PRCS Fatality in Tanker Truck due to H2S and HCN exposures

This is one type of situation where (c)(5) could be a means to enter a PRCS and OSHA agreed and issued some (c)(5) citations.

At 8:15 p.m. on May 25, 2018, Employee #1 was power washing the outside of the semi-truck tanker trailer. The employee entered the tanker trailer to wash the inside and was not found for two hours. The fire department was called to rescue the employee. Atmospheric monitoring found atmospheric levels of hydrogen sulfide at 100 ppm and hydrogen cyanide at 30 ppm. No written evidence of atmospheric monitoring was available following the employee’s recovery from the space, and no ventilation of the space prior to or during the entry was performed. No attendant or entry supervisor was assigned to the entry. Employee #1’s death was determined to be chemical asphyxia by vitiated atmosphere with hydrogen sulfide and hydrogen cyanide gasses.

Violation Summary
  Serious Willful Repeat Other Total
Initial Violations 11       11
Current Violations 11       11
Initial Penalty $128,051 $0 $0 $0 $128,051
Current Penalty $128,051 $0 $0 $0 $128,051

Violation Items
ID Type Standard Issuance Abate Curr$ Init$ Contest
01001 Serious

19100146 C05 II D – There may be no hazardous atmosphere

within the space whenever any employee is inside the space.

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01002 Serious

19100146 C05 II E 1 – An employee may not enter the space

until the forced air ventilation has eliminated any hazardous

atmosphere;

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01003 Serious

19100146 C05 II H – The employer shall verify that the space

is safe for entry and that the pre-entry measures required by

paragraph (c)(5)(ii) of this section have been taken, through a

written certification that contains the date, the location of the

space, and the signature of the person providing the certification.

The certification shall be made before entry and shall be made

available to each employee entering the space or to that

employee’s authorized representative.

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01004 Serious

19100146 D02 – Identify and evaluate the hazards of permit

spaces before employees enter them;

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01005 Serious

19100146 D04 VIII – Rescue and emergency equipment

needed to comply with paragraph (d)(9) of this section,

except to the extent that the equipment is provided by

rescue services; and

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01006 Serious

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;

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01007 Serious

19100146 D08 – Designate the persons who are to have active

roles (as, for example, authorized entrants, attendants, entry

supervisors, or persons who test or monitor the atmosphere

in a permit space) in entry operations, identify the duties of each

such employee, and provide each such employee with the training

required by paragraph (g) of this section;

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01008A 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.

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01008B Serious

19100146 E02 – Before entry begins, the entry supervisor identified

on the permit shall sign the entry permit to authorize entry.

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01009 Serious

19100146 H03 – Communicate with the attendant as necessary to

enable the attendant to monitor entrant status and to enable

the attendant to alert entrants of the need to evacuate the space

as required by paragraph (i)(6) of this section;

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01010A Serious

19100146 I04 – Remains outside the permit space during entry

operations until relieved by another attendant;

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01010B Serious

19100146 I05 – Communicates with authorized entrants as necessary

to monitor entrant status and to alert entrants of the need to evacuate

the space under paragraph (i)(6) of this section;

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01011 Serious

19100146 K03 I – 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.

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