WA-OSHA issues 46 serious and 17 general safety and health violations @ manufacturing facility/terminal ($192K)

Employees can be seriously injured or killed by being pulled into the former machine when the guard is removed and they are working near the opening to the rotating former belt.

 

Violation 1 Item 2

Violation Type: Serious; $4,200

WAC 296-800-14020(1)

The employer did not develop, supervise, implement, and enforce training on and effective use of employee personal toxic gas monitors for SO2 and H2S in the following instances:

1) An employee was observed to be wearing an expired personal monitor.

2) Employees were unaware of calibration and bump testing requirements.

3) An employee was observed to not be wearing monitors when performing sulfur transferring.

Employees can be seriously injured or killed if they are not trained properly on the maintenance and use of personal toxic gas monitors.

 

Violation 1 Item 3

Violation Type: Serious; $2,100

WAC 296-800-15030

The employer did not ensure that the sulfur plant had an emergency wash station that functioned correctly. Employees in this plant regularly use and transfer between containers, mineral spirits, and a petroleum based solvent. The emergency wash station was observed to have a disconnected eyewash.

 

Violation 1 Item 4

Violation Type: Serious; $2,100

WAC 296-800-16030

The employer did not retrain employees to use PPE when work habits readily demonstrated that employees lack the understanding, skill, or motivation to use PPE.

1) Employees were observed to be wearing reading glasses or sunglasses inside the sulfur plant when working around the forming machine.

2) One employee was observed not to be using gloves when cleaning machine parts with mineral spirits and others pouring and spraying molykote without gloves.

Employees can suffer eye injuries from flying particles and liquid chemicals and skin injuries from chemical spills on hands when not retrained to use PPE appropriately. Employees can be injured from slips, trips, and falls or hand tools when wearing sunglasses as safety glasses indoors.

 

Violation 1 Item 5

Violation Type: Serious; $4,200

WAC 296-800-28030(4)

The employer did not ensure that extension cords were not used as a substitute for fixed wiring and not run through holes in walls in the following instances:

1) Extension cords used throughout sulfur plant for sump pumps and lighting for months.

2) Extension cords run through walls on west side and northeast side of sulfur plant.

Extension cords were observed to be used in a wet environment in the sulfur forming area for sump pumps and lighting for months as reported by employees. Two cases of extension cords running through holes in walls were observed as well.

 

Violation 1 Item 6

Violation Type: Serious; $4,200

WAC 296-800-28030(7)

The employer did not ensure that insulation on flexible cords and cables was intact in the following instances:

1) Uninsulated section of extension chord to sump pump in sulfur plant.

2) Uninsulated wires at top of bentonite hopper platform.

 

Violation 1 Item 7

Violation Type: Serious; $4,200

WAC 296-800-31070(1)

The employer did not ensure that a working employee alarm system to warn employees of a fire or other emergencies is installed and maintained. The sulfur plant did not have air horns for emergency response alarm per interviews and facility protocol.

 

Violation 1 Item 8

Violation Type: Serious; $4,200

WAC 296-803-20005(5)

The employer did not ensure that lockout tagout procedures identified equipment specific information on lockout points and verification in the following instances:

1) Employees entering the rail car hopper (confined space) to breakup nitrate while a conveyer was running below slits in the floor.

2) Confined space permit, sulfur mixing tank accessed 10/28/2021, requiring six lockout points.

3) Other equipment in the forming plant that do not have written LOTO procedures including the sulfur transfer station and sulfur-bentonite forming lines, the forming machine, and the pellet agitator.

 

Violation 1 Item 9

Violation Type: Serious; $4,200

WAC 296-803-50005(1)

The employer did not ensure that employees used energy control procedures to protect employees servicing or maintaining machines and equipment from potentially hazardous energy in the following instances:

1) Employees entering the rail car hopper (confined space) to breakup nitrate while a conveyer was running below slits in the floor.

2) Confined space permit, sulfur mixing tank accessed 10/28/2021, requiring six lockout points.

3) Reported cleaning of the forming machine and replacement of bearings on the pellet agitator.

 

 

Violation 1 Item 10

Violation Type: Serious; $4,200

WAC 296-803-60005(1)

The employer did not provide and document employee training on the purpose and function of the energy control program to have the knowledge and skills necessary to carry out their program responsibilities in the following cases:

1) Employees entering the rail car hopper (confined space) to breakup nitrate while a conveyer was running below slits in the floor.

