Showing posts with label OSHA. Show all posts
Showing posts with label OSHA. Show all posts

Tuesday, July 18, 2017

Gloucester County Employee Resigns After Exposure To Carbon Monoxide

When I served on the Gloucester County Public Utilities Advisory Committee, one of the areas I found to be unacceptable was our Utilities Department’s workplace safety program, or literal lack thereof. Insuring that our employees are properly trained on workplace safety and making sure they religiously follow applicable rules, regulations and procedures established to protect their health and life should always be at the top of operational priorities. This is especially true for operations involving confined spaces in sewer pump stations and manholes due to the extremely high probability that they contain at least one of numerous deadly gases.

The Gloucester Department of Public Utilities' May report contains the following entry:

“filed incident report for Mr. Jackson’s exposure to elevated CO levels in the wet well of PS #11 on May 5th;”

After reading the entry I sent an email containing my concerns to the Board of Supervisors, the County Administrator and the Director of Utilities which resulted in an email conversation with the director. After that conversation I continue to believe there is still need for improvement and believe you will too after reading the email conversation that can be found below. Mr. Jackson resigned from the Utilities Department a few weeks after the incident.

Kenny Hogge, Sr.
Gloucester Point

Email Conversation   
From: Kenny  
Sent: Wednesday, July 05, 2017 12:49 PM
To: Board of Supervisors <>; Fedors, Brent <>; Dawson, James C. <>
Subject: Carbon Monoxide Exposure Incident
The May 2017 Utility Department monthly report contains the following comment: filed incident report for Mr. Jackson’s exposure to elevated CO levels in the wet well of PS #11 on May 5th;
This is a very concerning, dangerous and preventable incident. Was air quality testing performed before and during Mr. Jackson’s entry into the wet well? Was ventilation performed before and during his entry? Was Mr. Jackson connected to an appropriate retrieval system? What was the source of the carbon monoxide?
Kenneth E. Hogge, Sr.

From: "Dawson, James C." <>
To: Kenny; Board of Supervisors <>; "Fedors, Brent" <
Cc: "Curry, Garrey, Jr." <>
Sent: Wednesday, July 5, 2017 1:26 PM
Subject: RE: Carbon Monoxide Exposure Incident

Mr. Hogge,
Thank you for your inquiry.
Air quality in the wet well was sampled before entry in compliance with OSHA regulations and the results are documented on the Confined Space Entry Permit for that space entry. The wet well vent fan was operating and Mr. Jackson was wearing a properly calibrated “sniffer” while he was working in the wet well. Mr. Jackson was connected to a retrieval system.
Mr. Jackson was pulling rags off the bar screen when the “sniffer” he was wearing alarmed for carbon monoxide (CO). He immediately began to exit the wet well. The alarm cleared before he could exit the wet well but he waited a few minutes to see if the alarm returned before resuming his pulling rags.
There were no known sources of CO in operation while Mr. Jackson was working in the wet well so we believe the CO came from the accumulation of rags on the bar screen which were last pulled on May 1st.
Mr. Jackson reported some discomfort shortly after completing the work at PS #11 on May 5th so we filed the incident report and offered to send him to a doctor on our Workers Compensation Panel of Physicians.
James C. Dawson, P.E.
Director, Dept. of Public Utilities

On Jul 7, 2017, at 9:02 PM, Kenny wrote:
Thank you for the timely and detailed response. It is refreshing to hear that at least some OSHA confined space entry procedures are being practiced. However, your response seems to suggest Mr. Jackson may not have fully exited the wet well once the alarm sounded and that other OSHA requirements for an atmospheric alarm during an entry may not have been followed.  
According to OSHA regulations; if a hazardous atmosphere is detected during a confined space entry, all employees are supposed to leave the space immediately, the space is supposed to be evaluated to determine how the hazardous atmosphere developed and measures are supposed to be implemented to protect employees from the hazardous atmosphere before anyone is permitted to reenter the space.
Nothing in OSHA confined space requirements or guidance provides any latitude at all for any employee to unilaterally disregard an atmospheric alarm and to ignore prescribed and proven safety measures.
Utilization of only an exhaust fan to clear the air in wet wells and manholes is problematic to say the least. When air is drawn out of a confined space, much of the area within the space lacks circulation. Inadequate air circulation severely limits the effective removal of contaminated atmospheres within the space. When using only an exhaust fan, clean air is typically only drawn in at the hatch opening and the lethal pockets and layers of bad air outside of the confined flow path between the hatch and the exhaust fan will be left in the confined space.
Forced air blowers providing the proper CFM of clean air through a properly configured duct system are far safer than utilizing only exhaust fans because clean air is being forced into the space. When clean air is forced into the space it creates adequate circulation and dilutes the atmospheres, resulting in harmful gases being expelled more completely and efficiently. Utilizing a blower or combination blower and exhaust fan, instead of just an exhaust fan, will also allow the flow of clean air to be directed to best cover the area in the space where the employee will be working; therefore better protecting the employee.    
In your response you made it a point of stating a properly calibrated detector was used. I can’t help but wonder, by its exclusion from your response, if the detector used by Mr. Jackson was bump tested prior to being used that day. As I am sure you know, daily bump testing is not addressed in OSHA confined space entry requirements, but is highly recommended by most if not all reputable detector manufacturers. Taking a few minutes to verify a detector is working the way it is supposed to before beginning to use it each day is a small price to pay to prevent injury or death.  
Depending on the model, body worn detectors can certainly have their benefits in certain confined spaces, but based on personal experiences, I recommend against relying solely on body worn detectors to keep employees safe when working in active wet wells and manholes. I also recommend increased training for at least those employees designated to enter, supervise and attend confined spaces.
Kenny Hogge, Sr.

