OSHA issues Willfuls & Repeats for PRCS, PPE, Respirators w/ some HAZCOM, Fire Extinguisher, and Electrical citations for good measure

OSHA has cited an energy services company with 13 safety and health violations – including two willfuls and three repeats – for exposing workers to flash fires and other hazards. OSHA opened an inspection after two workers were injured by a fire that occurred in an oil and gas field tank (e.g. frac tank). Proposed penalties total $246,000.  OSHA found that the employer had failed to ensure that the air inside the tank was tested for flammable or toxic materials before providing employees with electrical equipment that is capable of causing a potentially flammable environment to ignite.  Here is a breakdown of these citation associated with an entry into a PRCS gone wrong…

The REPEAT violations include: (OSHA cited the company for similar violations in August 2011)

  • failing to provide eye and face protection,
  • communicate chemical hazard information to workers and
  • protect flexible electric cords from damage.  .

One of the willful violations involves failing to implement a respiratory protection program that includes an evaluation of respiratory hazards, medical evaluations for workers, fit testing, training, and the proper means to clean and store the respirators. The other violation involves failing to implement a permit-required confined space entry program that includes atmospheric testing, proper written permits, a qualified attendant and rescue plans. 

Eight serious violations include:

  • failing to ensure that electrical equipment such as a portable lamp is approved for hazardous locations,
  • maintain electrical conductors and cords in a safe operating condition,
  • train workers on the proper use of personal protective equipment,
  • consult workers on confined space entry procedures and
  • maintain fire extinguishers in a proper working condition. 

Here is breakdown of the actual citations:

PPE

  • employees cleaning the inside of frac tanks that contain gas field waste without proper PPE (1910.132(f)(1); Serious; $6K)
  • goggles and face shields not used when working inside frac tanks with chemical exposures (1910.133(a)(1); Repeat; $30,000)

Confined Space

  • employees were not consulted on the development and implementation of the confined space program (1910.146(l)(1); Serious; $7K)
  • No written PRCS Entry program (1910.146(c)(4); Willful; $70,000) 

Fire Extinguishers

  • fire extinguishers were not maintained in a charged and operable condition (1910.157(c)(4); Serious; $5K)

Electrical 

  • Two (2) electrical boxes had unlabled circuits (1910.303(f)(2); Serious; $5K)
  • Unguarded voltage over 50 volts (1910.303(g)(2)(i); Serious; $5K)
  • Failure of personnel to use GFCI with portable tools (1910.304(b)(3)(ii)(A); Serious; $7K)
  • Unused opening on electrical boxes/cabinets (1910.305(b)(1)(ii); Serious; $4K)
  • Non-rated electrical equipment used inside farc tanks (HAZLOC) (1910.307(c)(2)(i); Serious; $7K)
  • extension cords run across gravel parking lot to frac tabnks not protected from damage from vehicle damage (1910.305(a)(2)(i); Repeat; $15,000)
  • power cords for lights inside frac tanks did not have strain relief (1910.305(g)(2)(iii); Repeat; $0)

Respirators

  • No established respiratory protection program (1910.134(c)(1); Willful; $55,000)

HAZCOM

  • No written HAZCOM program (1910.1200(e)(1); Repeat; $30,000)
  • No HAZCOM training (1910.1200(h)(1); Repeat; $0) 
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