OSHA issues PRCS and LOTO citations @ paper mill ($101K)

OSHA opened an inspection of the mill on Dec. 27, 2016, in response to a complaint alleging unsafe working conditions. Inspectors discovered employees exposed to serious safety hazards, including permit-required confined space hazards and LOTO failures, which I have summarized below:

The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.

Citation 1 Item 7a

Type of Violation: Serious; $6,338

29 CFR 1910.146(c)(4): When the employer decided that its employees would enter permit spaces, the employer did not implement a written permit space entry program that complied with 29 CFR 1910.146:

on or about 1123/17: The employer’s written confined space program was not implemented in that employees enter confined spaces and permit required confined spaces without following the elements being implemented:
1. permits are not being completed;
2. safety harness not worn;
3. air checks are not being completed;
4. all lockout points are not being locked out;
5. attendants are not available during entry and
6. rescue services are not called prior to entries

Citation 1 Item 7b

Type of Violation: Serious; Grouped

29 CFR 1910.146(c)(7)(iii): The employer did not document the basis for determining that all hazards in a permit space had been eliminated, through a written certification that contained the date, the location of the space, and the signature of the person making the determination:

on or about 1/10/17: Employees entered a permit required confined space: Pulpers and did not document through a certification that the permit required confined space was declassified to a non-permit confined spaces.
on or about 1110/17: Employees entered a permit required confined space: Water Chests and did not document through a certification that the permit required confined space was declassified to a non-permit confined spaces.
on or about 1/10/17: Employees entered a permit required confined space: Cement Chests and did not document through a certification that the permit required confined space was declassified to a non-permit confined spaces.
on or about 1/10/17: Employees entered a permit required confined space: Under Liner Machine Chest and Top Liner Machine Chest and did not document through a certification that the permit required confined space was declassified to a non-permit confined spaces.
on or about 1/10/17: Employees entered a permit required confined space: Dump Chests and did not document through a certification that the permit required confined space was declassified to a non-permit confined spaces.
on or about 1/10/17: Employees entered a permit required confined space: Fresh Water Pit and did not document through a certification that the permit required confined space was declassified to a non-permit confined spaces.

Citation 1 Item 7c

Type of Violation: Serious; Grouped

29 CFR 1910.146(d)(14): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer did not review the permit-required confined space program, using the canceled permits retained under 29 CFR 1910.146(e)(6) within one year after each entry and did not revise the program as necessary, to ensure that employees participation in entry operations were protected from permit space hazards:

on or about 1123/17: Employer’s written confined space program has not been reviewed and updated since 2001.

The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.

Citation 1 Item 8a

Type of Violation: Serious; $6,338

29 CFR 1910.146(d)(5)(i): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer did not evaluate permit space conditions when entry operations were conducted by testing conditions in the permit space to determine if acceptable entry conditions existed before entry was authorized to begin:

on or about 1/10/17: Employees entered permit required confined space: Back Liner Machine Chest without testing the conditions in the permit space to determine if acceptable entry conditions existed before entry was authorized to begin.
on or about 1/10/17: Employees entered permit required confined space: Collection Pit without testing the conditions in the permit space to determine if acceptable entry conditions existed before entry was authorized to begin.

Citation 1 Item 8b

Type of Violation: Serious; Grouped

29 CFR 1910.146(d)(6): Under the permit-required confined space program required by 29 CFR 1910.146(c)(4), the employer did not provide at least one attendant outside the permit space into which entry was authorized for the duration of entry operations.

NOTE: Attendance may be assigned to monitor more than one permit space provided the duties described in 29 CFR 191O.146(i) can be effectively performed for each permit space that is monitored. Likewise, attendants may be stationed at any location outside.

on or about 1/10/17: Employees entered permit required confined space: Filler Machine Chest without at least one attendant outside the permit space.
on or about 1/10/17: Employees entered permit required confined space: Back Liner Machine Chest without at least one attendant outside the permit space.
on or about 1/10/17: Employees entered permit required confined space: Clear Cloudy Water Chest without at least one attendant outside the permit space.
on or about 1/10/17: Employees entered permit required confined space: Collection Pit without at least one attendant outside the permit space.
on or about 1/10/17: Employees entered permit required confined space: Cement Chest without at least one attendant outside the permit space.
on or about 1/27117: Employee entered Under Liner Pulper without at least one attendant outside the permit space.

Citation 1 Item 8c

Type of Violation: Serious; Grouped

29 CFR 1910.147(c)(4)(i): Procedures were not utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:

On or before 1/27/2017, Beater and prep area: Employees were entering into pulper vats without locking out all energy sources such as, but not limited to electricity, fluids and steam.
On or before 2/17/2017, Basement: Employees were entering into a collection pit without locking out the water infeed.
On or around 2/16/2017, throughout the facility: Specific procedures that were documented were not utilized regarding the identification and control of energy sources to facilitate lock out activities. This included work on motors, beaters, and steam lines. Energy sources include, but are not limited to electrical, hydraulic, steam, potential and liquid flow.