2) Confined space permit, sulfur mixing tank accessed 10/28/2021, requiring six lockout points.

3) Reported cleaning of the forming machine and replacement of bearings on the pellet agitator.

Two employees were missing training and all others did not effectively use procedures when performing lockout. Training consisted of 30 minute monthly safety meetings where multiple safety topics were discussed.

 

Violation 1 Item 11

Violation Type: Serious; $4,200

WAC 296-803-70005(1)

The employer did not conduct annual reviews to ensure employees know and can apply energy control procedures and correct any deviations identified. Employees did not use the existing LOTO permit procedure in the written program for tasks requiring lockout.

 

Violation 1 Item 12

Violation Type: Serious; $1,400

WAC 296-806-30030

The employer did not ensure rough cut projecting shaft ends were guarded in one instance on the rail conveyer system. An exposed shaft at ankle height adjacent to the conveyer platform was observed while the conveyer was running. The shaft end is rough cut, posing a potential to snag clothing and pull an employee into the conveyer.

 

Violation 1 Item 13

Violation Type: Serious; $2,100

WAC 296-806-42028

The employer did not ensure nip points were guarded in the following instances on the rail conveyer system:

1) Unguarded roller and belt underneath the conveyer hopper on the northeast end where ammonium nitrate spillage was removed.

2) Unguarded roller and belt underneath the conveyer hopper on the southeast end where ammonium nitrate spillage was removed.

3) Unguarded roller and belt underneath the conveyer on the west side at head height where employees walk.

4) Unguarded belt at top of conveyer on the west side.

 

Violation 1 Item 14

Violation Type: Serious; $4,200

WAC 296-807-14020(1)

The employer did not ensure air pressure was reduced to less than 30 PSI when cleaning with compressed air.

Employees use compressed air to clean the sulfur plant former machine heads multiple times per shift.

Employees can be blinded by projectiles when using compressed air at greater than 30 PSI.

 

Violation 1 Item 15

Violation Type: Serious; $4,200

WAC 296-807-14020(2)

The employer did not ensure the use of effective chip guarding when cleaning with compressed air. Employees use compressed air to clean the sulfur plant former machine heads multiple times per shift.

 

Violation 1 Item 16

Violation Type: Serious; $4,900

WAC 296-809-20002

The employer did not identify all permit required confined spaces in the following instances:

1) Rail cars or the rail car area, where employees would enter rail cars from top hatches to breakup ammonium nitrate into a hopper below.

2) Rail conveyer hopper, where employees would enter from a floor level hatch to breakup ammonium nitrate for it to pass through slits to fall onto a conveyer belt.

3) Two sulfur mixing tanks, where an employee entered to repair an agitator.

 

Violation 1 Item 17

Violation Type: Serious; $4,900

WAC 296-809-20004(1)

The employer did not inform affected employees about the existence and danger of confined spaces through the use of signs or other effective means in the following instances:

1) Rail cars or the rail car area, where employees would enter rail cars from top hatches to breakup ammonium nitrate into a hopper below.

2) Rail conveyer hopper, where employees would enter from a floor level hatch to breakup ammonium nitrate for it to pass through slits to fall onto a conveyer belt.

3) Two sulfur mixing tanks, where an employee entered to repair an agitator.

 

Violation 1 Item 18

Violation Type: Serious; $4,900

WAC 296-809-30002(1)

The employer did not document entry procedures and did not designate employees that have active roles in the confined space program including; attendants, competent persons, entrants, entry supervisors, rescuers, program administrator, or those who test or monitor the atmosphere in a permit required space.

Permit required confined space entry occurred in the rail cars, rail conveyer hopper, aqua scrubber, and sulfur mixing tank in the past 6 months. Deficiencies were identified in all of these entries resulting from a lack of designated employee roles and a lack of procedures outlining safe work practices for employees to follow.

 

Violation 1 Item 19a

Violation Type: Serious; $4,900

WAC 296-809-40002(2)

The employer did not ensure that confined space entry training was provided to each affected employee before an employee is first assigned to their duties. There were two employees who were observed as entrants while CSHOs were on site and one employee listed on a permit as an attendant. These three employees do not have training records.

