OSHA Inspection: REGENEX CORPORATION

Issued

May 4, 2006

Abate by

Nov 1, 2006

Penalty

Initial $875 · Current $438 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employmnent 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:
A.) REGENEX Corporation/Resale Process Systems & In House Process Systems:
Employees were potentially exposed to dust explosion hazards and related
burn injuries
because an evaluation was not conducted to determine whether hazards
necessitated the
installation of approved devices to prevent, mitigate, and/or control
hazards associated
with the propagation of dust explosions, deflagrations, and flame fronts
through plant
equipment, machinery, air systems, and related duct work:
(1) In Both the Resale and In House Departments, a Process Hazard Analysis
(PHA) and Process Risk Assessment were not conducted to determine whether
process hazards necessitated the installation of approved devices such as
explosion
protection systems, interlocked rotary valves,deflagration vents,
automatic
fast
acting valve systems, flame front diverters, and chemical isolation
systems to
prevent, mitigate, and/or control dust explosion hazards and the hazards
associated with propagation of deflagrations, explosions, and flame fronts
through
equipment, machinery, air systems, and conveying systems.  The equipment,
machinery, and systems included but were not limited to the grinders,
Cumberland grinder, RETEC, cyclones, dust collection system & bag units,
duct
work associated with the dust collection systems and air systems, air
movement
devices (e.g. fans/blowers), and the sorter.
NFPA 654 - Standard for the Prevention of Fire and Dust Explosions from the
Manufacturing, Processing, and Handling of Combustible Particulate Solids-
Sections 4.2.1 through 4.2.3 and 7.1 through 7.1.1 states the following:
4.2.1 - The design of explosion safety provisions shall be based on a
process
hazard analysis of the facility, the process, and associated fire or
explosion
hazards.
4.2.2 - The results of the Process Hazard Analysis will be documented and
maintained for the life of the process.
4.2.3 - The process hazard analysis shall be reviewed and updated at least
every
5 years.
7.1 - Methods of explosion protection for specific equipment.
7.1.1 - A documented risk evaluation acceptable to the authority having
jurisdiction shall be permitted to be conducted to determine the level of
protection
to be provided.
B.) REGENEX Corporation/Resale Process Systems & In House Process Systems:
Employees were potentially exposed to dust explosion hazards and related
burn injuries
because approved devices were not installed to prevent, mitigate, and/or
control the
hazards associated with the propagation of dust explosions, deflagrations,
and flame
fronts through plant equipment, machinery, air systems, and related duct
work.  In both
the Resale and In-house Departments:
(1) Air material separators (e.g. dust collection systems & bag
units/cyclones)
were located inside the building and were not protected by explosion
protection
systems and isolation devices.
NFPA 654 - Standard for the Prevention of Fire and Dust Explosions from the
Manufacturing, Processing, and Handling of Combustible Particulate Solids-
Section 7.13.1.1.1 states where an explosion hazard exists air material
separators
shall be located outside of buildings (Exception: Section 7.13.1.1.2(1)
Unless the
air material separator is protected by an explosion protection system)
Section 7.13.1.5 & 7.1.4 - Where an explosion hazard exists, isolation
devices
shall be provided for air material separators.
(2) Deflagration isolation devices were not installed between
interconnected pieces
of equipment
NFPA 654 - Standard for the Prevention of Fire and Dust Explosions from the
Manufacturing, Processing, and Handling of Combustible Particulate Solids:
Section 7.1.4.1 states where an explosion hazard exists, isolation devices
shall be
provided to prevent deflagration propagation between pieces of equipment
connected by duct work.
(3) Grinders in the In-house Department and the  Cumberland Grinder and
RETEC in the Resale Department were not equipped with an explosion
protection
system.
NFPA 654 - Standard for the Prevention of Fire and Dust Explosions from the
Manufacturing, Processing, and Handling of Combustible Particulate Solids:
Section A7.15 - Size reduction machinery includes equipment such as mills,
grinders, and pulverizers.
Section 7.15.2 & 7.1.2 states where an explosion hazard exists, an
explosion
protection system shall be provided on size reduction machinery
ABATEMENT NOTE:
Among other methods, feasible and acceptable means to correct the
conditions noted in
Instances A and B above include:
(1) Instance A = Complying with the applicable requirements noted in NFPA
654 -
Standard for the Prevent of Fire and Dust Explosions from the
Manufacturing,
Processing, and Handling of Combustible Particulate Solids- by conducting
a PHA &Process Risk Assessment.  The PHA/Process Risk Assessment must be
documented and
kept on file.
(2) Instance B/Air-Material Separators = Relocate the air material
separators (e.g.
cyclones, dust collection systems & bag units to the exterior of the
building.  And/or,
install approved deflagration devices, isolation devices, and explosion
protection systems
in in accordance with the PHA/Risk Assessment and the requirements noted
in NFPA
654.
(3) Instance B/Deflagration Isolation Devices, Grinders, and RETEC =
Install
approved deflagration devices, isolation devices, and explosion protection
systems in
accordance with the PHA/Risk Assessment and the requirements noted in NFPA
654.
C.) REGENEX Corporation/Resale Department/West Wall By Exit Door/Gas Fired
Heater Suspended Above the Floor:  Employees were potentially exposed to
dust
explosion hazards and related burn injuries from potential ignition
sources which included
but were not limited to gas fired heaters that were located in a process
area/environment
that generated and transported explosive plastic dust.  In the Resale
Department, the gas
fired heater was located in the same area as the Resale process line and
its related
equipment which generated/transported explosive plastic dust.
NFPA 654 - Standard for the Prevent of Fire and Dust Explosions from the
Manufacturing, Processing, and Handling of Combustible Particulate Solids-
Sections 9.6.1 through 9.6.3 states the following: 9.6.1 In areas
processing
combustible
dusts, process and comfort heat shall be provided by indirect means.
9.6.2 Fired
equipment shall be located outdoors on in a separate dust-free room or
building 9.6.3 Air
for combustion shall be taken from a clean outside source 9.6.4 Comfort
air systems for
processing areas contain combustible dusts shall not be recirculated.
ABATEMENT NOTE:
Among other methods, feasible and acceptable means to correct the
conditions noted with
the gas fired heater include:
(1) Complying with the applicable requirements noted in NFPA 654 -
Standard for the
Prevent of Fire and Dust Explosions from the Manufacturing, Processing,
and Handling
of Combustible Particulate Solids- Sections 9.6.1 through 9.6.6
(2) Relocate the gas fired heater to a separate dust free room, area,  or
building and
transfer the heat via indirect means through the duct work.