Citation 1 Item 8d

Type of Violation: Serious; Grouped

29 CFR 1910.261(j)(5)(iii): When cleaning, inspecting, or other work requires that persons enter pulpers, all steam, water, or other control devices were not locked or tagged out:

On or before 1/27/2017, Beater and prep area: Employees are entering into pulper vats without locking out all energy sources such as, but not limited to electricity, fluids and steam.

Citation 1 Item 9

Type of Violation: Serious; $6,338

29 CFR 1910.146(e)(1): Before entry was authorized, the employer did not document the completion of measures required by 29 CFR 1910.146(d)(3) by preparing an entry permit:

on or about 1/10/17: Employees entered permit required confined space: Filler Machine Chest without preparing an entry permit.
on or about 1/10/17: Employees entered permit required confined space: Back Liner Machine Chest without preparing an entry permit.
on or about 1/10/17: Employees entered permit required confined space: Clear Cloudy Water Chest without preparing an entry permit.
on or about 1/10/17: Employees entered permit required confined space: Collection Pit without preparing an entry permit.
on or about 1/10/17: Employees entered permit required confined space: Cement Chest without preparing an entry permit.
on or about 1/27 /17: Employee entered Under Liner Pulper without preparing an entry permit.

The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.

Citation 1 Item 10a

Type of Violation: Serious; $6,338

29 CFR 1910.146(f)(2): The entry permit that documented compliance and authorized entry to a permit space did not identify the purpose of the entry:

on or about 1/23/17: The confined space entry permit form used for entry into all permit required confined spaces did not identify the purpose of the entry.

Citation 1 Item 10b

Type of Violation: Serious; Grouped

29 CFR 1910.146(f)(3): The entry permit that documented compliance and authorized entry to a permit space did not identify the date and the authorized duration of the entry permit:

on or about 1/23/17: Confined space entry permits for all permit required confined spaces did not identify the authorized duration of the entry permit. Abatement certification must be submitted for this item.

Citation 1 Item 10c

Type of Violation: Serious; Grouped

29 CFR 1910.146(f)(7): The entry permit that documented compliance and authorized entry to a permit space did not identify the hazards of the permit space to be entered:

on or about 1/23/17: Confined space entry permits for all permit required confined spaces did not identify the most likely hazards to be encountered upon entry into a confined space.

Citation 1 Item 10d

Type of Violation: Serious

29 CFR 1910.146(f)(11): The entry permit that documented compliance and authorized entry to a permit space did not identify the rescue and emergency services summoned and the means for summoning those services:

on or about 1/23/17: Entry permits for all permit required confined spaces did not have the correct phone number for the West Carthage Fire Department noted on it.

The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.

Citation 1 Item 11a

Type of Violation: Serious; $6,338

29 CFR 1910.146(j)(4): The employer did not ensure that each entry supervisor verified that rescue services were available and that the means for summoning them were operable:

on or about 1/10/17: Employees entered permit required confined spaces including but not limited to: Filler Machine Chest; Back Liner Machine Chest; Clear Cloudy Water Chest; Collection Pit; Cement Chest and the entry supervisor did not verify that rescue workers were available.
on or about 1/27/17: Employee entered Under Liner Pulper and the entry supervisor did not verify that rescue workers were available.

Citation 1 Item 11b

Type of Violation: Serious; Grouped

29 CFR 1910.146(k)(1)(i): An employer who designated rescue and emergency services, pursuant to paragraph (d)(9) of this section, did not evaluate a prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified:

on or about 4/12/17: Employer’s confined space program designates West Carthage Fire Department to respond to a confined space emergency and they did not evaluate the Fire Department’s ability to respond to a rescue summons in a timely manner.

The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for injury or illness.

Citation 1 Item 12a

Type of Violation: Serious; $6,338

29 CFR 191O.146(k)(3): Whenever an authorized entrant entered a permit space, retrieval systems or methods were not used to facilitate non-entry rescue:

on or about 1/10/17: Employees entered permit required confined spaces including but not limited to: Filler Machine Chest; Back Liner Machine Chest; Clear Cloudy Water Chest; Collection Pit; Cement Chest and was not utilizing a retrieval system, including a harness, an attached retrieval line and winch.

Citation 1 Item 12b

Type of Violation: Serious; Grouped

29 CFR 1910.261(j)(5)(ii): When cleaning, inspecting, or other work requires that persons enter the pulpers, employees were not equipped with safety belt and lifeline, and one person was not stationed outside at a position to observe and assist in case of emergency:

on or about 1/27/17: Employee entered Under Liner Pulper without utilizing a chest or full body harness with a retrieval line attached.

Citation 1 Item 13

Type of Violation: Serious; $6,338

29 CFR 1910.146(g)(1): The employer did not provide training so that all employees whose work was regulated by 29 CFR 1910.146, Permit required confined spaces, acquired the understanding, knowledge, and skills necessary for the safe performance of the duties assigned:

on or about 4/7/17: Employees were required to enter permit required confined spaces and were not trained on the understanding, knowledge and skills required to perform safe entries into permit required confined spaces.

CLICK HERE for the citations.

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