 

Violation 1 Item 19b

Violation Type: Serious;

WAC 296-809-40004(1)

The employer did not certify employee proficiency in their assigned duties for confined space entry. Only one confined space entry training quiz record was provided and this employee signed off as the trainee and trainer. At least six employees are known to have participated in confined space entry activities.

Assessed penalty: Included in Violation 1 Item 19A

 

Violation 1 Item 20a

Violation Type: Serious; $4,900

WAC 296-809-50002(1)

The employer did not identify and evaluate potential hazards from permit required confined spaces and the work to be performed prior to employees entering spaces. Hazard assessments were not provided for documented confined space entries in the rail conveyer hopper, rail cars, sulfur mixing tank, and aqua ammonia scrubber.

 

Violation 1 Item 20b

Violation Type: Serious;

WAC 296-809-50002(2)

The employer did not ensure entry permits were completed before confined space entry was performed to document that the means, procedures, and practices necessary for safe entry and work are complete. Permits were not provided for confined space entry into rail cars and the rail conveyer hopper.

 

The violations above have been grouped because they involve similar or related hazards that may increase the potential for illness or injury resulting from an exposure or accident. A single penalty is applied to the first item in the group. Situation not believed to exist any longer. However, if this violation is identified again during future inspections, it may result in repeat or failure to abate violations which may include penalties.

Assessed penalty: Included in Violation 1 Item 20A

 

Violation 1 Item 21a

Violation Type: Serious; $4,900

WAC 296-809-50004(6)

The employer did not use confined space entry permits that contained results of initial and periodic tests performed to evaluate and identify the hazards and conditions of the space for the Sulfur Mixing Tank.

The 10/28/2021 Sulfur Mixing Tank permit listed oxygen deficiency and combustible atmospheres as hazards of the space but did not test for these parameters. A BW Clip, personal monitor for SO2 and H2S, was listed as the test instrument and was the only testing performed as confirmed by the entrant. A 4 gas meter was not used during entry.

 

Violation 1 Item 21b

Violation Type: Serious

WAC 296-809-50012(1)(a)

The employer did not test confined spaces for atmospheric hazards including oxygen and combustible gases and vapors for the Aqua Ammonia Scrubber and the Sulfur Mixing Tank in the following instances:

1) The 1/25/2022 Aqua Scrubber permit did not list test results or the tester signature and listed that ammonia vapors were a hazard involved.

2) The 10/28/2021 sulfur Mixing Tank permit listed oxygen deficiency and combustible atmospheres as hazards of the space but did not test for these parameters. A BW Clip, personal monitor for SO2 and H2S, was listed as the test instrument so a 4 gas meter was not used during entry.

Assessed penalty: Included in Violation 1 Item 21A

 

Violation 1 Item 22

Violation Type: Serious; $4,900

WAC 296-809-50004(11)

The employer did not use confined space entry permits that contained communication procedures for the Aqua Ammonia Scrubber and the Sulfur Mixing Tank in the following instances:

1) The 1/25/2022 Aqua Scrubber permit did not list communication methods.

2) The 10/28/2021 Sulfur Mixing Tank permit did not list communication methods.

 

Violation 1 Item 23a

Violation Type: Serious; $4,900

WAC 296-809-50004(13)

The employer did not use confined space entry permits that contained rescue and emergency contact information for the Aqua Ammonia Scrubber and the Sulfur Mixing Tank in the following instances:

1) The 1/25/2022 Aqua Scrubber permit did not list emergency contact information.

2) The 10/28/2021 Sulfur Mixing Tank permit did not list emergency contact information.

 

Violation 1 Item 23b

Violation Type: Serious

WAC 296-809-50014(1)(a)

The employer did not ensure adequate rescue and emergency services were available during permit required confined space entry in the following instances:

1) The 1/25/2022 Aqua Scrubber permit did not list emergency contact information.

2) The 10/28/2021 Sulfur Mixing Tank permit did not list emergency contact information.

3) Emergency services were not contacted prior to rail car entries.

4) Emergency services were not contacted prior to rail conveyer entries.

Note: Moses Lake fire departments confirmed with CSHO that they are not prepared for confined space entry rescue.

