OSHA Inspection: AMERICAN AEROGEL CORPORATION

Issued

2010-02-04 00:00:00

Abate by

2010-07-19 00:00:00

Penalty

Initial $2500.00 · Current $2000.00 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:
a) On or about 12/07/2009 in the Cutting Room; smoldering Aeroblack dust (
a ST2
class dust ) in the duct work of the surface sander, propagated through
seventy five ( 75
) feet of duct work, passing through the Evacuation/Sealing and Testing
areas, to the
process dust collector (DC-1), which was located outside the building
resulting in
destructive heat damage to the inside of DC-1.
b) On or about 12/07/09 in the Cutting Room; the 462 CFM exhaust air flow
volume and
1320 FPM exhaust air velocity on the eight inch diameter duct from the
sander going to
the dust collection ( DC-1) allowed between one half to one inch of
Aeroblack
dust ( a
ST2 class dust ) to accumulate inside the duct creating a fire and
deflagration hazard.
c) On or about 12/07/09 at the dust collector for the Cutting Room; dust
collector ( DC-1
) located outside the building was subject to an internal fire without
provisions for
protection from this hazard.
d) On or about 12/07/09 in the Cutting room; compressed air and dry
sweeping was used
to clean the Cutting creating dust clouds without the shutdown or removal
of electric
equipment not suitable for Class II locations, such as but not limited to
ordinary
florescent lights without lens covers.
e) On or about 12/07/09 throughout the facility; employer did not maintain
certification
records for annual training and review of the following subjects, such as
but not limited
to, housekeeping requirements, emergency response plans, response to
process
upset
conditions, for employees who are involved in operating, maintaining, and
supervising
facilities that handle combustible particulate solids.
f) On or about 12/07/09 in the Cutting room; dust collector ( DC-1 ) and
belt sander
would start up simultaneously without any operating logic controls so that
prior to start
up or shut down, the dust collector achieved or maintained system design
velocity until
material ( combustible dust ) was purged from the system.
ABATEMENT DOCUMENTATION REQUIRED
a) Feasible and acceptable abatement methods to correct this condition
would be; install
isolation devices, such as but not limited to, chokes, rotary valves,
automatic fast actingsystems in accordance with NFPA 69, Standard on
Explosions Prevention Systems, flame
front diverters, in accordance with NFPA 69, Standard on Explosions
Prevention
Systems, chemical isolation systems in accordance with NFPA 69, Standard on
Explosions Prevention Systems, Reference NFPA 654 - 2008 Prevention of
Fire and Dust
Explosions of Combustible Particulate Solids, Section 7.1.4 Isolation of
Equipment which
states: "Where an explosion hazard exist, isolation devices shall be
provided to prevent
deflagration propagation between pieces of equipment connected by
ductwork."
b) Feasible and acceptable abatement methods to correct this condition
would be; size
ductwork to provide air volume and air velocity necessary to keep the duct
interior clean
and free of residual material  Reference NFPA 654 - 2008 Prevention of
Fire and Dust
Explosions of Combustible Particulate Solids, Section 7.3.2.4 Material
Transfer Systems
which states: "All ductwork shall be sized to provide the air volume and
air velocity
necessary to keep the duct interior clean and free of residual material."
c) Feasible and acceptable abatement methods to correct this condition
would be; install
oxidant concentration reduction in accordance with NFPA 69, Standard on
Explosions
Prevention System, in accordance with NFPA 69, Standard on Explosions
Prevention
Systems, or dilution with a noncombustible dust, or flame arresting
device, as per
reference NFPA 654 - 2008 Prevention of Fire and Dust Explosions of
Combustible
Particulate Solids, Section 7.13.1.2 which states: "Where both an
explosion hazard and
fire hazard exists in an air-material separator, provisions for protection
for each type of
hazard shall be provided."
d) Feasible and acceptable abatement methods to correct this condition
would be; vacuum
area and equipment prior to use of compressed air, electrical equipment
not
suitable for
Class II locations shall be shut down or removed, as reference in NFPA 654
- 2008
Prevention of Fire and Dust Explosions of Combustible Particulate Solids,
Section
8.2.2.2 which states: "Vigorous sweeping or blowing down with steam or
compressed
air produces dust clouds and shall be permitted only where the following
requirements
are met: (1) Area shall be vacuumed prior to blowing down, (2) Electrical
equipment not
suitable for Class II locations and other sources or ignition shall be
shut down or
removed from the area, (3) Only low pressure steam or compressed air, not
exceeding
a gauge pressure of 15 psi (103kPa) shall be used. (4)  No hot surfaces or
flames capable
of igniting a dust cloud or layer shall exist in the area.
e) Feasible and acceptable abatement methods to correct this condition
would be; conduct
initial and refresher training to employees who are involved in operating,
maintaining,
and supervising facilities that handle combustible particulate solids so
that they are
knowledgeable about the following subjects, Hazards of the workplace,
plant safety rules,
equipment operation, safe startup, response to upset conditions,
housekeeping
requirements, emergency response plans, as reference in NFPA 654 - 2008
Prevention
of Fire and Dust Explosions of Combustible Particulate Solids, Section
11.1 which states:
The requirements of Sections 11.2 ( Plan ) and 11.3 ( Initial and
Refresher Training )
shall be applied retroactively.
f) Feasible and acceptable abatement methods to correct this condition
would be;
interlock the dust collector with the belt sander and any other equipment
the dust
collector would be connected to so that prior to the start of the belt
sander or any other
dust generating equipment, the dust collector would turn on and reach
design air velocity
before allowing the dust generating equipment to start.  The same logic
would be applied
to dust generating equipment shut down, as reference in NFPA 654 - 2008
Prevention
of Fire and Dust Explosions of Combustible Particulate Solids, Section
7.3.3 Operations,
which states: "Pneumatic conveying systems shall be designed with the
operating logic,
sequencing, and timing outlined in 7.3.3.2 and 7.3.3.3.

Issued

2010-02-04 00:00:00

Abate by

2010-02-09 00:00:00

Penalty

Initial $1225.00 · Current $1000.00 Reduced

Issued

2010-02-04 00:00:00

Abate by

2010-02-09 00:00:00

Penalty

Initial $700.00 · Current $500.00 Reduced

Issued

2010-02-04 00:00:00

Abate by

2010-03-09 00:00:00

Penalty

Initial $2500.00 · Current $2000.00 Reduced

Issued

2010-02-04 00:00:00

Abate by

2010-02-09 00:00:00

Penalty

Initial $2500.00 · Current $1500.00 Reduced

Issued

2010-02-04 00:00:00

Abate by

2010-07-19 00:00:00

Penalty

Initial $2500.00 · Current $1500.00 Reduced

Issued

2010-02-04 00:00:00

Abate by

2010-03-09 00:00:00

Penalty

Initial $2500.00 · Current $1500.00 Reduced