OSHA Inspection: TUBETECH

Issued

Nov 25, 2008

Abate by

Dec 28, 2008

Penalty

Initial $1,250 · Current $1,250

Hazardous substances A110

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:
Dust containing aluminum collected from the "baffle box" of the local
exhaust ventilation system
of the re-metallizing operation on Mill #1 on August 28, 2008, was a Class
St 1 explosive dust,
indicating the potential for explosion if ignited.  The following
conditions found at the facility
increase the potential for an explosion and/or potentially increase the
severity of an explosion:
a.  The local exhaust ventilation systems for re-metallizing at Mills #1,
3 and 4 were not
electrically bonded and grounded.
b.  The local exhaust ventilation systems for re-metallizing at Mills #1,
3 and 4 were not
provided with deflagration venting.
c.  The seams on the ducts of the local exhaust ventilation systems for
re-metallizing at Mills
#1, 3, and 4 were not oriented away from the employees' usual work areas.
d.  The blades and the housings of the fans in the local exhaust
ventilation systems at Mills #1,
3, and 4 were not constructed of nonsparking metal.
e.  The "baffle boxes" at Mills #1, 3, and 4 were not provided with
barriers or other means for
the protection of employees in case of explosion.
f.  Hot work permits are not being required before hot work (welding or
cutting) is done on the
"baffle boxes" of the local exhaust ventilation systems for re-metallizing.
g.  Spark-resistant tools are not being used for repairs and adjustments
on the "baffle boxes" of
the local exhaust ventilation systems for re-metallizing.
h.  The dust removed from the "baffle boxes" during clean-out operations
is not mixed with inert
material and stored in tightly covered metal containers.
i.  The dust is not removed from the "baffle boxes" at least once a day.
Among other methods, one feasible and acceptable method to correct this
hazard is to conduct
a process hazard analysis by an individual knowledgeable about explosive
metal dusts and
comply with applicable standards issued by the National Fire Protection
Association (NFPA),
including NFPA 484, Standard for Combustible Metals, Chapter 6, "Aluminum"
and Chapter
13, "Fire Prevention, Fire Protection, and Emergency Response."