Issued

May 4, 2006

Abate by

Nov 1, 2006

Penalty

Initial $875 · Current $437 Reduced

Issued

May 4, 2006

Abate by

Nov 1, 2006

Issued

May 4, 2006

Abate by

Jul 13, 2006

Penalty

Initial $700 · Current $300 Reduced

Issued

May 4, 2006

Abate by

Jul 13, 2006

Issued

May 4, 2006

Abate by

Jul 13, 2006

Penalty

Initial $700 · Current $300 Reduced

Issued

May 4, 2006

Abate by

Jul 13, 2006

Issued

May 4, 2006

Abate by

Jul 13, 2006

Penalty

Initial $700 · Current $300 Reduced

Issued

May 4, 2006

Abate by

Jul 13, 2006

Issued

May 4, 2006

Abate by

May 9, 2006

Penalty

Initial $446 · Current $223 Reduced

Issued

May 4, 2006

Abate by

May 9, 2006

Issued

May 4, 2006

Abate by

May 9, 2006

Penalty

Initial $446 · Current $223 Reduced

Issued

May 4, 2006

Abate by

Jul 13, 2006

Penalty

Initial $525 · Current $413 Reduced

Issued

May 4, 2006

Abate by

Jul 13, 2006

Issued

May 4, 2006

Abate by

Jul 13, 2006

Penalty

Initial $875 · Current $437 Reduced

Issued

May 4, 2006

Abate by

Jul 6, 2006