OSHA Inspection: CLARION LAMINATES, LLC

Issued

May 29, 2009

Abate by

Jul 1, 2009

Penalty

Initial $1,100 · Current $770 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. Clarion Laminates, LLC - Employees were potentially exposed to dust
explosion hazards and
burn injuries because written procedures to manage changes associated with
process materials,
technology, equipment, procedures, and facilities were not established and
implemented:
1.)  For Production areas and equipment that included but were not limited
to the Bonding
Infeed Area, Bonding Lines, Saw Lines, Intermediate Storage Warehouse,
Profile
Area, and dust
collection equipment, the Company had not developed and implemented
written Management of
Change procedures for ensuring that potential changes to production
equipment and dust control
equipment do not result in fires, dust explosions, and the propagation of
deflagrations,
explosions, and flame fronts through equipment, machinery, and air systems.
NFPA 664 Standard for the Prevention of Fires and Explosions in Wood
Processing and
Woodworking Facilities, Sections 4.3.1 through 4.3.2 and 10.7, and 10.7.2
states:
4.3.1 - The management-of-change procedures shall ensure that the
following issues are
addressed prior to any change:
(1) Technical basis for the proposed change
(2) Safety and health implications
(3) Whether the change is permanent or temporary
(4) Modifications to operating and maintenance procedures
(5) Employee training requirements
(6) Authorization requirements for the proposed change
4.3.2 - Implementation of the management-of-change procedures shall not be
required for
replacements-in-kind.
10.7 - Management shall implement and maintain a system to evaluate
proposed changes to the
facility and processes, both physical and human, for the impact on safety,
loss prevention, and
control.
10.7.2 - Management of change shall include review of all projects
involving the following:
(1) Occupancy and process changes involving storage configurations and
heights, process
equipment and materials, or rates of production
(2) Changes to all fire protection and alarm systems
(3) Exposure changes
(4) Human element changes involving key members of loss prevention programs
(5) New construction or modification to an existing structure
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 664 Standard for the
Prevention of
Fires and Explosions in Wood Processing and Woodworking Facilities by
establishing and
implementing written management of change procedures.
__________________________________
B. Clarion Laminates, LLC - Employees were potentially exposed to dust
explosion hazards and
burn injuries because a documented housekeeping and inspection program had
not been
developed and maintained:
1.)  For Production areas and equipment that included but were not limited
to the Bonding
Infeed Area, Bonding Lines, Saw Lines, Intermediate Storage Warehouse,
Profile
Area, and dust
collection equipment, the Company did not maintain a documented
housekeeping and inspection
program to prevent excessive accumulations of combustible and explosive
wood dust in order
to prevent fires, dust explosions, and the propagation of deflagrations,
explosions, and flame
fronts through equipment, machinery, and air systems.
NFPA 664 Standard for the Prevention of Fires and Explosions in Wood
Processing and
Woodworking Facilities, Sections 11.1.2 states:
11.1.2 - Documented housekeeping and inspection programs shall be
developed and maintained.
ABATEMENT NOTE:
Among other methods, feasible and acceptable means to correct the
conditions noted in Instance
B.) include but are not limited to developing a housekeeping and
inspection
program following
the guidelines outlined in Annex A of NFPA 664:
Implement a weekly housekeeping inspection in the facility's fire
prevention and maintenance
program. Cleaning schedules for production equipment and the facility in
general can be based
on the findings of the housekeeping inspection. Typical cleanup routines,
as a minimum, should
include the following:
(1) Daily, or per shift, cleanup of personal work areas, walkways,
emergency escape routes, and
accessways to fire protection equipment.
(2) Weekly cleanup of floors throughout the facility, and specific cleanup
in and around
materials-handling equipment or production equipment (e.g., beneath wood
sorting decks,
beneath or at the transfer points of belted chip or scrap conveyors, and
beneath board presses).Machinery, motors, and hot surfaces should be kept
clean of materials such as sawdust, oil, or
grease.
(3) Weekly to semiannual cleanup of dust collection on horizontal surfaces
(e.g., ducts, hoods,
interior mezzanines, or ceilings) and on structural building members, such
as ledges, beams, and
joists, to minimize dust accumulations. As a rule of thumb, do not exceed
3.2 mm (1/8 in.) in
depth. In all cases, consideration should be given to minimizing
horizontal surfaces where dust
can accumulate. One method of reducing horizontal surfaces on structural
building members is
to install angled members (angle of repose) or shields to minimize buildup.

Issued

May 29, 2009

Abate by

Jun 3, 2009

Penalty

Initial $825 · Current $580 Reduced