OSHA Inspection: DELL MANUFACTURING COMPANY, INC.

Issued

2011-11-07 00:00:00

Abate by

2011-12-22 00:00:00

Penalty

Initial $4900.00 · Current $4900.00

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 fire and explosion hazards caused by the presence of
combustible dust:
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 combustible dust fire and
explosion hazards from
deburring, buffing and/or other finishing operations on titanium and other
metal aircraft engine
parts in the portion of the plant labeled Deburring Area:
A. A dry media type dust collector was located indoors and was used in the
Deburring Area
to collect combustible metal dust, including titanium dust.  Combustible
metal dust,
including titanium dust, was allowed to collect on the  polypropylene
filter inside the
Aercology  DM-500 dust collection unit.  This type of collector helps
create the
conditions for a titanium dust fire/explosion. During manual shake-down,
the
accumulated dust creates a dust-laden atmosphere inside the unit .
Among other methods, one feasible and acceptable abatement method to
correct this
hazard is to follow National Fire Protection Association (NFPA) Standard
484 Standard
for Combustible Metals Chapter 10, including without limitation Section
10.4.8.1 ("
Electrostatic and media type collection systems shall not be used.").
B. Combustible titanium metal dust was produced inside equipment such as
the dry type
Aercology DM-500 dust collection unit, the buffing machine, the deburring
operation,
the flexible plastic duct work, and the metal exhaust hood over the
buffing machine, all
of which handled combustible metal dust (including titanium dust).
Grounding and
bonding are required to help prevent a static electricity
buildup/discharge which could
ignite a combustible fire/explosion.
Among other methods, one feasible and acceptable abatement method to
correct this
hazard is to follow National Fire Protection Association (NFPA) Standard
484 Standard
for Combustible Metals Chapter 10, including without limitation Section
10.4.4.2
(Connecting ducts shall be completely bonded and grounded.) and Section
10.4.8.7.5
("All equipment shall be bonded and grounded.").
C. The buffing machine and the deburring operation were not interlocked
with the dust
collector to ensure that the dust collector was on and properly
functioning before buffing
or deburring operations commenced. Also, a time delay switch or equivalent
device was
not provided on the dust collector to prevent buffing and deburring from
starting until
the dust collector was in full operation.  These practices permitted
release of excess
amounts of fugitive combustible metal dust (including titanium dust),
increasing the
probability of a combustible dust fire/explosion.
Among other methods, one feasible and acceptable abatement method to
correct this
hazard is to follow National Fire Protection Association (NFPA) Standard
484 Standard
for Combustible Metals, Chapter 10, including without limitation  Section
10.4.4.6.1
(The power supply to the dust-producing equipment shall be interlocked
with the airflow
from the exhaust blower so that improper functioning of the dust
collection system willshut down the equipment it serves.) and Section
10.4.4.6.2 ("A time delay switch or
equivalent device shall be provided on the dust-producing equipment to
prevent starting
of its motor device until the collector is in complete operation.")
D. The dust collection system was not designed to minimize the
accumulation of combustible
metal dust (including titanium dust) within its duct work. The flexible
plastic, non-
conductive duct hose was not as short and straight as possible and did not
have a smooth
internal surface.  Accumulation of combustible metal dust in collector
ductwork increases
the probability of a dust fire/explosion.
Among other methods, one feasible and acceptable abatement method to
correct this
hazard is to follow National Fire Protection Association (NFPA) Standard
484 Standard
for Combustible Metals, Chapter 10, including without limitation Section
10.4.6.4
(Ducts
shall be as short as possible and have as few bends and irregularities as
possible.) and
Section 10.4.6.5.1 (Ducts shall be constructed of conductive material and
assembled with
smooth internal surfaces.).
E. Incompatible metal dusts (including combustible titanium dust) from the
buffing and
deburring operations were collected together in the Aercology DM 500 dust
collection
unit. This allowed the incompatible dusts to accumulate and co-mingle
inside the
collector, which increased fire/explosions hazards.
Among other methods, one feasible and acceptable abatement method to
correct this
hazard is to create an appropriate cleaning schedule for the dust
collection unit and to
follow National Fire Protection Association (NFPA) Standard 484 Standard
for
Combustible Metals, Chapter 10, including without limitation Section
10.4.4.4 (If the
titanium dust collecting unit is to be used for other material, it shall
be
thoroughly
cleaned of all incompatible materials prior to and after use.) and Section
10.4.8.6 ("Dust
shall be removed from the dry collector at the end of each work day or
more frequent.").
Specific Abatement Documentation Is Requiedtation

Issued

2011-11-07 00:00:00

Abate by

2011-12-22 00:00:00

Issued

2011-11-07 00:00:00

Abate by

2011-12-22 00:00:00

Issued

2011-11-07 00:00:00

Abate by

2011-12-22 00:00:00

Penalty

Initial $2380.00 · Current $400.00 Reduced

Issued

2011-11-07 00:00:00

Abate by

2012-03-30 00:00:00

Penalty

Initial $2380.00 · Current $2380.00

Issued

2011-11-07 00:00:00

Abate by

2011-12-22 00:00:00

Issued

2011-11-07 00:00:00

Abate by

2011-12-22 00:00:00

Issued

2011-11-07 00:00:00

Abate by

2011-12-22 00:00:00

Issued

2011-11-07 00:00:00

Abate by

2011-12-22 00:00:00