OSHA Inspection: CRU LOGISTICS, LLC

Issued

Nov 8, 2019

Abate by

Nov 18, 2019

Penalty

Initial $9,282 · Current $8,354 Reduced

General-duty citation text

29 CFR 1910.134(c)(1): A written respiratory protection program that included the provisions in 29 CFR 1910.134(c)(1)(i) - (ix) with worksite specific procedures was not established and implemented for required respirator use:    Railcar Cleaning Terminals:  On or about May 10, 2019, and at times prior thereto, employees were exposed to chemical fire, and explosion hazards, while conducting, the de-heeling process inside the railcar tankers containing chemical commodity such as, but not limited to, natural gas condensate and sweet crude oil as employer did not consistently ensure that employees wore tight-fitting full/half-facepiece respirators with organic vapor cartridges or self-contained breathing apparatus.

Issued

Nov 8, 2019

Abate by

Nov 18, 2019

Penalty

Initial $9,282 · Current $8,354 Reduced

General-duty citation text

29 CFR 1910.134(d)(1)(iii): The employer did not identify and evaluate the respiratory hazard(s) in the workplace; including a reasonable estimate of employee exposures to respiratory hazards and identification of the contaminant's chemical state and physical form:      Railcar Cleaning Terminals:  On or about May 10, 2019, and at times prior thereto, employees were exposed to respiratory hazards while conducting the de-heeling process inside railcar tankers while wearing tight-fitting full/half-facepiece respirators with organic vapor cartridges or self contained breathing apparatus without an atmospheric evaluation performed prior to entry and during the course of work operations within the railcar.

Issued

Nov 8, 2019

Abate by

Nov 18, 2019

Penalty

Initial $9,282 · Current $8,354 Reduced

General-duty citation text

29 CFR 1910.134(g)(2)(i): When there was a change in the work area, conditions, or degree of employee exposure or stress that may effect respirator effectiveness, the employer did not reevaluate the continued effectiveness of the respirator:    Railcar Cleaning Terminals:  On or about May 10, 2019, and at times prior thereto, employees were exposed to respiratory hazards while wearing tight-fitting full/half-facepiece respirators with organic vapor cartridges for the de-heeling process inside railcar tankers instead of a supplied air respirator to protect from hazardous chemicals such as, but not limited to natural gas condensate, sweet crude oil, and hydrocarbon sludge.

Issued

Nov 8, 2019

Abate by

Nov 18, 2019

Penalty

Initial $9,282 · Current $8,354 Reduced

General-duty citation text

29 CFR 1910.134(h)(1): Respirators were not cleaned and disinfected using the procedures in Appendix B-2 of 29 CFR 1910.134 or equivalent procedures recommended by the respirator manufacturer:    Railcar Cleaning Terminals:  On or about May 10, 2019, and at times prior thereto, employees were exposed to health and respiratory hazards while using tight-fitting full/half-facepiece respirators with organic vapor cartridges, that were not cleaned and disinfected, for the de-heeling process inside railcar tankers that contained chemical commodity such as, but not limited to, natural gas condensate, sweet crude oil, nano-dissolve, and hydrocarbon sludge

Issued

Nov 8, 2019

Abate by

Nov 18, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(h)(2)(i): Respirators were not stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals or were not packed or stored to prevent deformation of the facepiece and exhalation valve:        Railcar Cleaning Terminals: On or about May 10, 2019, and at times prior thereto, employees were exposed to health and respiratory hazards while using tight-fitting full/half-facepiece respirators with organic vapor cartridges, that were found outside on the bench and the ground, exposing them to the outside elements.

Issued

Nov 8, 2019

Abate by

Nov 18, 2019

Penalty

Initial $3,978 · Current $3,580 Reduced

General-duty citation text

29 CFR 1910.134(h)(2)(ii)(B): Emergency respirators were not stored in compartments or in covers that were clearly marked as containing emergency respirators:      Railcar Platforms:  On or about May 10, 2019, and at times prior thereto, employees were exposed to respiratory hazards, while storing Scott Luxfer 4500 PSI rescue bottles in unmarked containers without making them readily identifiable for employees performing cleaning operations inside railcar tankers.

Issued

Nov 8, 2019

Abate by

Nov 18, 2019

Penalty

Initial $9,282 · Current $8,354 Reduced

General-duty citation text

29 CFR 1910.134(l)(1): Evaluations of the workplace were not conducted to ensure the written respiratory protection program was being effectively implemented:       On or about May 10, 2019, and at times prior thereto, employees were exposed to respiratory hazards while performing cleaning and washing operations of railcar tankers without consistently evaluating as necessary the effectiveness of the respiratory protection used for the type of commodity present as outlined in their written program.

Issued

Nov 8, 2019

Abate by

Nov 18, 2019

Penalty

Initial $9,282 · Current $8,354 Reduced

General-duty citation text

29 CFR 1910.1200(h)(3)(iii): The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used:      On or about May 10, 2019, and at times prior thereto, employees were exposed to health and respiratory hazards, while not having safety data sheets readily available, although onsite and available to managers, for the de-heeling process inside railcar tankers.