Text For Citation: 01 Item/Group: 001A Hazard: CHEMICAL

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The %% employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to hazards including eye and inhalation exposure to leachate gases associated with improper safety/work practices during the transfer of leachate liquid/slurry from the underground storage tank to the tanker truck for disposal: The alleged violations below have been grouped because they involve similar or related hazards that may increase the potential for illness. a) Leachate Holding Tank - An employee transferring leachate slurry while on top of a tanker truck was exposed to leachate gases and was overcome. Proper safety precautions were not developed or followed for transferring leachate liquid/slurry from underground storage tank to tank truck, thus exposing employees to unknown levels of leachate gases. Among other methods, one feasible and acceptable abatement method to correct this hazard is to implement and utilize a tank emptying/processing program which includes at least the following essentials: 1) prior to employees conducting such processes formalized training shall be provided which includes information on the nature of the hazards likely to be encountered including the presence of contaminants/gases, the symptoms and consequences of contaminated overexposure and oxygen deficiency, emergency procedures, use of applicable respirators, first aid, safety equipment and safe rescue procedures. 2) A program of atmospheric testing for oxygen deficiency, flammable gases and vapors and other hazardous atmospheric contaminants shall be implemented and performed by qualified persons who have received formal training using properly calibrated direct reading oxygen, combustible gas and toxic gas indicator. This testing shall be done adjacent to the accessible areas of the tank opening and shall be carried out prior to and during each tank opening. While employees are working in the area, they must carry atmospheric monitoring devices, with alarms which meet the above criterion. 3) There shall be a trained standby person assigned during each tank processing operation, with a fully charged, positive pressure self contained breathing apparatus (SCBA) at hand. Additional duties of the stand-by person are to maintain unobstructed view and communications to any worker working around the tank processing area. Under no circumstances should the stand-by person enter the area until he/she is relieved and is assured that adequate assistance is present. 4) Appropriate safety equipment and clothing, such as respirators, head, foot, hand and body protection shall be available as appropriate for each tank process. 5) Written processing procedures which address set-up communication/observation procedures, emergency rescue and safe work practices shall be developed. 6) Signs shall be posted, as a means of employee information near tank processing spaces to notify employees of those hazards which may be present and serve notice that only authorized employees may enter areas. 7) Engineering controls which could significantly reduce or limit employee exposure shall also be developed. Examples of such engineering controls would be: a) Development of a system to power ventilate and agitate materials in the underground storage tank to reduce the build-up of leachate gases. b) Development of a system for filling the tank truck which would eliminate or greatly reduce the need for employees to work in the area of the transfer process. This could include a permanent rigid piping system under which the tank truck could be backed for filling.