Safety and Health Plans Must Comply with the OSHA Respiratory Protection Standard

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Type:  Lessons Learned

Publisher:  U. S. Department of Energy, Office of Fossil Energy

Published As:  Public


Topics:  Respiratory Protection, Occupational Safety and Health, Confined Space

When an Accident Investigation Board convened to investigate a scissor lift tip-over injury at the Strategic Petroleum Reserve (SPR) during abrasive blasting inside a tank, early attention to possible causes considered the fact that the scissor lift operator was wearing a supplied air respirator. Although the board determined that the respirator did not contribute to the fall, its research into the respirators, air compressor, and compressed air quality testing led to a review of all documents related to the respiratory protection in effect at the time of the incident. The board found that safety and health documents submitted by the subcontractor prior to work authorization were generic and lacked any information about the identity and anticipated concentrations of airborne hazards. Although the job safety analysis recommended the use of a specific make and model of a supplied air blasters helmet, the plan did not specify the equipment or the procedures to be used to provide supplied air for the respirators, the air quality testing procedures, or testing frequency to ensure supplied air quality. Because none of the safety and health plan reviewers commented on these deficiencies, the work was authorized without requiring the subcontractor to correct and re-submit the safety and health plan.

Lessons Learned: Safety documents that require the use of respiratory protection must identify the atmospheric hazard(s) of concern, the anticipated levels, the methods to be used to evaluate those levels, and proper respirator use procedures.

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