OSHA Inspection: ARMADA E&P OH, LLC

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $8,525 · Current $5,200 Reduced

General-duty citation text

29 CFR 1910.28(b)(1)(i): (1) Unprotected sides and edges.  (i) Except as provided elsewhere in this section, the employer must ensure that each employee on a walking-working surface with an unprotected side or edge that is 4 feet (1.2 m) or more above a lower level is protected from falling by one or more of the following:  1910.28(b)(1)(i)(A) Guardrail systems; 1910.28(b)(1)(i)(B) Safety net systems; or 1910.28(b)(1)(i)(C) Personal fall protection systems, such as personal fall arrest, travel restraint, or positioning systems.   a. On and/or before August 1, 2019, in the pit area, the employer did not ensure that employees who performed activities such as cleaning, dumping, mixing and loading boxes of material around pit #1 were protected from falls up to 10 feet into the pit.    b. On and/or before August 1, 2019, in the pit area, the employer did not ensure that employees who performed activities such as cleaning, dumping, mixing and loading boxes of material around pit #2 were protected from falls up to 10 feet into the pit.   c. On and/or before August 1, 2019, in the washout area, the employer did not ensure that employees who performed washout activities by climbing up onto the bottle trucks and tankers were always protected from falls up to approximately 13 feet, 6 inches.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $5,115 · Current $3,000 Reduced

Hazardous substances 0515

General-duty citation text

29 CFR 1910.134(e)(1): General. The employer shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.     a. On or about September 23, 2019, in the pit area, the employer did not provide a medical evaluation for an employee required to use a 3M 6100 tight-fitting half facepiece respirator while mixing AMG Vanadium LimeAdd (corrosive) into the waste material in pit #2.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 0515

General-duty citation text

29 CFR 1910.134(f)(2): The employer shall ensure that an employee using a tight-fitting facepiece respirator is fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.     a. On or about September 23, 2019, in the pit area, the employer did not ensure that an employee required to use a 3M 6100 tight-fitting half facepiece respirator while mixing AMG Vanadium LimeAdd (corrosive) into the waste material in pit #2 was fit tested prior to initial use of the respirator.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 0515

General-duty citation text

29 CFR 1910.134(g)(1)(i): The employer shall not permit respirators with tight-fitting facepieces to be worn by employees who have:   29 CFR 1910.134(g)(1)(i)(A): Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function.    a. On or about September 23, 2019, in the pit area, the employer did not ensure that an employee required to use a 3M 6100 tight-fitting half facepiece respirator while mixing AMG Vanadium LimeAdd (corrosive) into the waste material in pit #2 was clean-shaven with no facial hair coming between the sealing surface of the respirator and face.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $0 · Current $0

Hazardous substances 0515

General-duty citation text

29 CFR 1910.134(h)(3)(ii): The employer shall ensure that respirator inspections include the following:   29 CFR 1910.134(h)(3)(ii)(A): A check of respirator function, tightness of connections, and the condition of the various parts including, but not limited to, the facepiece, head straps, valves, connecting tube, and cartridges, canisters or filters.   a. On or about September 23, 2019, in the pit area, the employer did not ensure that an employee required to use a 3M 6100 tight-fitting half facepiece respirator while mixing AMG Vanadium LimeAdd (corrosive) into the waste material in pit #2 was using the correct cartridges.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $8,525 · Current $5,200 Reduced

General-duty citation text

29 CFR 1910.146(c)(4): If the employer decides that its employees will enter permit spaces, the employer shall develop and implement a written permit space program that complies with this section. The written program shall be available for inspection by employees and their authorized representatives.       a. On and/or before September 23, 2019, for permit required confined spaces at the facility, the employer's written Confined Space Entry Program, Document Number: HSMS-04, was not fully developed in that the Facility-Specific Information sections were not completed including, but not limited to, the following: Acceptable Entry Conditions; Identification and Labeling of Confined Spaces; Ventilation; Air Monitoring; Emergency Procedures; and Training.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $8,525 · Current $0 Reduced

General-duty citation text

29 CFR 1910.146(d): Permit-required confined space program (permit space program). Under the permit space program required by paragraph (c)(4) of this section, the employer shall:     29 CFR 1910.146(d)(3): Develop and implement the means, procedures, and practices necessary for safe permit space entry operations, including, but not limited to, the following:      29 CFR 1910.146(d)(3)(iii): Isolating the permit space.     a. On and/or before August 29, 2019, in the washout area, the employer did not develop and implement the means, procedures, and practices for isolating the permit space such as ensuring that the driver's key was under the exclusive control of the employees performing entry into the bottle trucks and tankers which could include lockout/tagout.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $8,525 · Current $0 Reduced

General-duty citation text

29 CFR 1910.146(e)(5): The entry supervisor shall terminate entry and cancel the entry permit when:     29 CFR 1910.146(e)(5)(i): The entry operations covered by the entry permit have been completed.     a. On and/or before August 29, 2019, in the washout area, the employer did not ensure that the entry supervisors canceled the entry permits after entry permits had been completed for entries made into bottle trucks and tankers.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(f): Entry permit. The entry permit that documents compliance with this section and authorizes entry to a permit space shall identify:     a. On and/or before August 29, 2019, in the washout area, the employer did not ensure that all of the entry permits authorizing entries into bottle trucks and tankers identified the following: authorized duration of the entry permit [(f)(3)]; signature or initials of the entry supervisor [(f)(6)]; measures used to isolate the permit space and to eliminate or control permit space hazards before entry, such as controlling the driver's key, chocking the tires, and using orange cones [(f)(8)]; results of initial and periodic tests performed under paragraph (d)(5) of this section, accompanied by the names or initials of the testers and by an indication of when the tests were performed [(f)(10)]; rescue and emergency services that can be summoned and the means (such as the equipment to use and the numbers to call) for summoning those services [(f)(11)]; and equipment, such as personal protective equipment and testing equipment [(f)(13)].

