OSHA Inspection: NEW ENGLAND WOOD PELLET, LLC

Issued

Dec 10, 2012

Abate by

Jan 12, 2013

Penalty

Initial $5,390 · Current $4,120 Reduced

General-duty citation text

29 CFR 1910.22(a)(1): All places of employment were not kept clean and orderly:      a) KD (kiln dried wood) Receiving Area, on or about 8/22/12:  In the KD building, wood dust emissions from the scalper and conveyor operation was allowed to accumulate to depths and over surface areas in quantities that exposed workers to fire and/or explosion hazards.

Issued

Dec 10, 2012

Abate by

Jan 12, 2013

Penalty

Initial $2,310 · Current $1,765 Reduced

General-duty citation text

29 CFR 1910.134(c): The employer did not develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use:        a)  New England Wood Pellet, LLC, Schuyler, NY, on or about 8/22/12:  Employer had not established a written respiratory protection program when employees were voluntarily wearing North half-mask tight fitting respirators.

Issued

Dec 10, 2012

Abate by

Jan 12, 2013

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.134(e)(1): The employer did not provide a medical evaluation to determine the employee���s ability to use a respirator, before the employee was fit tested or required to use the respirator in the workplace:      a)  New England Wood Pellet, LLC, Schuyler, NY, on or about 8/22/12:  Employees who were voluntarily wearing North half-mask tight fitting respirators were not provided with a medical evaluation prior to use to determine their ability to wear a respirator.

Issued

Dec 10, 2012

Abate by

Dec 28, 2012

Penalty

Initial $3,850 · Current $2,940 Reduced

General-duty citation text

29 CFR 1910.146(c)(5)(ii)(C): Before an employee entered a space, the internal atmosphere was not tested with a calibrated direct-reading instrument for oxygen, flammable gases and vapors and potential toxic air contaminants:      a)  New England Wood Pellet, LLC, Schuyler, NY, on or about 8/22/12:  Employees have entered into permit-required confined spaces without prior testing of the atmoshphere for oxygen, gases and vapors and potential toxic air contaminants.

Issued

Dec 10, 2012

Penalty

Initial $2,310 · Current $1,765 Reduced

General-duty citation text

29 CFR 1910.212(a)(1): One or more methods of machine guarding was not provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks:    a)  Maintenance, on or about 8/22/12:  Grizzly drill press was not provided with a chuck guard.

Issued

Dec 10, 2012

Abate by

Jan 12, 2013

Penalty

Initial $3,850 · Current $2,940 Reduced

General-duty citation text

29 CFR 1910.307(b):  Documentation for areas designated as hazardous (classified) locations under the Class and Zone system and areas designated under the Class and Division system established after August 13, 2007 was not available to those authorized to design, install, inspect, maintain, or operate electric equipment at the location:      a)  New England Wood Pellet, Schuyler Facility, on or about 9/18/2012:  The Employer was unable to produce electrical classification drawings of the facility which are required to be available to those authorzied to design, install, inspect, maintain, or operate electric equipment in hazardous locations.

