Text For Citation: 03 Item/Group: 002 Hazard: LIFTING

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 the hazard associated with improper entry opening of an atmosphere tank containing unknown concentrations of hydrogen sulfide gas without proper precautions being taken: A) Hydrogen Sulfide Gas Holder - An employee performing a non-routine task atop a 42 foot high hydrogen sulfide gas holder did not follow proper safety precautions for opening the 2ft. by 2ft. hatch on the gas holder shell. The employee was exposed to unknown levels of hydrogen sulfide gas while performing this operation. Violations Note: Employee(s) who performed work on the hydrogen sulfide gas holder were not required to adhere to the monsanto safety procedure 5-5 for breaking into pipeline/equipment/container. a written procedure for breaking into pipeline or equipment or opening any container has been developed by monsanto which partially addresses aspects of safe opening. The written procedure was not, however, effectively implemented to address the following elements: Permit issuance; atmospheric monitoring/testing; purging of lines or space preparation; formal emergency rescue; safety equipment; respiratory protection; effective communication and standby personnel and labeling and posting or work areas. Among other methods, one feasible and acceptable abatement method to correct this hazard is to implement and utilize an entry/breaking into pipeline/equipment/container program which includes at least the following essentials: 1) Prior to employee entry into pipelines or tank holders formalized training shall be provided which includes information in the nature of the hazards likely to be encountered including entry, the symptoms and consequences of contaminant overexposure and oxygen deficiency, emergency procedures. Use of applicable respirators, first aid, lock out/isolation procedures, 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 area of the tank opening, and shall be carried out prior to each opening. Periodic retesting while employees are in the area may also be necessary depending on the nature of the work performed. 3) Where it has been determined that the tank holder contains hazardous air contaminant(s) and for an oxygen deficiency, use of mechanically induced ventilation is necessary both before opening the vessel. Appropriate respiratory protection against the hazard encountered may also be required. 4) A permit system shall be implemented which provides written authorization to enter the tank holder and documents the location and type of work to be done, evaluation of existing protective hazards, including atmospehric test readings, necessary protective equipment and measures. The permit shall be dated and carry an expiration time (usually for one (1) shift only). The permit shall document the implementation of necessary lockout and isolation procedures utilized to ensure safety of employees entering the area. 5) Rescue procedures shall be specifically designed for each entry. There shall be a trained standby person assigned to each with a fully charged, positive pressure self-contained breathing apparatus (scba) at hand. Additional duties of the stand-by person are to maintain unobstructed life lines and communications to any workers inside the open area (space). Under no circumstances should the stand-by person enter the area until she/he is relieved and is assured that adequate assistance is present. Rescue teams entering the area shall be equipped with all the above mentioned safety equipment including life lines. 6) Appropriate safety equipment and clothing, such as respirators, head, hand, foot and body protection, safety belts, life lines, harness and lifting device shall be available as appropriate, for each entry. 7) Written entry procedures which address entry, communication/ observation procedures, emergency rescue and safe work practices, shall be posted adjacent to pipeline, vessels of equipment opening or container openings. 8) Signs shall be posted, as a means of employee information near permit spaces to notify employees of those hazards which may be present and serve notice that only authorized employees may enter areas.