OSHA Inspection: AMERICAN PHOENIX, INC.

Issued

Oct 31, 2011

Abate by

Dec 31, 2015

Penalty

Initial $6,930 · Current $6,000 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 dust deflagration, explosion, or other fire hazards as the
result of working at or near
dust collection systems, which were handling combustible rubber
compounding additive dust,
not designed to prevent or minimize damage in the event of a deflagration
or other uncontrolled
fire event:
(a)Second floor; Buhler Inc. air-material separators (baghouse dust
collectors) #4,
#5/6, #7, #8, #9, #10 associated with various Banbury mixers were located
inside
the facility and were used to collect and, when needed, return excess
combustible
rubber compound additive dust to the mixers. Combustible rubber compound
additive dust contained various dry chemicals such as, but not limited to,
carbon
black, titanium dioxide, sulfur, zinc borate, kaolin, amorphous silica, and
aluminum oxide. The dust collectors did not include:
1)a method of explosion protection and;
2)a method of providing deflagration isolation to connected
equipment and ducting
(b)Fourth floor, Eastside; Penthouse Hopper air-material separator
(baghouse dust
collector) associated with various hoppers, including #200, was located
inside the
facility and handled combustible rubber compound additive dust. Combustible
rubber compound additive dust contained various dry chemicals such as, but
not
limited to, carbon black, kaolin, amorphous silica, and aluminum oxide.
The dust
collector did not include:
1)a method of explosion protection;
2)a method of providing deflagration isolation to connected
equipment and ducting and;
3)a method of fire detection and suppression
(c)Fourth floor, Westside; The Pre-Weigh air-material separator (baghouse
dust
collector) fed from the Pre-Weigh area on the second floor was located
inside the
facility and handled combustible rubber compound additive dust. Combustible
rubber compound additive dust contained various dry chemicals such as, but
not
limited to, titanium dioxide, sulfur, silica containing compounds, zinc
borate, N-t-
butyl-2-benzothiazolesulfenamide. The dust collector did not include:
1)a method of explosion protection;
2)a method of providing deflagration isolation to connected
equipment and ducting and; 3)a method of fire detection and suppression
(d)Second floor, Compounding; The air-material separator (cyclone dust
collector)
was located inside and was used to collect combustible rubber compound
additive
dust, similar to the Pre-Weigh dust collector, such as but not limited to,
zinc
borate, titanium dioxide, N-t-butyl-2-benzothiazolesulfenamide. The dust
collector
did not include:
1)a method of explosion protection;
2)a method of providing deflagration isolation to connected
equipment and ducting and;
3)a method of fire detection and suppression
(e)Roof; The air-material separators (baghouse dust collectors) #1 and #2
associated
with Banbury mixers #100 and #200 were located outside the facility. The
collectors were used to collect and, when needed, return excess combustible
rubber compound additive dust to the mixers. Combustible rubber compound
additive dust contained various dry chemicals such as, but not limited to,
carbon
black, titanium dioxide, sulfur, zinc borate, kaolin, amorphous silica, and
aluminum oxide. The dust collectors did not include:
1)a method of explosion protection and;
2)a method of providing deflagration isolation to connected
equipment and ducting
Among other methods, a feasible abatement method to correct this hazard
would be to
comply with NFPA 654: Standard for the Prevention of Fire and Dust
Explosion from
Manufacturing, Processing, and Handling of Combustible Particulate Solids,
2006
[Section 7.13 (7.13.1.1, 7.13.1.2, 7.13.1.3, 7.13.1.5); 7.16 (7.16.3);
7.1.2; and 10] in
regards to proper engineering and administrative controls to be
implemented.
Abatement Schedule
STEP 1- A combination of administrative controls shall be implemented as
an interim
protective measure until feasible engineering and administrative controls
can
be
permanently implemented.
STEP 2- A written detailed plan of abatement shall be submitted to the
Area Director
outlining a schedule for the implementation of engineering and/or
administrative
measures to control employee exposures to the hazardous condition as
referenced in this
citation. This plan shall include, at a minimum, target dates for the
following actionswhich must be consistent with the abatement dates
required by this citation: (1)
Evaluation of engineering/administrative control options; (2) Selection of
optimum
control methods and completion of design; (3) Procurement, installation
and operation
of selected control measures; and (4) Testing and acceptance or
modification/redesign of
controls; All proposed control measures shall be approved for each
particular use by a
competent certified professional engineer.
STEP 3- Abatement shall have been completed by the implementation of
feasible
engineering and administrative controls upon verification of their
effectiveness in
achieving compliance.
Date by Which Violation Must be Abated: STEP 1- 12/30/11; Date by Which
Violation
Must be Abated: STEP 2- 03/31/12; Date by Which Violation Must be Abated:
STEP
3- 06/30/12

Issued

Oct 27, 2011

Abate by

Dec 13, 2011

Penalty

Initial $6,930 · Current $4,505 Reduced

Issued

Oct 27, 2011

Abate by

Dec 13, 2013

Issued

Oct 27, 2011

Abate by

Dec 13, 2011

Issued

Oct 27, 2011

Abate by

Dec 13, 2011

Penalty

Initial $6,930 · Current $4,505 Reduced

Issued

Oct 27, 2011

Abate by

Dec 13, 2011

Penalty

Initial $4,950 · Current $3,218 Reduced

Issued

Oct 27, 2011

Abate by

Nov 30, 2011

Penalty

Initial $6,930 · Current $4,505 Reduced

Issued

Oct 27, 2011

Abate by

Dec 13, 2011

Issued

Oct 27, 2011

Abate by

Dec 13, 2011

Penalty

Initial $6,930 · Current $2,772 Reduced

Issued

Oct 27, 2011

Abate by

Dec 13, 2011

Penalty

Initial $2,970 · Current $1,485 Reduced

Issued

Oct 27, 2011

Abate by

Dec 13, 2011

Penalty

Initial $2,970 · Current $1,485 Reduced

Issued

Oct 27, 2011

Abate by

Dec 13, 2011

Penalty

Initial $2,970 · Current $1,931 Reduced