wastes being cleaned, including but not limited to benzene, toluene, methyl isobutyl ketone, methyl methacrylate, aluminum sulfate solution, phosphoric acid, and sodium hydroxide.