The violations above have been grouped because they involve similar or related hazards that may increase the potential for illness or injury resulting from an exposure or accident. A single penalty is applied to the first item in the group.

 

Violation 1 Item 24

Violation Type: Serious; $4,900

WAC 296-809-50010(1)

The employer did not provide the necessary equipment to employees performing confined space entry into the rail conveyer hopper including testing/monitoring equipment, ventilation, communication devices, PPE, and ladders. Employees were observed to be breaking up ammonium nitrate inside the conveyer hopper without monitoring equipment, ventilation, radios, ladders, and suitable PPE.

 

Violation 1 Item 25

Violation Type: Serious; $4,900

WAC 296-809-50016(1)

The employer did not use non-entry rescue systems or methods whenever possible for employees entering rail cars, which are permit required confined spaces. Multiple employees reported vertically entering rail cars regularly to breakup ammonium nitrate into the rail car hopper below without confined space entry safe work practices including the use of non-entry rescue systems.

Employees can be seriously injured or killed if rescue is hindered by a lack of non-entry rescue systems.

Employees outside of the confined space may be seriously injured or killed if they enter the space to rescue entrants.

 

Violation 1 Item 26

Violation Type: Serious; $4,900

WAC 296-809-50018(2)

The employer did not ensure that a supervisor oversaw confined space entry operations for employees entering the rail conveyer hopper, a permit required confined space. Multiple employees entered the rail car hopper daily without a supervisor overseeing entry operations.

 

Violation 1 Item 27

Violation Type: Serious; $4,900

WAC 296-809-50020(2)

The employer did not ensure attendants understood the hazards they may face during confined space entry including the mode, signs or symptoms, and results of exposure to the hazards. Multiple employees attended confined space entry of the rail car hopper daily and did not recognize the hazards including limited access, health effects of the ammonium nitrate, and getting caught by the conveyer running along the floor.

 

Violation 1 Item 28

Violation Type: Serious; $4,900

WAC 296-809-50022(1)

The employer did not ensure entrants understood the hazards they may face during confined space entry including the mode, signs or symptoms, and results of exposure to the hazards. Multiple employees performed confined space entry of the rail car hopper daily and did not recognize the hazards including limited access, health effects of the ammonium nitrate, and getting caught by the conveyer running along the floor.

 

Violation 1 Item 29

Violation Type: Serious; $4,200

WAC 296-817-20005(1)

The employer did not conduct employee noise exposure monitoring when reasonable information indicated that an employee’s exposure may equal or exceed 85 dBA TWA8 for rail car unloading employees. Employees who unload solid materials from rail cars in the northeast area of the facility were observed to be using sledgehammers to dislodge solids from rail cars to the hopper below and observed using a rail car PIT to move rail cars throughout the facility. Both of these activities produced noise that could be heard at the sulfur plant and the offices.

 

Violation 1 Item 30

Violation Type: Serious; $4,200

WAC 296-817-20010

The employer did not control employee noise exposures that exceed 90 dBA during the following activities, as verified by dosimeter readings:

1) Using sledgehammers to dislodge solids from rail cars to the hopper below.

2) Using a rail car PIT to move rail cars throughout the facility.

 

Violation 1 Item 31

Violation Type: Serious; $4,200

WAC 296-817-20015(1)

The employer did not ensure employees wear hearing protection when noise exposures exceed 85 dBA TWA8 and 115 dBA for the following activities:

1) Using sledgehammers to dislodge solids from rail cars to the hopper below.

2) Using a rail car PIT to move rail cars throughout the facility.

 

Violation 1 Item 32

Violation Type: Serious; $4,200

WAC 296-817-20020(2)

The employer did not ensure employees receive training about noise and hearing protection when noise exposures exceed 85 dBA TWA8 for the following activities:

1) Using sledgehammers to dislodge solids from rail cars to the hopper below.

2) Using a rail car PIT to move rail cars throughout the facility.

 

Violation 1 Item 33

Violation Type: Serious; $4,200

WAC 296-817-20035(1)

The employer did not use audiometric testing to identify hearing loss in employees to indicate program deficiencies for the following activities:

1) Using sledgehammers to dislodge solids from rail cars to the hopper below.

2) Using a rail car PIT to move rail cars throughout the facility.

