OSHA Inspection: POLYCHEM DISPERSIONS, INC.

Issued

Nov 1, 2000

Abate by

May 1, 2001

Penalty

Initial $2,250 · Current $1,350 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 burn and explosion hazards:
On August 16, 2000, an explosion took place in the Littleford mixer that
was blending a batch
containing Celogen OT, the principle ingredient of which is p,p'-oxybis
(benzene
sulfonylhydrazide), a flammable dust.  The force of the explosion opened
the product door on
the right, spraying an employee who was walking in the aisle way next to
the mixer.  The
explosion also vented up the explosion vent on the right, which discharged
next to the hopper
and the work platform.  The deflagration venting and other aspects of the
design of the Littleford
mixer and its work area do not conform to NFPA 654, "Standard for the
Prevention of Fire and
Dust Explosions for the Manufacturing, Processing and Handling of
Combustible
Particulate
Solids," 1997 Edition.
a) The Littleford mixer used for blending Celogen OT was not segregated
from other operations
by dust-tight physical barriers or separated from other operations by at
least 30 feet, including
a loading dock, aisle ways for pedestrian and lift truck traffic, and
other operations in rooms
with open doorways.  This is not in accordance with NFPA 654, Section 2-2,
"Segregation,
Separation, or Detachment of Combustible Dust Handling and Processing
Areas," which states
in relevant portions:
2-2.1 General: Areas in which combustible dusts are processed or handled
shall be
detached, segregated, or separated from other occupancies to minimize
damage if a fire
or explosion occurs.
2-2.2.1 Physical barriers erected to segregate dust hazards shall have all
penetrations of
floors, walls, ceilings, or partitions sealed dust-tight and, where
structural assemblies
have a fire endurance rating, the seal shall maintain that rating.
2-2.3.2 The required separation distance between the hazardous area
identified in 2-2.3.1
and surrounding exposures shall be determined by an engineering evaluation
addressing
the properties of the materials, the type of operation, the amount of
material likely to be
present outside the process equipment, the design of the building, and the
nature of
surrounding exposures.  In no case shall the distance be less that 30 feet
(9 meters).
b) The discharge of material from the explosion relief vent on the right
near the hopper of the
Littleford mixer and the work platform is not in accordance with NFPA 654,
Section 2-4,
"Deflagration Venting", and Section 2-5, "Relief Valves," which state as
follows:
2-4.2 Vent closures shall be directed toward a personnel restricted area,
or
the vent
closure shall be restrained to minimize the missile hazard to personnel
and equipment.
The fireball emitted from the vent opening shall not impinge upon
personnel pathways.
2-5 Relief valves shall not be vented to a dust hazard area as defined by
2-2.3.1.
c) The dust collection system did not have isolation devices to prevent
the explosion from
reaching the dust collector.  This is not in accordance with NFPA 654,
Section 3-1.2,
"Equipment Isolation," which states in relevant part:
3-1.2.1 Isolation devices shall be provided to prevent deflagration
propagation between
pieces of equipment connected by ductwork.  Isolation devices include, but
are not
limited to:
(a) Chokes
(b) Rotary valves
(c) Automatic fast-acting valve systems in accordance with NFPA 69,
"Standard
on Explosion Prevention Systems"
(d) Flame front diverters in accordance with NFPA 69, "Standard on
Explosion
Prevention Systems"
(e) Flame front extinguishing systems in accordance with NFPA 69, "Standard
on Explosion Prevention Systems"
d) The Littleford mixer was not dust-tight. Specifically, it leaked dust
around the shaft to the
right chopper.  This is not in accordance with NFPA 654, Section 3-6,
"Mixers and Blenders,"
which states in relevant part:
3-6.1 Mixers and blenders shall be dust-tight.
e) The dust collector is inside the building, in the same room as the
Littleford mixer.  This is
not in accordance with NFPA 654, Section 4-1, "Dust Collection," which
states
in relevant part:
4-1.2 Dust collectors shall be located outside of buildings.
This requirement does not apply to dust collectors equipped with one of
the following methods
of protection: oxidant concentration reduction, deflagration pressure
containment, deflagration
suppression systems, in accordance with NFPA 69, "Standard on Explosion
Prevention
Systems," or dilution with a noncombustible dust to render the mixture
noncombustible.  It also
does not apply to dust collector located within 20 feet of an exterior
wall and equipped with
deflagration vents vented through ducts to the outside.
f) The Littleford mixer was not maintained in a manner that minimized the
escape of dust.
Specifically, the sealing to the right chopper was not repaired to prevent
dust from escaping
around the shaft.  This is not in accordance with NFPA 654, Section 4-2,
"Housekeeping,"
which states in relevant part:
4-2.1 Equipment shall be maintained and operated in a manner that
minimizes the escape
of dust.g) Operating and maintenance procedures for the Littleford mixer
and emergency plans for
employees operating the Littleford mixer had not been reviewed annually.
This is not in
accordance with NFPA 654, Section 7-1, "Employee Training," which states
in relevant part:
7-1.1 Operating and maintenance procedures and emergency plans shall be
developed.
These shall be reviewed annually, and as required by process changes.
h) The Littleford mixer was not tested and maintained to ensure that it
was operating as
designed.  This is not in accordance with NFPA 654, Section 8-1,
"Inspection and
Maintenance," which states in relevant part:
8-1.1 An inspection, testing and maintenance program shall be implemented
that ensures
that the fire and explosion protection systems and related process
controls
and equipment
perform as designed, and that a change in process equipment does not
increase the
hazard.
Note: Feasible and acceptable abatement methods include but are not
limited to:
1) Place the Littleford mixer that processes Celogen OT in a room without
other operations, with
doorways that are sealed to be dust-tight, and walls of a fire-resistance
rating of at least one-half
hour and capable of withstanding the maximum possible pressure that could
be generated by a
deflagration;
2) Extend the explosion relief venting to discharge above the roof;
3) Place the controls that operate the Littleford mixer outside the room
and create mechanisms
for the remote addition of materials such as oil that are added after the
blending begins;
4) Add explosion suppression systems in the duct collection ductwork and
in the dust collector;
5) Move the dust collector to the outside of the building;
6) Inspect and maintain the Littleford mixer so that it is dust-tight,
operates as designed, and so
that excess heat is not generated;
7) Put revised operating and maintenance procedures in writing, and review
them annually or
whenever the mixing process is changed;
8) Improve the training of operators, assistants, maintenance employees
and supervisors to
ensure that they understand the procedures as written, the explosion
prevention and suppression
systems, emergency procedures, and the explosion potential of Celogen OT.

Issued

Nov 1, 2000

Abate by

Nov 6, 2000

Issued

Nov 1, 2000

Abate by

Nov 6, 2000

Issued

Nov 1, 2000

Abate by

May 1, 2001