OSHA has dined a Delaware Rail Car Tank Cleaning And Repair Facility $371,276 for Safety and Health Hazards. This same company, different location, was cited last year after a PRCS fatality inside a Rail Car (PRCS fatality cleaning a railcar (Oxygen Deficient and $551K): Membership Content). This inspection was initiated due to a complaint, but surely OSHA has to be considering an emphasis program on the “tank cleaning industry” and their PRCS entry practices. Just last week we had another PRCS accident inside a tanker truck trailer with one entrant and one would-be-rescuer dying due to a hazardous atmosphere.
In this most recent citation, OSHA took issue with several issues, but it is respiratory protection practices at the facility that caught my eye:
- Fit Testing not being done
- Grade-D Breathing Air Quality (using a portable air compressor that was NOT for breathing air)
- Entry into IDLH atmospheres with Air-line SAR(s) w/o escape air (Willful)
This was found in a July 2019 inspection and the fatality (at a different location) occurred in May 2019. One would have hoped that the company would have stepped up and raised the bar regarding their critical safety practices such as PRCS and Respirators. This is a major company – not some mom and pop shop!
PLEASE NOTE: these citations were just issued and there has not even been an informal conference, so things may change in the coming weeks. The company has contested the citations from their May 2019 PRCS fatality accident in Pittston, PA.
Citation 1 Item 3
Type of Violation: Serious; $8,482
29 CFR 1910.134(f)(2): Employee(s) using tight-fitting facepiece respirators were not fit tested prior to initial use of the respirator and at least annually thereafter:
(a) On or about August 12, 2019, the employer failed to provide annual respirator fit testing for employees who wear North 5500 series full face respirators and North 7700 half-face respirators during maintenance activities.
Citation 1 Item 4
Type of Violation: Serious; $13,494
29 CFR 1910.134(i)(1)(ii): Breathing air did not meet requirements for Grade D breathing air as described in the ANSI/Compressed Gas Association Commodity Specification G-7.1-1989:
(a) Sand Blasting Area (“Blast Cleaning Room”) – On or about August 12, 2019, the employer failed to provide acceptable breathing air. Employees who wore respirators during abrasive blasting operations were instructed to connect their airlines to a Portable Compressor, exposing them to a potential inhalation hazard posed by contaminated air.
Citation 2 Item 1
Type of Violation: Willful; $134,937
29 CFR 1910.134(d)(2)(i)(B): The employer did not provide a full facepiece pressure-demand supplied-air respirator (SAR) with auxiliary self-contained air supply for employee use in IDLH atmospheres:
(a) Tank Car Maintenance & Repair Shop – On multiple dates after August 12, 2019, the SAR provided by the employer did not have an auxiliary air supply for employees who entered tank cars, permit-required confined spaces, to perform maintenance activities, exposing employees to an inhalation hazard.
1. On 8/14/19, tank car 33455 was entered for wire wheeling;
2. On 8/16/19, tank car 34334 was entered for cleaning;
3. On 8/16/19, tank car 34575 was entered for cleaning;
4. On 8/22/19, tank car 34412 was entered for cleaning;
5. On 8/23/19, tank car 21106 was entered to check heater coils;
6. On 8/24/19, tank car 21106 was entered for pipe repairs/ heater coils;
7. On 8/26/19, tank car 21106 was entered to weld heater pipe and brackets;
8. On 8/27/19, tank car 21106 was entered to inspect coils;
9. On 8/27/19, tank car 25007 was entered for cleaning;
10. On 8/28/19, tank car 9788 was entered for measurements;
11. On 8/28/19, tank car 25007 was entered for cleaning;
12. On 9/3/19, tank car 9299 was entered for ultrasonic testing;
13. On 9/3/19, tank car 34136 was entered for ultrasonic testing;
14. On 9/3/19, tank car 34143 was entered to clean welds;
15. On 9/3/19, tank car 39513 was entered for wire wheeling;
16. On 9/5/19, tank car 130012 was entered for wire wheeling and ultrasonic testing;
17. On 9/9/19, tank car 25007 was entered for weld repair;
18. On 9/11/19, tank car 90027 was entered for cleaning; and,
19. On 9/12/19, tank car 130001 was entered for wire wheeling and ultrasonic testing.
https://www.osha.gov/sites/default/files/citations/DanaRailcare_1421123_0210_20.pdf