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Occupational Safety and Health Administration OSHA

Citation 312926280/01001

InspectionReporting IDOpen DateSICEstablishment Name
312926280 0626700 02/09/2011 4231Enterprise Products Transportation Company, Llc

CitationIssuance DateHazard Category
01001 08/04/2011 Falling

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer does not furnish employment and a place of employment which are free from the recognized hazard of falling from elevated working surfaces when fall protection systems are not properly designed, installed, inspected and maintained, exposing employees to conditions causing or likely to cause death or serious physical harm. This was observed on February 9, 2011 and thereafter, when horizontal lifelines were not designed by a qualified person, fall clearances were inadequate to prevent a falling employee from striking lower surfaces, and fall protection components were corroded, not functional, and improperly installed. The conditions observed exposed employees working on the top of tanker trailers to fall hazards of approximately 11 feet. These conditions include, but are not limited to: a)In all 6 bays, the fall protection system being used employs a horizontal lifeline spanning the 70 foot length of each bay, that was not designed by a qualified person utilizing acceptable engineering practice to determine that the system, including all components will perform as intended, including evaluation of the estimated forces in comparison to the strength of components being used. b)In all 6 bays, the formed eyes of wire rope do not employ the use of thimbles to prevent damage to the wire rope. c)In shop bay 3, clips used to form eyes of wire rope are installed backwards with the saddle of the clip on the dead end of the wire rope. d)In all 6 bays, screw pin shackles used as anchorage attachment devices in the horizontal lifeline system did not have the hole end of the shackle pin moused with wire to prevent loosening of the pin due to vibration, and are subject to side loading as arranged. e)In wash bay 1, the Miller retractable lifeline and rescue device was severely corroded, the safety hook no longer swiveled, and the required two step action ot open the hook was defeated by corrosion allowing it to be opened with a single action. The equipment was not inspected utilizing the manufacturer's instructions. f)In all 6 bays, the fall protection system was not selected to satisfactorily limit total fall distance and allow for dynamic elongation, including activation distance of the connecting subsystem, and elongation of the horizontal lifeline, lanyard, energy absorber and harness. One feasible and acceptable method of abatement to correct this hazard would be to install a personal fall arrest system, with horizontal lifeline and retractable lanyard designed by a qualified person, installed in accordance with manufacturer's instructions, inspected and maintained as described in manufacturer's instructions and ANSI Z359.1- 1993. Pursuant to 29 CFR 1903.19, within ten (10) calendar days from the abatement date of this citation, the employer must submit documentation showing that fall protection sytems and components are designed, installed and maintained in accordance with manufacturer's instructions.

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