 

Violation 1 Item 34

Violation Type: Serious;

WAC 296-824-20005(1)

The employer did not ensure the emergency response plan adequately addressed personnel roles and PPE for the following:

1) Of the five senior emergency contacts and safety managers, only one senior emergency contact still works for the company and his emergency response training was more than one year out of date.

2) PPE is vaguely and briefly embedded in response procedures. A separate PPE Program exists but is not referenced in the Emergency Response Plan. The PPE Program does not adequately detail the types of gloves and respiratory protection. APRs are selected for emergency response. This contradicts the NIOSH Respiratory Selection Guide.

3) Proper use of PPE.

4) Hazards created by wearing PPE.

5) PPE procedures detailing donning and doffing are not included.

 

Violation 1 Item 35

Violation Type: Serious; $4,200

WAC 296-824-30005(2)

The employer did not provide emergency response refresher training annually for 11 employees. Based on training logs provided, 11 employees had out of date (>1 year from opening) or missing training records for emergency response, where employees would need to act in awareness or operator level roles during a release of ammonia, SO2, or H2S.

 

Violation 1 Item 36a

Violation Type: Serious

WAC 296-824-60005(2)

The employer did not select the appropriate emergency response respirators based on site hazards and unknown emergency conditions. Employees are provided full face elastomeric respirators to use during operator level response actions to a release of ammonia, SO2, or H2S when SCBAs should be selected for unknown/emergency conditions.

 

Violation 1 Item 36b

Violation Type: Serious

WAC 296-842-13005

The employer did not provide the appropriate respirator for emergency response based on site hazards and unknown emergency conditions. Employees are provided full face elastomeric respirators to use during operator level response actions to a release of ammonia, SO2, or H2S, when SCBAs should be provided for use in unknown/emergency situations.

The violations above have been grouped because they involve similar or related hazards that may increase the potential for illness or injury resulting from an exposure or accident. A single penalty is applied to the first item in the group.

 

Violation 1 Item 37

Violation Type: Serious; $4,200

WAC 296-842-15005(3)

The employer did not use quantitative fit-test methods for full facepiece respirators requiring a protection factor of 50. Multiple employees have full facepiece respirators and the respiratory protection program lists full facepiece respirators with an APR for ammonia, SO2, and H2S.

 

Violation 1 Item 38

Violation Type: Serious; $4,200

WAC 296-842-16005(4)(c)

The employer did not provide effective training on respiratory protection as employees have not retained knowledge or skills. Numerous respirator deficiencies were apparent on site including storage, cleaning, and lack of use of respiratory protection.

Employees are expected to respond to emergency leaks of SO2, H2S, and NH3 in an operations capacity, potentially exposing them to IDLH conditions. Employees were trained in November 2021 in an ineffective safety meeting format where respiratory protection and fall protection were both covered in meetings reported to last 30 minutes.

 

Violation 1 Item 39

Violation Type: Serious; $4,900

WAC 296-863-40005(2)(a)

The employer did not ensure that employees were not allowed under the elevated part of any PIT, whether it is loaded or empty. A sulfur plant operator would regularly reach under a one ton load (supersack) of bentonite to cut the bag to load the sulfur process hopper.

 

Violation 1 Item 40

Violation Type: Serious; $3,300

WAC 296-880-10005(1)

The employer did not ensure that all surfaces on which employees walk are structurally sound and will support them safely. A section of grating at the top of the conveyer platform adjacent to the controls approximately 2.5x2ft was missing and covered by a wooden pallet, exposing employees who adjust the conveyer controls to approximately a 12 foot fall.

 

Violation 1 Item 41

Violation Type: Serious; $4,200

WAC 296-880-10005(2)(a)

The employer did not inspect all components of personal fall arrest systems prior to each use according to manufacturers recommendations. An employee was observed to be using a harness on a genie lift to inspect the sulfur storage tank. The harness and lanyard had no inspections record and had visible signs of wear and rust.

 

Violation 1 Item 42

Violation Type: Serious; $2,800

WAC 296-880-10010(2)

The employer did not guard open sump pump holes that employees could step into with covers of standard strength in the following instances:

1) Three exposed sump pump holes were observed in the floor of the sulfur plant in walkway areas where employees could have easily stepped into them.

2) Two exposed holes in the ground in the sulfur transfer area.

