Knowing the limitation of your respiratory protection can mean the difference between life and death

Once again, a DOT container cleaning company had another fatal PRCS incident (2020) where we have an entrant and a would-be rescuer dying in a hazardous atmosphere – oxygen deficient.  In this incident, the would-be rescuer donned a full-face Air Purifying Respirator before he attempted his rescue effort but was overcome by the atmosphere and died.  There were so many things done wrong that led up to this tragedy – but had this individual been properly trained in the LIMITATIONS of his/her APR we maybe could have avoided one fatality. 

At 8:30 a.m. on August 12, 2020, two employees, age 23 and 30, were performing chemical tank car cleaning in two separate tank cars at the cleaning rack. Employee #1 enters the tank car to perform chemical cleaning prior to completing an entry permit, ventilating the PRCS, testing the atmosphere, and without a designated attendant.  Employee #1 becomes incapacitated during the entry.

Employee #2 arrives to perform a rescue, wearing a full-face air-purifying respirator, and enters the PRCS.

NOTE: the company has contested all 13 citations, 2 willful and 11 serious, for $419,347

Employee #2 also becomes incapacitated.

Both employees were removed from the PRCS and transported to a local hospital. Both employees died from asphyxiation.

Violation Summary
  Serious Willful Repeat Other Total
Initial Violations 11 2     13
Current Violations 11 2     13
Initial Penalty $146,283 $273,064 $0 $0 $419,347
Current Penalty $146,283 $273,064 $0 $0 $419,347

 

Violation Items
# ID Type Standard Issuance Abate Curr$ Init$ Contest
1. 01001 Serious 5A0001 02/09/2021 02/22/2021 $13,653 $13,653 03/02/2021
2. 01002A Serious

19100134 F02 – 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.

02/09/2021 03/01/2021 $9,753 $9,753 03/02/2021
3. 01002B Serious

19100134 F06 – QLFT may only be used to fit test

negative pressure air-purifying respirators that must

achieve a fit factor of 100 or less.

02/09/2021 03/01/2021 $0 $0 03/02/2021
4. 01002C Serious

19100134 D01 III – The employer shall identify and evaluate

the respiratory hazard(s) in the workplace; this evaluation

shall include a reasonable estimate of employee exposures

to respiratory hazard(s) and an identification of the

contaminant’s chemical state and physical form. Where the

employer cannot identify or reasonably estimate the

employee exposure, the employer shall consider the

atmosphere to be IDLH.

02/09/2021 03/29/2021 $0 $0 03/02/2021
5. 01003A Serious

19100134 G02 I – Appropriate surveillance shall be

maintained of work area conditions and degree of

employee exposure or stress. When there is a

change in work area conditions or degree of

employee exposure or stress that may affect

respirator effectiveness, the employer shall

reevaluate the continued effectiveness of the

respirator.

02/09/2021 03/29/2021 $13,653 $13,653 03/02/2021
6. 01003B Serious

19100146 D02 -Identify and evaluate the hazards of

permit spaces before employees enter them

02/09/2021 03/29/2021 $0 $0 03/02/2021
7. 01004 Serious

19100146 D04 I – Testing and monitoring equipment

needed to comply with paragraph (d)(5) of this section

02/09/2021 03/01/2021 $13,653 $13,653 03/02/2021
8. 01005 Serious

19100146 D04 IX – Any other equipment necessary

for safe entry into and rescue from permit spaces

02/09/2021 03/01/2021 $13,653 $13,653 03/02/2021
9. 01006 Serious

19100146 D06 – Provide at least one attendant outside

the permit space into which entry is authorized for the

duration of entry operations

02/09/2021 03/08/2021 $13,653 $13,653 03/02/2021
10. 01007A Serious

19100146 G02 III – Whenever there is a change in permit

space operations that presents a hazard about which an

employee has not previously been trained

02/09/2021 03/29/2021 $13,653 $13,653 03/02/2021
11. 01007B Serious

19100146 H01 – Know the hazards that may be faced during

entry, including information on the mode, signs or symptoms,

and consequences of the exposure;

02/09/2021 03/29/2021 $0 $0 03/02/2021
12. 01007C Serious

19100146 I01 – Knows the hazards that may be faced during

entry, including information on the mode, signs or symptoms,

and consequences of the exposure

02/09/2021 03/29/2021 $0 $0 03/02/2021
13. 01008 Serious

19100146 J01 – Knows the hazards that may be faced during

entry, including information on the mode, signs or symptoms,

and consequences of the exposure

02/09/2021 03/29/2021 $13,653 $13,653 03/02/2021
14. 01009 Serious

19100146 J02 – Verifies, by checking that the appropriate entries

have been made on the permit, that all tests specified by the

permit have been conducted and that all procedures and

equipment specified by the permit are in place before

endorsing the permit and allowing entry to begin;

02/09/2021 03/29/2021 $13,653 $13,653 03/02/2021
15. 01010A Serious

19100146 K02 II – Train affected employees to perform

assigned rescue duties. The employer must ensure that

such employees successfully complete the training required

to establish proficiency as an authorized entrant, as provided

by paragraphs (g) and (h) of this section;

02/09/2021 03/29/2021 $13,653 $13,653 03/02/2021
16. 01010B Serious

19100146 K02 IV – Ensure that affected employees practice

making permit space rescues at least once every 12 months,

by means of simulated rescue operations in which they remove

dummies, manikins, or actual persons from the actual permit

spaces or from representative permit spaces. Representative

permit spaces shall, with respect to opening size, configuration,

and accessibility, simulate the types of permit spaces from which

rescue is to be performed.

02/09/2021 03/29/2021 $0 $0 03/02/2021
17. 01011A Serious

19100146 K03 – 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.

02/09/2021 03/29/2021 $13,653 $13,653 03/02/2021
18. 01011B Serious

19100146 K03 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.

02/09/2021 03/01/2021 $0 $0 03/02/2021
19. 02001 Willful

19100146 D05 I – Test conditions in the permit space to determine

if acceptable entry conditions exist before entry is authorized to

begin, except that, if isolation of the space is infeasible because

the space is large or is part of a continuous system (such as a sewer),

pre-entry testing shall be performed to the extent feasible before entry

is authorized and, if entry is authorized, entry conditions shall be

continuously monitored in the areas where authorized entrants are

working

02/09/2021 03/29/2021 $136,532 $136,532 03/02/2021
20. 02002 Willful

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

02/09/2021 03/29/2021 $136,532 $136,532 03/02/2021

 

 

CLICK HERE for the case file

 

 

 

 

 

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