Worker Safety and Health Enforcement Program Experience

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Worker Safety and Health Enforcement Program
Experience
Kathy McCarty Director, Office of Worker Safety
and Health Enforcement Office of Health, Safety
and Security March 17, 2010
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Actions Completed (since last conference)
SLAC Notices of Violation - PVC pipe explosion
- Stanford University and two subcontractors
ANL Notice of Violation - arsenic ampoule
explosion - carbon monoxide overexposure
BNL Consent Order - well house explosion
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Actions Completed (since last conference)
Enforcement Letters - Parsons (SRS) Form Wood
Timber Fire - CWI (Idaho) Electrical Safety
Deficiencies
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Ongoing Cases

• LLNL Beryllium Program Deficiencies
• SNL Sled Track Accident
• ETTP Electrical Arc Event
• LANL Electrical Shock Event
• WCH Catwalk Fall
• SRNS Nitric Acid Spill and Electrical Arc Event
• - Parsons (SRS) Crane Lubrication Hand Injury

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Arsenic Ampoule Explosion

• Principal Investigator attempting to synthesize a
  new material described in an as yet unpublished
  journal article
• Two small sealed quartz ampoules containing
  elemental arsenic and iron, and a lanthanum
  compound heated in a muffle furnace
• Ampoules fail catastrophically

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Arsenic Ampoule Explosion

• Smoke alarm activates and building evacuated
• One evacuee notes a white haze in laboratory
• Laboratory was unoccupied no injuries

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Problems Identified

• Did not have an approved Experiment Safety Review
• Did not identify use of carcinogens in laboratory
• Did not identify pressure hazard associated with
  heating arsenic above its sublimation temperature
• Did not operate the muffle furnace in a fume hood
  as required by procedures
• Principal Investigator was not trained on
  carcinogen health hazards and control measures

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Carbon Monoxide Exposure

• Glove bag containing CO is used to manipulate
  samples housed in a Scanning Tunneling Microscope
  holder
• CO is needed to maintain the sample in the proper
  chemical state
• Glove bag used in a continuously vented fume hood
• Glove bag was only partially sealed during
  inflation with CO
• Glove bag is opened and pressure applied with
  hands for deflation

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Carbon Monoxide Exposure

• Postdoctoral researcher conducting experiment for
  the first time using CO experiences symptoms of
  CO overexposure
• Transported to local hospital
• Carboxyhemoglobin level measured three times the
  ACGIH BEI after two hours of oxygen
  administration

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Experimental Steps
1. Open deflated glove bag
Fume Hood
2. STM Parts inside
3. Sealing the glove bag
4. Inflating with CO
5. Assembling STM Box
6. Seal removal
STM Box
7. Deflating Glove Bag
CO- sensor
CO
Glove Bag
8. Removing STM Box
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Wide-Mouth Canister
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Problems Identified

• Did not have an approved Experiment Safety
  Review work conducted using an unapproved draft
  procedure
• Potential for worker exposure to CO was not
  assessed prior to experiments workplace
  monitoring not conducted
• Appropriate hazard controls for use of a
  flammable gas and asphyxiant were not identified
• Inappropriate CO monitors used

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Problems Identified

• Fume hood was not evaluated
• Fume hood had no flow monitor or low flow alarm
• Researcher was not effectively trained on hazard
  controls for asphyxiants

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Problems Common to Both Events

• Division ESH Coordinator was not trained and
  qualified to manage the divisions safety program
  
• Division did not implement corporate experiment
  safety review process requirements
• Division Chemical Hygiene Plan was not updated to
  reflect laboratory hazards

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Notice of Violation

• Four Severity Level I violations
• Noncompliances were not reported into the DOE
  Noncompliance Tracking System in a timely manner
• No mitigation provided due to weaknesses in event
  investigations, time required to fully develop
  corrective actions, and failure to correct prior
  deficiencies in the divisions experiment safety
  review process
• Civil Penalty of 280,000

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Citations

• Hazard identification and assessment (851.21)
• Hazard prevention and abatement (851.22)
• Training and information (851.25)
• General requirements, procedural adherence
  (851.10)
• 29 CFR 1910.1450(b), (e), and (f) NFPA 45

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Worker Safety and Health Enforcement Reforms

• Rapid response to safety significant events
• Focus on contractors ability to identify
  applicable regulatory requirements and
  noncompliances
• Emphasize noncompliances with OSHA requirements

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Resources

• Office of Enforcement Web Page
• http//www.hss.energy.gov/Enforce/
• Enforcement Process Overview
• http//www.hss.energy.gov/enforce/Final_EPO_J
  une_2009_v4.pdf