At 2:30 p.m. on September 13, 2010, Employee #1, Employee #2, and Employee #3 were tasked with the dismantling of a scaffold level within a phosgene containment dome. During their dismantling work, at approximately 80 feet above the ground, alarms specific to phosgene gas were triggered. The process within this Dome was the manufacturing and use of phosgene to facilitate the production of PMDI (an isocyanate). The leak occurred when an employee of another contractor, working below the three scaffolding employees, removed a “slip blind” between a valve and a downstream section of pipe. The valve and subsequent piping were used to transport liquid phosgene. After the bolts connecting the valve and line were broken, the valve continued to leak phosgene, triggering the alarms. The phosgene dosimeter badges worn by Employee #1, Employee #2, and Employee #3, provided by the host facility, turned a color indicating exposure to between 50 to 100 ppm of phosgene. The host facility ERT transported these employees to the hospital where they stayed for at least eighteen hours for treatment.
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Violation Summary
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|---|---|---|---|---|---|
| Serious | Willful | Repeat | Other | Total | |
| Initial Violations | 2 | 2 | |||
| Current Violations | 1 | 1 | 2 | ||
| Initial Penalty | $6,000 | $0 | $0 | $0 | $6,000 |
| Current Penalty | $1,500 | $0 | $0 | $4,500 | $6,000 |
| Violation Items | ||||||||
|---|---|---|---|---|---|---|---|---|
| # | ID | Type | Standard | Issuance | Abate | Curr$ | Init$ | LastEvent |
| 1. | 01001 | Other | 19260021 B06 I – | 01/20/2011 | 02/22/2011 | $4,500 | $4,500 | I – Informal Settlement |
| 2. | 01002A | Serious |
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 |
01/20/2011 | 02/22/2011 | $1,500 | $1,500 | I – Informal Settlement |
| 4. | 01002C | Serious |
19100134 E05 I – The following information must be provided to the PLHCP before the PLHCP makes a recommendation concerning an employee’s ability to use a respirator |
01/20/2011 | 02/22/2011 | $0 | $0 | I – Informal Settlement |
| 5. | 01002D | Serious |
19100134 K01 VI – How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators |
01/20/2011 | 02/22/2011 | $0 | $0 | I – Informal Settlement |
| 6. | 01002E | Serious |
19100134 K01 III – How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions |
01/20/2011 | 02/22/2011 | $0 | $0 | I – Informal Settlement |
| 7. | 01002F | Serious | 19100134 K01 VII – The general requirements of this section | 01/20/2011 | 02/22/2011 | $0 | $0 |
I – Informal Settlement |