A few weeks ago we were debating in my FaceBook Group about these vaults being a PRCS. The picture in question (shown to the left – full scale in the article) had a working platform just a little more than 4′ down inside the vault, but the fixed ladder went all the way down to the bottom of the vault, approximately 12′ – 14′ deep. The platform was built with steel grating. This meant (to me at least) that the vault was one (1) – a single space as a worker on the platform would be exposed to the same hazards below the platform (e.g. an explosion/flash fire in the bottom of the vault would impact the worker on the platform). This became a heated debate, which really surprised me as were are still debating what a CS and PRCS are in the Year 2020! But as usual, there is an OSHA Case file that I base my argument on. My apologies for the late post!
The case involved a worker using a piece of NON-RATED electrical equipment inside the vault, which held an underground gasoline storage tank at a gas station. The NON-RATED electrical equipment ignited the gasoline vapors that had found their way into the vault and accumulated to make up at least 1.5% of the atmosphere in the vault (e.g. gasoline’s LEL is 1.5%). Gasoline vapors are 2 X’s heavier than air so they accumulated on the floor of the vault, which just happened to be where the NON-RATED electrical equipment was being used. The worker in the vault died and his attendant sustained severe burns, but survived. Here are the full-size picture and the OSHA Case file…
NOTE: the picture is NOT an OSHA picture and is NOT related to the OSHA Case File – it is from my Facebook Group.
At 5:50 p.m. on June 12, 2018, two employees were removing excess water from the underground concrete vault which contained a metal gasoline storage tank for an automobile gasoline station. Employee #1 was using a “shop vacuum” inside the vault that was not approved for a flammable vapor environment. Employee #2 was on the surface of the parking lot near the manhole entrance of the vault. Gasoline vapors were ignited which caused a large explosion and a fire plume. Employee #1 was entrapped inside the concrete vault and killed from the blast and fire. Employee #2 sustained severe burns to the body and was transported to a hospital.
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Violation Summary
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|||||
|---|---|---|---|---|---|
| Serious | Willful | Repeat | Other | Total | |
| Initial Violations | 3 | 3 | 6 | ||
| Current Violations | 3 | 3 | 6 | ||
| Initial Penalty | $28,085 | $0 | $0 | $0 | $28,085 |
| Current Penalty | $19,992 | $0 | $0 | $0 | $19,992 |
| Violation Items | ||||||||
|---|---|---|---|---|---|---|---|---|
| # | ID | Type | Standard | Issuance | Abate | Curr$ | Init$ | LastEvent |
| 1. | 01001A | Serious |
19100146 C01 – The employer shall evaluate the workplace to determine if any spaces are permit-required confined spaces. |
11/16/2018 | 03/01/2019 | $10,000 | $12,934 | I – Informal Settlement |
| 2. | 01001B | 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. |
11/16/2018 | 03/01/2019 | $0 | $0 | I – Informal Settlement |
| 3. | 01002 | Serious |
19100307 C02 I – Equipment shall be approved not only for the class of location, but also for the ignitable or combustible properties of the specific gas, vapor, dust, or fiber that will be present. |
11/16/2018 | 12/03/2018 | $8,500 | $12,934 | I – Informal Settlement |
| 4. | 01003A | Serious |
19101200 E01 – Employers shall develop, implement, and program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, safety data sheets, and employee information and training will be met, and which also includes the following: … |
11/16/2018 | 12/03/2018 | $1,492 | $2,217 | I – Informal Settlement |
| 5. | 01003B | Serious |
19101200 H01 – Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and safety data sheets. |
11/16/2018 | 12/03/2018 | $0 | $0 | I – Informal Settlement |
| 6. | 02001 | Other |
19100028 B01 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: |
11/16/2018 | $0 | $0 | I – Informal Settlement | |
| 7. | 02002 | Other |
19100029 F04 – Openings in stair rails. No opening in a stair rail system exceeds 19 inches (48 cm) at its least dimension. |
11/16/2018 | 12/03/2018 | $0 | $0 | I – Informal Settlement |
| 8. | 02003 | Other |
19100134 C01 – In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer shall establish and implement a written respiratory protection program with worksite-specific procedures. The program shall be updated as necessary to reflect those changes in workplace conditions that affect respirator use. The employer shall include in the program the following provisions of this section, as applicable: |
11/16/2018 | 01/15/2019 | $0 | $0 | I – Informal Settlement |
CLICK HERE for the OSHA file
