OSHA Inspection: HARTE-HANKS FLYER, INC

Issued

Apr 18, 2012

Abate by

May 21, 2012

Penalty

Initial $4,250 · Current $2,125 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
are likely to cause burns, serious injury or death in that employees are
exposed to fire and
explosion hazards associated with the paper dust collection system:
For the AGET Filterkop baghouse and cyclone present in the bailing area as
part
of the paper scrap and dust collection system, as observed on 04/09/2012.
The
paper dust was analyzed to be combustible/explosive with a Kst of 31.68
bar*m/s
and a pressure ratio of 8.31.  The following deficiencies were noted with
the
collection system:
a) There was no explosion protection or fire protection system for
either the cyclone or the baghouse to protect employees in the
event of a dust explosion or fire.  The cyclone and baghouse were
located inside the building at the bailer area where employees
accessed and worked daily.
b)There was no fire and/or explosion isolation system for the
cyclone and baghouse to ensure that in the event of a fire or
explosion, flames or other hazardous energy could not be
propagated back into the building through the exhaust stream, or
back up the duct work.
c)Grounding and bonding were not in place to dissipate the buildup
of static potential/electricity, a potential ignition source, by
ensuring that the entire collection system was electrically
conductive and grounded. This was due to the presence of non-
grounded flexible ducts which were in place to convey dusty air
between the cyclone and the baghouse, non-conductive/non-
grounded plastic PVC ducts for the inlet dusty air stream that
connected to the cyclone, and broken duct work joints in many
sections on the metal pneumatic conveying ducts. The joints were
taped together with duct tape, but no metallic jumper wire was
installed to ensure that continuity and an adequate ground was
achieved.
d)Sources of paper dust had not been practically eliminated resulting
in accumulations of paper dust on the bailer, on some electrical
equipment, and on the ground.  The motor for the exhaust system
did not have sufficient capacity to eliminate the back pressure
associated with poor suction from the fan between the cyclone and
the baghouse.  This prevented the dust from being properly
exhausted, as well as created jams in the compactor resulting in
dust emission from the process.
e)Compressed air was used to blow off the dust from the bailer and
the floor around the bailer. This practice resulted in combustible
paper dust clouds that could potentially form a
flammable/explosive concentration.
ABATEMENT NOTE: Among other methods, one feasible and acceptable
method to correct these hazards include complying with the National Fire
Protection Agency NFPA 654 "Standard for the Prevention of Fire and Dust
Explosions from the Manufacturing, Processing, and Handling of Combustible
Particulate Solids 2006 Edition" NFPA 68 "Standard on Explosion Protection
by
Deflagration Venting" and NFPA 69 "Standard on Explosion Prevention Systems
2008 edition", which includes, but may not be limited to:
a)Install explosion relief venting on the cyclone and baghouse vented
to the outside and capable of directing fire and explosion energy
outside to an unoccupied area as specified in NFPA 654 and
NFPA 68.
b)Route the exhaust air from the baghouse outside through duct
capable of also transmitting any fire/explosion energy to a safe and
unoccupied area as required by NFPA 654.
c)Install fire/explosion isolation devices on the baghouse and cyclone
as specified in NFPA 654 and NFPA 68 and 69.
d)Safely exhaust the baghouse to outside and generate adequate air
flow/suction to ensure that jams do not occur in the compactor
resulting in minimized dust emission from the process as specified
in NFPA 654.
e)Comply with NFPA 654 by ensuring that all ductwork for the
pneumatic conveying paper dust/paper scraps is conductive,
grounded, and bonded to the rest of the dust collection system.
f)Comply with NFPA 654 by using a combustible dust approved
vacuum to clean up the dust or other means to avoid producing
dust clouds.