Line Break involving Chlorine within a crawl space goes bad when workers have FACIAL HAIR

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.

Violation Summary
  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
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