OSHA Inspection: PRAXIS NORTHEAST

Issued

2008-09-23 00:00:00

Abate by

2009-08-15 00:00:00

Penalty

Initial $3000.00 · Current $2100.00 Reduced

General-duty citation text

7.13.1.5 and 7.1.4 - Where an explosion hazard exists, isolation devices
shall be
provided for air-material separators.
ABATEMENT NOTE:
Among other methods, feasible and acceptable means to correct the
conditions noted in Instance
D.) include but are not limited to:
Install approved deflagration devices, isolation devices, and explosion
protection systems
Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
in the air returns from the dust collection systems in accordance with the
PHA/Process
Risk Assessment and the requirements noted in NFPA 654.
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 employees
were exposed to:
A.) Praxis Northeast, Production Areas - Employees were potentially
exposed to dust
explosion hazards and severe burn injuries because an evaluation was not
conducted to determine
whether the hazards necessitated the installation of approved devices to
prevent, mitigate, and/or
control the hazards associated with the propagation of dust explosions,
deflagrations, and flame
fronts through the production areas, plant equipment, machinery, air
systems, and related duct
work:
1.) In production areas that included but were not limited to, the mix /
molding room, fiberglass
spray area, Walk-in Grind Room, Multi-piece Room, Drill Grind Area, Flange
Grind
Area, and
Skirt Saw Area, a Process Hazard Analysis (PHA) and Process Risk
Assessment were not
conducted to determine whether the 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 the
propagation of deflagrations, explosions, and flame fronts through
equipment, machinery, and
air systems.  The equipment, machinery, and systems included but were not
limited to dust
collection systems for the Walk In Grind Room, Flange Grind Area, Skirt
Saw Area, and the
ductwork associated with the systems.
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:
4.2.1 - The design of the fire and explosion safety provisions shall be
based on a process
hazard analysis of the facility, the process, and the associated fire or
explosion hazards.
4.2.2 - The results of the process hazard analysis shall 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.
ABATEMENT NOTE:
Among other methods, feasible and acceptable means to correct the
conditions
noted in Instance
A.) include but are not limited to:
Complying with applicable requirements noted in NFPA 654 Standard for the
Prevention of Fire and Dust Explosions from the Manufacturing, Processing,
and
Handling of Combustible Particulate Solids by conducting a PHA and Process
Risk
Assessment.
B.) Praxis Northeast, Production Areas - Employees were potentially
exposed to dust
explosion hazards and severe 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
ductwork:
1.) Air-material separators (e.g. dust collection systems) were located
inside the building and
were not protected by explosion protection systems and isolation devices.
These units included
but were not limited to the DCE Unimaster, Murphy-Rodgers, and Hoffman
dust collection
systems.
NFPA 654 Standard for the Prevention of Fire and Dust Explosions from the
Manufacturing, Processing, and Handling of Combustible Particulate Solids
states:
7.13.1.1.1 - Where an explosion hazard exists, air-material separators
shall be located
outside of buildings (unless the requirements of 7.13.1.1.2 are met).
7.13.1.5 and 7.1.4 - Where an explosion hazard exists, isolation devices
shall be
provided for air-material separators.
ABATEMENT NOTE:
Among other methods, feasible and acceptable means to correct the
conditions noted in Instance
B.) include but are not limited to:
Relocating the air-material separators outside the building or complying
with the
requirements set forth in NFPA 654 Section 7.13.1.1.2.
Install approved deflagration devices, isolation devices, and explosion
protection systems
in accordance with the PHA/Process Risk Assessment and the requirements
noted in
NFPA 654.
C.) Praxis Northeast, Murphy-Rodgers and Hoffman units' dust storage /
accumulation
containers - Employees were potentially exposed to dust explosion hazards
and severe burn
injuries because approved containers were not utilized to collect the dust
which was periodically
emptied from the air-material separators.
1.) An open top fiberglass tub and an open top tilt-hopper were used to
collect the dust which
was periodically emptied from the Hoffman and Murphy-Rodgers dust
collection
systems.  The
presence of the explosive dust in open top containers could potentially
increase the severity of
fires, explosions, and associated burn injuries in the event that a dust
explosion and/or
deflagration occurred in the facility.
NFPA 654 Standard for the Prevention of Fire and Dust Explosions from the
Manufacturing, Processing, and Handling of Combustible Particulate Solids
states:
7.2.2 - Bulk storage containers, whether located inside or outside of
buildings, shall be
constructed so as not to represent an increase in the fire load beyond the
capabilities of
the existing fire protection.
7.2.3.2.1 - Where an explosion hazard exists, fixed bulk storage
containers shall be
located outside of buildings (unless the requirements of 7.2.3.2.2 are met)
ABATEMENT NOTE:
Among other methods, feasible and acceptable means to correct the
conditions noted in Instance
C.) include but are not limited to:
Obtain and install approved bulk storage enclosures and install approved
deflagration
devices, isolation devices, and explosion protection systems in accordance
with the
PHA/Process Risk Assessment and the requirements noted in NFPA 654.
Complying with the requirements contained in Section 7.2, Bulk Storage
Enclosures, of
NFPA 654.
D.) Praxis Northeast, dust collection systems - Employees were potentially
exposed to dust
explosion hazards and severe burn injuries because approved devices were
not installed to
prevent, mitigate, and/or control the hazards associated with the
transmission of energy from
a fire or explosion in the air-material separators back into the building
through
the air recycle
/ return ductwork:
1.) The air from the DCE Unimaster, Murphy-Rodgers, and Hoffman dust
collection systems
was recycled / returned to the building without approved devices to
prevent the transmission of
energy from a fire/explosion back into the building.  In the event of a
dust explosion in the dust
collection systems, the explosion, deflagration, and/or flame front could
potentially propagate
through the recycle / return ductwork and into areas of the building
occupied by Company
employees.
NFPA 654 Standard for the Prevention of Fire and Dust Explosions from the
Manufacturing, Processing, and Handling of Combustible Particulate Solids
states:
6.1.3 - Recycling of air-material separator exhaust to buildings shall be
permitted if the
system is designed to prevent both return of dust with an efficiency of
99.9 percent at
10 um and the transmission of energy from a fire or explosion to the
building.

Issued

2008-09-23 00:00:00

Abate by

2008-11-13 00:00:00

Penalty

Initial $1125.00 · Current $790.00 Reduced

Issued

2008-09-23 00:00:00

Abate by

2008-11-13 00:00:00

Issued

2008-09-23 00:00:00

Abate by

2008-11-13 00:00:00

Issued

2008-09-23 00:00:00

Abate by

2008-09-26 00:00:00

Penalty

Initial $900.00 · Current $630.00 Reduced

Issued

2008-09-23 00:00:00

Abate by

2009-08-15 00:00:00

Penalty

Initial $1125.00 · Current $785.00 Reduced

Hazardous substances 9130

Issued

2008-09-23 00:00:00

Abate by

2009-08-15 00:00:00

Hazardous substances 9130