 

Violation 1 Item 43

Violation Type: Serious; $4,200

WAC 296-880-10015(1)

The employer did not provide fall protection training for employees that were working at heights that required them to demonstrate an understanding of the material and demonstrate the ability to use fall protection properly in the following instances:

1) Using a Genie lift at varying heights including to check a 10 ft tall tank.

2) On top of rail cars and tanker trucks over 10 feet in height without training on fall protection work plan elements.

Training records for employees consist of a monthly 30 minute safety meeting held in November 2021 where fall protection and respiratory protection was covered. These meetings are reported to be in a powerpoint format with no tests or hands on activities.

 

Violation 1 Item 44

Violation Type: Serious; $4,200

WAC 296-880-10020(1)

The employer did not develop a fall protection work plan for areas of the facility where employees are assigned and fall hazards of 10 or more feet exist in the following instances:

1) Four employees reported accessing the top of rail cars to break up solidified ammonium nitrate inside. No fall protection used.

2) One employee was observed using the Genie lift to check the level in the 10 ft high sulfur tank. They were using the PFAS connected to the genie lift. It was not inspected and had visible deficiencies requiring it to be removed from service. Another employee reported using this Genie lift to access the top of the sulfur trucks to connect the air line.

No fall protection work plans could be provided for these activities.

 

Violation 1 Item 45

Violation Type: Serious; $4,200

WAC 296-880-20005(10)

The employer did not ensure that employees exposed to fall hazards of four feet or more to the ground or lower level from vehicles or rolling stock on which employees must be located in order to perform their job duties are protected by fall arrest systems. This was observed in the following instances:

1) Four employees reported accessing the top of rail cars to break up solidified ammonium nitrate inside. No fall protection used. Evidence of employees working over open rail car hatches in a separate area of the plant was observed by CSHOs.

2) Four employees reported going on top of one type of sulfur truck that required connecting the air hose from the top of the truck. One employee reportedly fell and broke their foot doing this two years ago. No fall protection used.

 

Violation 1 Item 46

Violation Type: Serious; $4,200

WAC 296-901-14016(1)

The employer did not provide employees with effective information and training on hazardous chemicals in their work area. Employees had limited knowledge of the hazard communication program and did not use labeled containers for regularly used chemicals.

 

Violation 2 Item 1

Violation Type: Repeat General; $320

WAC 296-842-15005(1)(b)

The employer did not provide annual fit tests for employees required to use full facepiece respirators. Multiple employees have full facepiece respirators and the respiratory protection program lists full facepiece respirators with an APR for ammonia, SO2, and H2S. One fit test record provided was from April 2019.

 

Violation 3 Item 1

Violation Type: General; $0

WAC 296-24-73505(1)

The employer did not ensure that passageways in the sulfur plant were maintained in a dry condition to the extent feasible. Standing water was observed in the sulfur plant walkways due to process water, surrounding ground runoff, roof leaks, and ineffective sump pumps.

Employees can slip and fall seriously injuring themselves on the wet concrete floor.

 

Violation 3 Item 2

Violation Type: General; $700

WAC 296-27-02105(6)

The employer did not post the OSHA 300A log annual summary prior to February 1, 2022. The 300A log was not observed to be posted in any of the employee common areas during the initial site visit.

 

Violation 3 Item 3

Violation Type: General; $0

WAC 296-800-11040

The employer did not control chemical agents in a manner that they would not present a hazard to workers regarding exposure to elemental sulfur all over the ground in the sulfur transfer area. Skin contact with elemental sulfur from handling boots and clothing can cause skin irritation and dermatitis.

 

Violation 3 Item 4

Violation Type: General; $0

WAC 296-800-15035

The employer did not ensure that emergency wash stations are activated weekly to check the proper functioning of the valves, hardware, and availability of water. The sulfur plant emergency wash stations did not have an eyewash component for months prior to the opening, which weekly activation checks would have identified and fixed. Employees in this plant regularly use and transfer between containers, mineral spirits, and a petroleum based solvent. Other employees manage ammonia transferring and mixing on site.

 

Violation 3 Item 5

Violation Type: General; $0

WAC 296-800-23040(2)

The employer did not ensure eating areas are healthy and food is not stored in areas exposed to toxic substances.

The employee breakroom in the sulfur plant was observed to have dust on all items and surfaces and PPE contaminated with elemental sulfur, an irritant that can cause dermatitis.