Issued

Dec 10, 2012

Abate by

Jul 1, 2013

Penalty

Initial $10,780 · Current $8,235 Reduced

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1): 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 wood dust explosions, deflagrations, and fire hazards due to deficient design and/or implementation of preventive and/or protective measures in its wood pellet processing system and related equipment, such as the following:      A) KD (kiln dried wood) Recieving Area, on or about 9/18/2012:   KD wood dust conveyed and scalped in this operation generates wood dust emissions which are not adequately captured by the existing dust collection system.      Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:    Section 11.1.2.1 of 2012 NFPA 664 requires that continuous suction to capture and contain fugitive dust  shall be provided.  Section 11.1.2.2 of 2012 NFPA 664 requires that the captured dust shall be conveyed to one or more dust collectors.      Feasible abatement would include providing local exhaust ventilation with sufficient capacity to capture the generated dust at the scalper and conveyors.          B) KD (kiln dried wood) Recieving Area, on or about 9/18/12:  The KD Receiving dust collector was not provided with an isolation device from the silo number 1 and 2 infeed conveyor.      Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:     Section 8.2.4.1 of 2012 NFPA 664 requires that conveying systems with fire and deflagration hazards shall be isolated to prevent propagation of fire and deflagration both upstream and downstream critical process equipment.       Feasible isolation devices include rated rotary feeders, high-speed actuated slide gates, pant leg gates, suppression, etc.          C)  Dry Hammer Mill, on or about 9/18/12:  Isolation devices were not provided at the connecting path between the following components to prevent or mediate the transmission of a flame front or deflagration between them:    1.  The infeed conveyor from silos to oscillating screener;  2.  The oscillating screener from the hammer mill;  3.  The hammer mill plenum from the dust collector;  4.  The hammer mill plenum from the screw auger;  5.  The screw auger from the distribution bin.     Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:    Section 8.2.4.1 of 2012 NFPA 664 requires that conveying systems with fire and deflagration hazards shall be isolated to prevent propagation of fire and deflagration both upstream and downstream critical process equipment.    Feasible isolation devices include but are not limited to, rated rotary feeder valves, high-speed actuated slide gates, pant leg gates, material chokes, suppression, etc.          D) Dry Hammer Mill, on or about 9/18/12:  The make-up air duct to the dry hammer mill was not designed, constructed and installed to contain deflagration.    Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:    Section 8.2.2.2.3 of 2012 NFPA 664 requires that ducts with deflagration hazards (potential bursting) shall be designed, constructed and installed so that:    a. Duct is strong enough to contain deflagration  b. Provided with deflagration suppression  c. Provided with relief vents ducted to the outdoors  d. Provided with relief vents thru flame quenching devices    As immediate mitigation the employer sealed the make-up air openings to the dry hammer mill. Feasible and permanent abatement might include high-speed actuated slide gates, suppression, stronger duct to contain and convey deflagration outdoors, stronger duct vented to a flame-quenching device.        E)  Rotary Dryer, on or about 9/18/12:  The Rotary Dryer which had deflagration hazards was located inside the building where there were no effective methods to prevent employees from being exposed to serious injury or death from explosion and fire.      Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:    Section 8.6.2 of 2012 NFPA 664 offers strict guidance that rotary dryers shall be located outdoors or in a separate detached building or in a separate cutoff room with damage-limiting construction.    Feasible abatement for the dryer includes:    a. Relocating the dryer outside or to a separate detached building. Modifying the existing structure to create a cutoff room with damage-limiting construction would also satisfy code intent.    b. Shutdown of the dryer if embers are detected by a secondary fail-safe detector between the dryer and the cyclones.    c. Isolation of dryer outfeed if embers are detected by a secondary fail-safe detector between the dryer and the cyclones.    d. Stop material infeed to the dryer if embers are detected by a secondary fail-safe detector between the dryer and the cyclones.    e. Shut off dryer heat sources if embers are detected by a secondary fail-safe detector between the dryer and the cyclones.         F)  Rotary Dryer, on or about 9/18/12:  The Rotary Dryer is operating without an extinguishing system located between the dryer drum and the six downstream cyclones.       Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:    Section 8.6.2.2 of 2012 NFPA 664 requires that rotary dryers have automatic spark detection (existing FireFly Detector) and extinguishing systems located between the dryer drum and downstream material-handling.     Feasible abatement should follow the guidance in the 2012 NFPA 664 Appendix 8.6.2.2. which recommends:    a. Spark detection and extinguishing systems (e.g., water deluge spray) on the duct between the dryer and the cyclone.  b. Provide a second fail-safe detection point on the duct downstream of the extinguishing system and upstream of the cyclones to:    i. Isolate dryer cyclone outfeed  ii. Stop material infeed to the dryer  iii. Initiate water deluge in the dryer        G)  Cyclones downstream of Rotary Dryer, on or about 9/18/12:  There are six cyclones operating without an automatic water spray deluge interlocked to a second fail-safe detection point on the duct downstream of the extinguishing system and upstream of the cyclones.    Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:    Section 8.6.2.2 of 2012 NFPA 664 requires that rotary dryers have automatic spark detection (existing FireFly Detector) and extinguishing systems located between the dryer drum and downstream material-handling.       Feasible abatement should follow the guidance in the 2012 NFPA 664 Appendix 8.6.2.2. which recommends:      a. Spark detection and extinguishing systems (e.g., water deluge spray) on the duct between the dryer and the cyclone.  b. Provide a second fail-safe detection point on the duct downstream of the extinguishing system and upstream of the cyclones to:    i. Isolate dryer cyclone outfeed  ii. Stop material infeed to the dryer  iii. Initiate water deluge in the dryer          H)  Cyclones downstream of Rotary Dryer, on or about 9/18/12:  The cyclone plenum explosion vent discharges into the building rather than to outdoors.  The building is not designed for the overpressure that would be introduced from a deflagration and fire event.      Among other methods, one feasible and acceptable abatement method to correct this hazard is to comply with relevant provisions in NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, such as:     Section 8.2.2.5.1.4 of the 2012 NFPA 66428 specifies that indoor dust collectors (e.g. cyclones per definition 3.3.10 of 2012 NFPA 664) must be vented to a safe area outdoors.    Section 6.4.2.1 of the 2012 NFPA 664 which requires that a facility which may be subjected to a damaging overpressure event (e.g., relief of cyclone vent) should be constructed to relieve the deflagration pressure.     Feasible abatement would include the installation of wall or roof pressure relief panels.         NEW ENGLAND WOOD PELLET, LLC. WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD, SECTION 5(a)(1) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 311584213, CITATION NUMBER 2, ITEM NUMBER 1, ISSUED ON JULY 22, 2008, WITH RESPECT TO A WORKPLACE LOCATED AT  141 OLD SHARON ROAD, JAFFREY, NEW HAMPSHIRE, 03452. THE FINAL ORDER DATE FOR THE CITATION WAS ON AUGUST 5, 2008 UPON SIGNING AN INFORMAL SETTLEMENT AGREEMENT.

Issued

Dec 10, 2012

Abate by

Jan 12, 2013

Penalty

Initial $10,780 · Current $8,235 Reduced

General-duty citation text

29 CFR 1910.307(c):  Equipment, wiring methods, and installations of equipment in hazardous (classified) locations were not intrinsically safe, approved for the hazardous (classified) location, or safe for the hazardous (classified) location:      a) KD (kiln dried wood) Receiving Area, on or about 9/18/12:  The KD Receiving Area is a Class II Division 2 hazardous environment.  The lighting and some wire ways in this area were not rated for CLass II, Division 2 hazardous location.         NEW ENGLAND WOOD PELLET, LLC. WAS PREVIOUSLY CITED FOR A VIOLATION OF THIS OCCUPATIONAL SAFETY AND HEALTH STANDARD, 29 CFR 1910.307(c) WHICH WAS CONTAINED IN OSHA INSPECTION NUMBER 311584213, CITATION NUMBER 3, ITEM NUMBER 1, ISSUED ON JULY 22, 2008, WITH RESPECT TO A WORKPLACE LOCATED AT 141 OLD SHARON ROAD, JAFFREY, NEW HAMPSHIRE, 03452. THE FINAL ORDER DATE FOR THE CITATION WAS ON OR ABOUT AUGUST 5, 2008.