OSHA Inspection: ZOE CHEMICAL CO. INC.

Issued

Nov 21, 1991

Abate by

Jun 15, 1992

Penalty

Initial $2,500 · Current $2,125 Reduced

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 the hazard of fires and explosions from the manufacture
of aerosol products.
(a)  Production Department; Employees with the job titles
of Operators, Batchmakers and Maintenance workers were
exposed to the potential for fires and explosions during
the manufacture of aerosol products.  The job tasks include
but are not limited to, mixing base product, filling cans
with isobutane in gas houses, and the warehouse and storage
of the final product; on or about 6/5/91.
ABATEMENT NOTES:
Among other methods, one feasible abatement method to reduce this
hazard, is to establish and enforce adequate procedures for manufactur-
ing and warehousing as stipulated by the National Fire Protection
Association Code for the Manufacture and Storage of Aerosol Products,
NFPA 30B, 1990.  Elements essential to protect employees include at a
minimum:
1.   All openings (i.e. doorways, ductwork, and conveyor lines) shall
be protected with automatic closing or self-closing fire doors or
dampers.
2.   Flammable propellant charging and pump rooms shall be separated
from flammable propellant storage by a distance of at least 25 feet.
3.   Deflagration venting shall be provided for flammable propellant
charging and pump rooms.
4.   Mechanical exhaust ventilation shall be provided for flammable
propellant chrging and pump rooms.  Ventilation systems shall
include exhaust systems and make-up air systems.  The ventilation
system shall meet the following requirments:
a.   The ventilation shall be nonrecirculating
b   Make-up air shall be taken either directly from outside or
from areas of the building where flammable vapors are not
present.
c.   Air inlets and outlets shall be located so that air flows
uniformly across the floor of the room.  The bottom of the
air inlets and outlets shall be no more than 6 inches above
the floor.
d.   Ventilation shall be not less than one air change per minute.
e.   Emergency ventilation shall be automaticaly activated at not
more than 20 percent of the lower flammable limit.  It shall
be designed to provide 150 percent of the air flow rate, or
two changes per minute.
f.   Exhaust discharge stacks shall be separated horizontally by
at least 10 feet above the roof and at least 3 feet above any
other building within 25 feet.
g.   Exhaust ventilation air flow shall be suitably monitored to
enable automatic shutdown of the propellant filling line in
event of failure of the ventilation system.
h.   All fan blades utilized by the exhaust and make-up air
systems shall be of spark proof material.
i    The room shall be maintained at a negative pressure in
relation of the ambient air.
5.   Aerosol container test baths shall be enclosed and provided with
exhaust ventilation.
6.   Local exhaust ventilation shall be provided for reject aerosol
container receptacles that are located within buildings.
7.   All equipment involved in the manufature of aerosol products
shall be suitably bonded and grounded.
8.   Flammable propellent charging and pump rooms shall be provided
with an approved gas detection system that is equipped with
audible or visible alarms.  The gas detection systems shall be
interlocked so that at the detection of 20% of the lower explosive
limit, the alarm activates and the general ventilation flow rate
increases to two air changes per minute.  At the detection of 40%
of the lower explosive limit, the audible alarm activates.  The
main propellant line, all equipment in the charging room, and the
vaccuum pumps used in conjuction with aerosol can filling, shall
all automatically shut down.  Annuciation of the gas detection
system alarm shall be within the charging and pump rooms and in
nearby production areas.
9.   Flammable propellant charging and pumps room shall be protected
by either a wet pipe or a deluge type automatic sprinler system.
10.  Drainage systems shall be procided to direct leaks and spills to a
safe location.
11.  An explosion suppression system meeting the requirements of NFPA
69 shall be installed in any flammable propellant charging room
where personnel are permitted to enter during propellant charging
operations.
12.  Aerosol laboratores shall be considered as Class A laboratory
units, and shall comply with NFPA 45, Standard on Fire Protection
for Laboratories Using Chemicals.  Tests for total discharge, rate
of spray, spray pattern, and net weight shall be conducted with
proper ventilation.
13.  Aerosol products shall be classified as Level 1, Level 2 or  Level
3.  All cartons or aerosol products shall be identified with the
classification of the aerosol products contained therein.  Storage
height, clearance requirements and quantity of mateiral stored
shall be in accordance with NFPA 30B, Chapter 4, "Storage in
Warehouses and Storage Areas", depending on the classification of
the aerosol product.
14.  Filled or partly filled aerosol containers shall be seperated from
all other rubbish and trash and shall be placed in noncombustible
waste containers.  They shall not be disposed of in compactors,
balers, or incinerators that could crush the container or heat its
contents.
15.  A written and documented preventive maintenance program  shall be
developed for equipment, machinery, and processes that are crit-
ical to firesafe operation of the facility.

Issued

Nov 21, 1991

Abate by

Jan 31, 1992

Penalty

Initial $1,750 · Current $1,375 Reduced

Issued

Nov 21, 1991

Abate by

Jan 31, 1992

Penalty

Initial $1,250 · Current $875 Reduced

Issued

Nov 21, 1991

Abate by

Jan 31, 1992

Penalty

Initial $1,250 · Current $875 Reduced

Issued

Nov 21, 1991

Abate by

Jan 31, 1992

Penalty

Initial $1,250 · Current $875 Reduced

Issued

Nov 21, 1991

Abate by

Jan 31, 1992

Penalty

Initial $1,750 · Current $1,375 Reduced

Issued

Nov 21, 1991

Abate by

Jan 31, 1992

Penalty

Initial $1,750 · Current $1,375 Reduced

Issued

Nov 21, 1991

Abate by

Jan 31, 1992

Penalty

Initial $1,750 · Current $1,375 Reduced

Issued

Nov 21, 1991

Abate by

Jan 31, 1992

Penalty

Initial $1,750 · Current $1,375 Reduced

Issued

Nov 21, 1991

Abate by

Jan 31, 1992

Issued

Nov 21, 1991

Abate by

Jan 31, 1992

Penalty

Initial $1,750 · Current $1,375 Reduced

Issued

Nov 21, 1991

Abate by

Jan 31, 1992

Issued

Nov 21, 1991

Abate by

Jan 31, 1992