OSHA's Got its Eyes Trained on Transportation Tank Cleaning Operations

Crowe & Dunlevy
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Occupational Safety and Health Administration (OSHA) Region 6—the region covering Oklahoma, Arkansas, Louisiana, Texas and New Mexico—recently announced a new local emphasis program. Local emphasis programs (LEPs) are enforcement strategies designed and implemented by regional offices to target hazards or industries that pose a particular risk to workers in the office's jurisdiction. LEPs programs operate on the carrot and stick approach. The “carrot” is OSHA’s offer of special outreach and educational opportunities through its local and regional OSHA offices. The “stick” is a round of programmed inspections, where agents randomly choose employers within the covered industry for surprise inspections.

Concerned about the number of serious injuries and fatalities related to transportation tank cleaning operations over the past five years, the Region 6 office has chosen to focus its newest LEP on transportation tank cleaning companies. LEP-related enforcement activities will focus on worksites in the business of cleaning, repairing and/or maintaining truck and rail transportation tanks. Inspections will include, but not be limited to, the inspection and review of production operations; working conditions; injury and illness records; safety and health programs and chemical handling and use. OSHA will be paying particular attention to compliance with OSHA standards related to the following:

  • Permit Required Confined Space Program
  • Respiratory Protection Program
  • Hazard Communication
  • Personal Protective Equipment

Covered companies have until October 23, 2021, before programmed inspections under this LEP begin.  (Of course, non-programmed inspections, including those motivated by complaints and fatality and serious injury reports continue as usual.) This interlude – between announcement and programmed enforcement – provides covered companies with an opportunity to reevaluate their current safety programs, including those of particular interest to OSHA, and ensure that their written programs as well as on-the-ground safety practices meet or exceed the OSHA standards.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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