Message body

Tuesday, February 7, 2017

My experiences while serving as an At-Large member of the Gloucester County, Virginia Public Utilities Advisory Committee (PUAC) (The 5th in a series of articles about my experiences and findings)

Our Public Sewer Collection System

Like our public water system, parts of our public sewer collection system are very old and in need of attention sooner than later. Our sewer system is made up of a series of underground pipes, manholes and pumping stations; with some components in the Courthouse area dating back to the 1950’s.

Many of the Courthouse area sewer components and components in other areas of our sewer system are not sealed to prevent rain and ground water from entering the system and to prevent sewer water from escaping into the environment. In fact there is at least one building in the Courthouse area that has its storm drain pipes connected to our public sewer system. When rain and groundwater enter our sewer system it greatly increases the amount of sewer water that must be treated before it can be released back into the environment. Rain and ground water infiltration also increases the workload on our pumping stations, causing some stations to be flooded and overwhelmed during heavy rain and flood events. Because sewer pumping stations are typically built on low land, overwhelmed and flooded sewer systems have the potential to cause negative environmental impacts to our creeks, rivers, streams, etc. All of these negative impacts equate to a lot of tax and utility customer dollars being flushed down the drain.

Environmentally sound, operationally capable and dependable pumping stations are necessary components of our sewer system. Some of our older pumping stations pose significant operational and environmental risks. At least two of our pumping stations need to be completely replaced due to their age, size and the way they were built. We also have several pumping stations that need to be upgraded because they are so old that it is impossible to obtain repair and replacement parts. These stations typically contain two pumps, but some of our stations only have one operational pump. Not having an operational backup pump significantly decreases dependability and greatly increases environmental and other risks. It will cost a substantial amount of money to upgrade the pumping stations that need it, but it will cost far less than complete replacement of the stations. The needs of our pumping stations are all part of normal public sewer system operations and maintenance and should have been financially planned for years ago.

Employee safety in and around sewer pump stations, manholes and other such high risk areas should always be a high priority to those we hire and elect. Sadly and alarmingly that is not what I found to be the case in Gloucester County. In fact, it was quite the opposite.

Sewer pumping stations pose numerous health and safety risks to those who operate and maintain them. Sewer gases can form in pumping station tanks that will incapacitate a person within three seconds. Imagine climbing down a ladder into a tank 15 feet deep with liquid several feet deep below you. Imagine becoming incapacitated after you take one or two breaths. You will fall in and die if you are not already connected to a retrieval system and someone uses it to remove you from the tank immediately. It has happened, many, many times all over the world. In fact, in September 1996 four construction workers died on the Navel Weapons Station pier in Yorktown. One man entered a pumping station tank and became incapacitated. Another man entered to help the first man and he too was knocked out by sewer gas. Another man went in to help, he too fell out. A fourth man climbed in and he went down too. A fifth man called for help when he discovered what happened, but it was too late. All four men were dead within minutes because mandated employee safety procedures were not followed. What is even worse is they had an air quality tester and a retrieval system right there with them, but chose not to utilize them.  

The Occupational Safety and Health Administration or OSHA has established mandatory employee safety procedures for entering confined spaces like sewer manholes and pumping station tanks. Failure to follow OSHA mandated permit required confined space entry procedures can result in injury and death of employees; and fines, jail time and lawsuits for supervisors, executives, businesses, counties, cities, etc. Utilities has a portable tripod and wench retrieval system that can be connected to a single person when they enter some types of confined spaces. This system does not work at some of our pumping stations because of they way the stations were built and how much room the tripod requires. I suggested constructing a fixed retrieval system at these pump stations, but do not know if anything has been done as of yet to protect our employees and comply with law. Utilities also has air quality testers, but it appears they started using them only year or so ago. For years our elected representatives, hired government administrators and leaders of our utilities department have been allowing our labor level employees to enter potential death traps, on almost a daily bases, without testing air quality, utilizing adequate retrieval systems or following other workplace safety laws.

Over the years a heck of a lot of what I have shared in this and other articles about my experiences on the PUAC has been made known to our elected representatives and hired administrators. Over the years they have all continued to kick the can down the road. Well, the can has become thin and the road short. Before our current elected representatives throw more money away on pipe dreams of industrializing our County in support of turning it into a retirement community, they need to rectify our infrastructure deficiencies and set in place ordinances that will provide the necessary mandates to prevent further neglect, fraud, waste and abuse of our public water and sewer systems.

Keep following and please share with everyone you know in Gloucester County.

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Kenny Hogge, Sr.
Gloucester Point, Virginia