Employees keep their lunches and drinks in this room and in the refrigerator.

Employees can get dermatitis from incidental skin contact and elemental sulfur ingestion can cause burning and diarrhea.

 

Violation 3 Item 6

Violation Type: General; $0

WAC 296-800-30020

The employer did not ensure that portable fire extinguishers are visually inspected monthly. The fire extinguishers in the main office, scale hours, and sulfur plant had not been inspected for 5 months or more based on the inspection tags.

 

Violation 3 Item 7

Violation Type: General; $0

WAC 296-800-30025

The employer did not train employees or did not provide effective training to employees on the use of portable fire extinguishers in incipient stage firefighting. Employees interviewed stated they were expected to use fire extinguishers but could not recall when they had been trained on them, even though training records showed they had been trained two months prior to questioning. Four employees were not trained within one year of the opening conference.

 

Violation 3 Item 8

Violation Type: General; $0

WAC 296-817-20040(1)

The employer did not document noise exposure measurements and retain those records for at least two years and for as long as they are relied on to determine employee exposure. Noise screening was reported to have been done for the sulfur plant to verify that hearing protection was not required. However, records of this were unable to be provided.

Noise exposure data must be maintained to ensure that any changes to the facility or conditions initiate rescreening to prevent employee overexposure to noise.

 

Violation 3 Item 9

Violation Type: General; $0

WAC 296-841-20005(1)

The employer did not conduct exposure evaluations to determine or reasonably estimate employee exposures above a PEL in the following instances:

1) Dust in the sulfur plant.

2) SO2 in the sulfur plant.

3) H2S in the sulfur plant.

4) Ammonia in the transfer and storage areas.

No exposure monitoring records could be provided and employees did not recall sampling ever being performed. Employees have personal monitors for SO2, H2S, and NH3 but the data has not been evaluated. Employees were monitored for these parameters and found to be below the WAC 296-841-20025 PELs. Sample results are limited to the times and conditions collected and can vary.

 

Violation 3 Item 10

Violation Type: General; $0

WAC 296-842-10505

The employer did not designate a program administrator to implement the respiratory protection program. No program administrator was identified in the written program and as a result employee respirator use is inconsistent due to a lack of sufficient direction and training.

 

Violation 3 Item 11

Violation Type: General

WAC 296-842-12005(2)

The employer did not maintain the effectiveness of the respiratory protection program by ensuring procedures are followed, employees are monitored, and employee feedback is solicited. Numerous inconsistencies between on site observations and what is written in the program were observed.

Employees can be injured from exposure to airborne compounds on site including dust, ammonia, SO2, and H2S without an effective respiratory protection program.

 

Violation 3 Item 12

Violation Type: General; $0

WAC 296-842-12010(2)

The employer did not keep employee fit test records. Only one employee’s fit test records could be provided. Five other employees are known to have elastomeric respirators and use them.

 

Violation 3 Item 13

Violation Type: General; $0

WAC 296-842-12010(4)

The employer did not keep employee medical evaluation records. Only one employee’s medical evaluation record could be provided. Five other employees are known to have elastomeric respirators and use them. Employees can be injured from use of their respirator without confirmation that they are medically fit to wear a respirator, as confirmed through medical evaluation records.

 

Violation 3 Item 14

Violation Type: General; $0

WAC 296-842-17010(1)

The employer did not ensure that respirators are stored properly to protect them from sunlight or extreme temperatures. Most employees interviewed stated that they kept their respirators in their vehicles where they are subject to temperature extremes and sunlight.

 

Violation 3 Item 15

Violation Type: General; $0

WAC 296-842-18005(2)

The employer did not ensure that employees do not use respirators if employees have a characteristic that interferes with the respirator facepiece seal or valve function such as facial hair. Most of the employees who stated they have and use full face elastomeric respirators had facial hair.

 

Violation 3 Item 16

Violation Type: General; $0

WAC 296-901-14012(6)

The employer did not ensure that containers were labeled in accordance with the hazard communication standard detailing product identifier and words, pictures, symbols, or a combination thereof to communicate the hazards of the chemical in the following instances:

1) Totes of varying levels and colors of liquid.

2) Spray bottles of molykote and mineral spirits.

 

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