At 10 p.m. on 3/19/18, an employee and coworker were performing preventative maintenance on a chlorine gas system used in a water filtration process. The employee and coworker were removing and reinstalling, a flange with a black Teflon rubber gasket. They were working in a 48-foot long, 24-foot wide, and 6-foot tall crawl space under a chlorine cylinder storage building. The schedule 80 polyvinyl chloride (PVC) chlorine pipes that were connected to the flange were under vacuum and purged before the work began in an attempt to remove residual chlorine gas. The employees were required to wear a Self-Contained Breathing Apparatus (SCBA), 4,500 PSI, with a Full Facepiece as protection against any residual chlorine gas. Near the end of the work, one of the employees adjusted their tight-fitting, elastomeric facepiece and inhaled residual chlorine gas. The employee became agitated and while attempting to exit the crawl space further dislodged the tight-fitting elastomeric facepiece. The employee was hospitalized. The employee was reported to have a beard.
This is a classic example of improper use of respirators with the blasted facial hair raising its ugly head. It sounds like the employee got a dose of Chlorine while adjusting his mask, panicked and must have thought he was in fresh air and fully removed his facepiece before he exited the space and got a bigger dose. We should ALWAYS be using a calibrated meter to monitor the atmosphere, EVEN WHEN USING AN SCBA! ANd for the love of your God – SHAVE your friggin’ face when you are in a respiratory protection program!
NOTE 1: I do not understand all of these citations with no penalty. This was in MD and this was a public water treatment facility. MD-OSHA is a STATE PLAN so they cover municipal facilities, but in this case, they issued 22 citations with ZERO in $’s.
NOTE 2: Based on the citations, OSHA must have established the 48′ long, 24′ wide, and 6′ tall “crawl space” (more like a “tunnel”) was a PRCS. As we can see from their summary, there are flanges in the Chlorine Piping within this space and that provided the “potential for a hazardous atmosphere” and I have to assume that the means to get into this “crawl space”/”tunnel” was by ladder or some other “restricted means of entry/exit”.
The facility is contesting the citations.
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Violation Summary
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|---|---|---|---|---|---|---|
| Serious | Willful | Repeat | Other | Unclass | Total | |
| Initial Violations | 22 | 22 | ||||
| Current Violations | 22 | 22 | ||||
| Initial Penalty | $0 | $0 | $0 | $0 | $0 | $0 |
| Current Penalty | $0 | $0 | $0 | $0 | $0 | $0 |
| Violation Items | |||||||||
|---|---|---|---|---|---|---|---|---|---|
| # | ID | Type | Standard | Issuance | Abate | Curr$ | Init$ | Contest | LastEvent |
| 1. | 01001 | Serious |
19100119 C01 – Employers shall develop a written plan of action regarding the implementation of the employee participation required by this paragraph. |
06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 2. | 01002 | Serious |
19100119 D01 – No Information pertaining to the hazards of the highly hazardous chemicals in the process. |
06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 3. | 01003 | Serious | 19100119 E01 – No PHA done | 06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 4. | 01004 | Serious | 19100119 F01 – No SOPs | 06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 5. | 01005 | Serious | 19100119 G03 – No training documentation | 06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 6. | 01006 | Serious | 19100119 J02 – No MI procedures | 06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 7. | 01007 | Serious | 19100119 L01 – No MOC program | 06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 8. | 01008 | Serious |
19100134 C01 I – Procedures for selecting respirators for use in the workplace; |
06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 9. | 01009 | Serious |
19100134 C01 II – Medical evaluations of employees required to use respirators; |
06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 10. | 01010 | Serious | 19100134 C01 III – Fit testing procedures for tight-fitting respirators; | 06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 11. | 01011 | Serious |
19100134 C01 VI – Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators; |
06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 12. | 01012 | Serious |
19100134 C03 – The employer shall designate 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 program effectiveness. |
06/19/2018 | 06/27/2018 | $0 | $0 | 07/03/2018 | – |
| 13. | 01013 | Serious |
19100134 E01 – 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. |
06/19/2018 | 06/27/2018 | $0 | $0 | 07/03/2018 | – |
| 14. | 01014 | Serious |
19100134 F01 – The employer shall ensure that employees using a tight-fitting facepiece respirator pass an appropriate qualitative fit t est (QLFT) or quantitative fit test (QNFT) as stated in this paragraph. |
06/19/2018 | 06/27/2018 | $0 | $0 | 07/03/2018 | – |
| 15. | 01015 | Serious |
19100134 G01 I A – Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or |
06/19/2018 | 06/27/2018 | $0 | $0 | 07/03/2018 | – |
| 16. | 01016 | Serious |
19100134 L01 – The employer shall conduct evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective. |
06/19/2018 | 06/27/2018 | $0 | $0 | 07/03/2018 | – |
| 17. | 01017 | Serious |
19100146 C01 – The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces. |
06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 18. | 01018 | Serious |
19100146 C04 – 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. |
06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 19. | 01019 | Serious |
19100146 E01 – Before entry is authorized, the employer shall document the completion of measures required by paragraph (d)(3) of this section by preparing an entry permit. |
06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 20. | 01020 | Serious |
19100146 G01 – The employer shall provide training so that all employees whose work is regulated by this section acquire the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under this section. |
06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 21. | 01021 | Serious |
19100146 K01 – An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of this section |
06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |
| 22. | 01022 | Serious |
19100146 L01 – Employers shall consult with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program required by paragraph (c) of this section. |
06/19/2018 | 07/23/2018 | $0 | $0 | 07/03/2018 | – |