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $11,934 · Current $7,435 Reduced

General-duty citation text

29 CFR 1910.146(d): Permit-required confined space program (permit space program). Under the permit space program required by paragraph (c)(4) of this section, the employer shall:   29 CFR 1910.146(d)(4): Provide the following equipment (specified in paragraphs (d)(4)(i) through (d)(4)(ix) of this section) at no cost to employees, maintain that equipment properly, and ensure that employees use that equipment properly:   29 CFR 1910.146(d)(4)(viii): Rescue and emergency equipment needed to comply with paragraph (d)(9) of this section, except to the extent that the equipment is provided by rescue services.   a. On and/or before August 29, 2019, in the washout area, the employer did not provide and ensure that employees used rescue and emergency equipment to facilitate at a minimum non-entry rescue of employees performing entry inside bottle trucks and tankers.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(k)(3): To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval systems shall meet the following requirements.   a. On and/or before August 29, 2019, in the washout area, the employer did not ensure the use of retrieval systems or methods to facilitate non-entry rescue for employees performing entry into bottle trucks and tankers including compliance with the following requirements:     1910.146(k)(3)(i)  Each authorized entrant shall use a chest or full body harness, with a retrieval line attached at the center of the entrant's back near shoulder level, above the entrant's head, or at another point which the employer can establish presents a profile small enough for the successful removal of the entrant. Wristlets may be used in lieu of the chest or full body harness if the employer can demonstrate that the use of a chest or full body harness is infeasible or creates a greater hazard and that the use of wristlets is the safest and most effective alternative.      1910.146(k)(3)(ii)  The other end of the retrieval line shall be attached to a mechanical device or fixed point outside the permit space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary. A mechanical device shall be available to retrieve personnel from vertical type permit spaces more than 5 feet (1.52 m) deep.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $11,934 · Current $7,436 Reduced

General-duty citation text

29 CFR 1910.146(d): Permit-required confined space program (permit space program). Under the permit space program required by paragraph (c)(4) of this section, the employer shall:   29 CFR 1910.146(d)(5): Evaluate permit space conditions as follows when entry operations are conducted:   29 CFR 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.   a. On and/or before August 29, 2019, in the washout area, the employer did not ensure that testing or monitoring was conducted through intermittent and/or continuous monitoring to determine if acceptable entry conditions were being maintained during the course of entry operations into bottle trucks and tankers.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $8,525 · Current $1,729 Reduced

General-duty citation text

29 CFR 1910.151(c): Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.     a. On and/or before September 23, 2019, in the pit area, an eyewash/shower was not provided for employees who performed activities such as mixing AMG Vanadium LimeAdd (corrosive) into the waste material in pit #1.     b. On and/or before September 23, 2019, in the pit area, an eyewash/shower was not provided for employees who performed activities such as mixing AMG Vanadium LimeAdd (corrosive) into the waste material in pit #2.

Issued

Nov 12, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(c)(1): The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces.  NOTE: Proper application of the decision flow chart in Appendix A to section 1910.146 would facilitate compliance with this requirement.   a. On and/or before September 23, 2019, in the pit area, the employer did not evaluate the workplace to determine if all spaces were permit-required confined spaces such as pit #1 and pit #2.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.146(c)(2): If the workplace contains permit spaces, the employer shall inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces.  NOTE: A sign reading DANGER -- PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER or using other similar language would satisfy the requirement for a sign.     a. On and/or before September 23, 2019, in the pit area, the employer did not have confined space signs posted or other effective means to inform employees of the existence and location of and the danger posed by permit-required confined spaces such as pit #1 and pit #2.   b. On and/or before September 23, 2019, in the washout area, the employer did not have confined space signs posted or other effective means to inform employees of the existence and location of and the danger posed by permit-required confined spaces such as the bottle trucks and tankers.

Issued

Nov 12, 2019

Abate by

Dec 16, 2019

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1096(e)(2): Radiation area. Each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol described in subparagraph (1) of this paragraph and the words:   CAUTION  RADIATION AREA   a. On and/or before August 1, 2019, in the pit area, the employer did not ensure that a radiation sign or signs were posted where employees performed activities such as cleaning, dumping, mixing and loading boxes of material in and around the pits that contained radioactive waste.    b. On and/or before August 1, 2019, in the washout area, the employer did not ensure that a radiation sign or signs were posted where employees performed washout activities of bottle trucks and tankers that contained radioactive waste.