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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 are exposed to the hazards of toxic and flammable gases and of oxygen deficient atmosphere during entry into confined spaces: a) Iron and Transportation Division 1) Blast Furnace #3, Auxillary Area, Stove Platform Level- gas main. A Millwright and helper were required to enter a gas main pipe to remove coke and debris from inside the pipe. These employees were potentially exposed to carbon monoxide, natural gas, and oxygen deficient atmospheres during pipe cleaning operations, observed 8/1/89. 2) Blast Furnace Department, Blast Furnace #2: Employee(s) are required to perform periodic checks around the furnace stack. These employee(s) were exposed to carbon monoxide at levels which may be immediately dangerous to life or health (IDLH) while working in the furnace stack, observed 8/9/89, b) Steel Producing Division 1) Open hearth Department Furnace Ladel - Employee(s) entering the bell which was lowered into the ladel, were required to repair the bottom pouring hole. These employees were potentially exposed to carbon monoxide during these repair operations, observed 9/18/89. 2) Open Hearth Department Flue Number 8 - Employee(s) were required to perform maintenance and repair operations in flue Number 8. These employees were potentially exposed to carbon monoxide, welding fumes and the accidental release of steam and gases during repair operations on steam pipes, while cleaning the flues, observed 7/26/89. c) Utilities, Shops & Services Division 1) Potable Water Treatment Department, West End Chlorine Room North of Manhole: Employee(s) were required to enter a manhole to close a valve in the potable water treatment plant. These employees were potentially exposed to hydrogen sulfide gas while in the manhold, observed 8/25/89. VIOLATION NOTE: Employee(s) who entered these confined spaces were not required to adhere to the USS confined space entry procedures thereby ensuring that these employee(s) were protected upon entry and while working in these confined spaces. A written entry procedure has been developed by the Fairless Works which partially addresses aspects of safe entry. This procedure has not, however, been effectively implemented to address the following elements of confined space entry: permit issuance; atmospheric testing/monitoring; confined space preparations; medical surveillance; formal employee training; emergency rescue safety equipment and clothing; respiratory protection; effective communication and standby personnel and labeling and posting of work area. Among other methods, one feasible and acceptable abatement method to correct this hazard is to implement and utilize a confined space entry program which includes at least the following essentials: 1) Prior to employee entry into confined spaces, employees designated to perform this task shall be provided with formalized training which includes information on the nature of the hazards likely to be encountered during the confined space entry, the symptoms and consequences of contaminant overexposure and oxygen deficiency, emergency entry and exit procedures, use of applicable respirators, first aid, lock out procedures, safety equipment and safe rescue training drills shall be provided at least on an annual basis to develop and maintain the proficiency of these employees in performing confined space entry work. A system for documenting training should also be established. 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 toxic gas indicator. This testing shall be done adjacent to and throughout the accessible areas of the confined space may also be necessary depending on the nature of the work performed. 3) Where it has been determined that the confined space contains hazardous air contaminant(s) and/or and oxygen deficiency, use of mechanically-induced ventilation is necessary both before entry and during occupancy. 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 confined space and documents the location and type of work to be done, evaluation of existing hazards including atmospheric test readings, necessary protective equipment and measures. The permit shall be dated and carry an expiration time (usually for one shift only). The permit shall be posted in a conspicuous place, close to the entrance, with a copy on file with the employer. The permit shall document the implementation of necessary lockout and isolation procedures utilized to ensure safety of employees entering the confined space. 5) Rescue procedures shall be specifically designed for each entry. There shall be a trained standby person assigned to each entry 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 space. Under no circumstances should the stand-by person enter the confined space until she/he is relieved and is assured that adequate assistance is present. Rescue teams entering the confined space shall be equipped with all the above mentioned safety equipment including life lines. 6) Appropriate safety equipment clothing, such as respirators, head, hand, foot and body protection, safety belts life lines, harness and lifting devices shall be available as appropriate, for each entry. 7) Employees who enter a confined space shall have pre-placement and periodic physical examinations. These examinations should place emphasis on a general evaluation of an employee's ability to carry out his assigned duties within a confined space. The examination should also include an evaluation of the employee's ability to wear a respirator along with the employee's hearing ability. 8) Written confined space entry procedures which address entry, exit, communication/observation procedures, emergency rescue and safe work practices, shall be posted adjacent to pits, tanks, vessels or other confined space which may be entered. 9) 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 the confined space.
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