OSHA Inspection: LUDLOW TECHNICAL PRODUCTS

Issued

Feb 2, 1995

Abate by

Feb 8, 1995

Penalty

Initial $2,625 · Current $1,300 Reduced

Hazardous substances A101

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized hazards that
were causing or likely to cause death or serious physical harm to
employees in that employees
were exposed to fire and explosion hazards where aluminum dusts were
generated. The hazards
were caused by the following conditions:
THE EMPLOYER DID NOT FOLLOW THE REQUIREMENTS OF THE FOLLOWING
STANDARD SECTIONS OF THE NATIONAL FIRE PROTECTION ASSOCIATIONS
(NFPA) CODES ON ALUMINUM PROCESSING AND FINISHING INCLUDING
BUT NOT LIMITED TO DESIGN, STRENGTH, FIRE PROTECTION, AND DUST
COLLECTION.
a) NFPA STANDARD NUMBER 65, CHAPTER 2-1, DUST COLLECTION ,SUBPART
21.5,
THE ABRADER'S DRY TYPE DUST COLLECTOR WAS NOT LOCATED OUTSIDE
OF THE BUILDING.
b) NFPA STANDARD NUMBER 65, CHAPTER 2-2, DUCTS AND DUCTWORK, SUBPART
2-2.5 THE DUCTWORK EXHAUSTING THE ABRADER TO THE DUST COLLECTOR
WAS NOT OF METAL CONSTRUCTION WITH SMOOTH INTERIOR SURFACES.
c) NFPA STANDARD NUMBER 65, CHAPTER 2-4, DRY TYPE DUST COLLECTORS,
SUBPART 2-4.2, THE SIMCO DUST COLLECTOR USED FOR THE COLLECTION OF
ALUMINUM DUSTS FROM THE ABRADER UTILIZED FILTER MEDIA MADE FROM
SYNTHETIC FABRICS WHICH ACCUMULATE HIGH STATIC CHARGE.
d) NFPA STANDARD NUMBER 65, CHAPTER 2-4, DRY TYPE DUST COLLECTORS,
SUBPART 2-4.3 ALUMINUM DUST GENERATED BY THE ABRADING PROCESS WAS
NOT REMOVED FROM THE SIMCO DRY COLLECTOR AT LEAST DAILY IN
ACCORDANCE WITH THIS SUBPART.
e) NFPA STANDARD NUMBER 65, CHAPTER 2-4 DRY TYPE DUST COLLECTORS,
SUBPART 2-4.5 THE ABRADERS DRY TYPE DUST COLLECTION EQUIPMENT WAS
NOT PROVIDED WITH EXPLOSION VENTING IN ACCORDANCE WITH NFPA 68
WHERE AN EXPLOSION HAZARD EXISTED.
f) NFPA STANDARD NUMBER 65, CHAPTER 3-1, FIRE SAFE PRACTICES, SUBPART
3-1.4. A SEARS WET DRY VAC NOT SPECIFICALLY APPROVED FOR THE
COLLECTION OF REACTIVE COMBUSTIBLE METAL DUSTS WAS USED TO
SUPPLEMENT THE ABRADERS EXHAUST VENTILATION SYSTEM AND FOR CLEAN
UP OF FUGITIVE ALUMINUM DUST IN AND AROUND THE ABRADING MACHINE
AND DUST COLLECTING EQUIPMENT .
g) NFPA STANDARD NUMBER 65, CHAPTER 5. FIRE PROTECTION,SUBPART 5-1.1;
THE EMPLOYER DID NOT PROVIDE A CLASS D TYPE FIRE EXTINGUISHER IN THE
ALUMINUM ABRADING AREA WHERE METAL DUST WAS PRESENT.
AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT
METHOD TO CORRECT THESE HAZARDS IS TO HAVE THE ABRADER, ITS
OPERATING PROCEDURES, AND DUST COLLECTION SYSTEM MEET THE
REQUIREMENTS OF THE NATIONAL FIRE PROTECTION ASSOCIATIONS CODES FOR
FOR PROCESSING AND FINISHING OF ALUMINUM AS SET FORTH BY NFPA 65 1987,
AND ALL OTHER CODES REFERENCED BY NFPA 65.

Issued

Feb 2, 1995

Abate by

Mar 7, 1995

Penalty

Initial $2,625 · Current $1,325 Reduced

Hazardous substances A101

Issued

Feb 2, 1995

Abate by

Feb 7, 1995

Penalty

Initial $4,500 · Current $2,250 Reduced

Hazardous substances A101

Issued

Feb 2, 1995

Abate by

Mar 7, 1995

Penalty

Initial $1,500 · Current $750 Reduced

Issued

Feb 2, 1995

Abate by

Feb 7, 1995

Penalty

Initial $4,500 · Current $2,250 Reduced

Issued

Feb 2, 1995

Abate by

Feb 7, 1995