OSHA Inspection: RI-NU ENVIRONMENTAL SERVICES, MILANO, LLC

Issued

Feb 1, 2018

Abate by

Feb 21, 2018

Penalty

Initial $4,434 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.134(c)(1): In any workplace where respirators are necessary to protect employee health or respirators are required by the employer, a written respiratory protection program that included the provisions in 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented:    The employer had not developed and implemented a written respiratory protection program with worksite-specific procedures and elements for required respirator use that complied with 29 CFR 1910.134(c), included but not limited to:    (1) Procedures for selecting respirators for use in the workplace in compliance with 1910.134(d);  (2) Medical evaluation of employees required to use respirators in compliance with 1910.134(e);  (3) Fit testing procedures for tight-fitting respirators in compliance with 1910.134(f);  (4) Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations in compliance with 1910.134(g);  (5) Procedures for schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators in compliance with 1910.134(h);  (6) Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators in compliance with 1910.134(i);  (7) Training of employees in the respiratory hazards to which they are potentially exposed to during routine and emergency situations in compliance with 1910.134(k);  (8) Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance in compliance with 1910.134(k);  (9) Procedures for regularly evaluating the effectiveness of the program in compliance with 1910.134(l); and   (10) Designating a program administrator who is qualified by appropriate training or experience that is commensurate with the complexity of the program to administer or oversee the respiratory protection program and conduct the required evaluations of the program effectiveness.  On or about November 14, 2017, and at times prior thereto, in the frac tank wash rack area, employees were required to wear tight-fitting respirators including, but not limited to, 3M 7503 half-face piece respirators with 3M 6002 cartridges without the protection afforded by a respiratory protection program. Employees routinely entered tanks that had been used in oil/gas field hydraulic fracturing operations to perform tasks such as pressure washing. Employees were exposed to the hazards of potential oxygen deficient atmospheres and/or inhalation of toxic gases or vapors.

Issued

Feb 1, 2018

Abate by

Feb 21, 2018

Penalty

Initial $51,734 · Current $36,000 Reduced

General-duty citation text

29 CFR 1910.146(c)(4): When the employer decided that its employees would enter permit spaces, the employer did not develop and implement a written permit space entry program that complied with the following:    (1) 1910.146(d)(2), Identify and evaluate the hazards of permit spaces before employees enter them;  (2) 1910.146(d)(5)(ii), Test or monitor the permit space as necessary to determine if acceptable entry conditions are being maintained during the course of entry operations;  (3) 1910.146(d)(8), Designate the persons who are to have active roles (as, for example, authorized entrants, attendants, entry supervisors, or persons who test or monitor the atmosphere in a permit space) in entry operations, identify the duties of each such employee, and provide each such employee with the training required by paragraph (g) of this section;  (4) 1910.146(d)(9), Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue;  (5) 1910.146(d)(10, Develop and implement a system for the preparation, issuance, use, and cancellation of entry permits as required by this section;  (6) 1910.146(d)(12), Develop and implement procedures (such as closing off a permit space and canceling the permit) necessary for concluding the entry after entry operations have been completed;  (7) 1910.146(d)(14), Review the permit space program, using the canceled permits retained under paragraph (e)(6) of this section within 1 year after each entry and revise the program as necessary, to ensure that employees participating in entry operations are protected from permit space hazards; and  (8) 1910.146(e)(2), Before entry begins, the entry supervisor identified on the permit shall sign the entry permit to authorize entry.    On or about November 14, 2017, in the wash rack area, employees are routinely entering and cleaning frac tanks without the employer developing and implementing a written permit confined space entry program.

Issued

Feb 1, 2018

Abate by

Feb 21, 2018

Penalty

Initial $739 · Current $739

General-duty citation text

29 CFR 1904.29(a): A Log of all Work-Related Injuries and Illnesses (OSHA Form 300), and/or Summary of Work-Related Injuries and Illnesses, (OSHA Form 300-A), and/or the Injury and Illness Incident Report (OSHA Form 301) or equivalent forms were not kept by the establishment:  On or about July 20, 2017, and at times prior thereto, recordable injuries were not recorded on the OSHA 301 Incident Report Forms or equivalent forms.