OSHA Inspection: HARDY INDUSTRIAL TECHNOLOGIES

Issued

Mar 25, 2013

Abate by

Apr 27, 2013

Penalty

Initial $7,000 · Current $7,000

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 combustible prill dust deflagration, explosion, and other fire hazards while working at or near prill processing equipment and associated dust collection system components where recognized measures to prevent employee exposure had not been implemented:    On or about October 11, 2012:    (a)Means of combustible dust explosion protection was not provided for processing equipment and fines recovery equipment such as, but not limited to:    i. prill tower and associated product and fines recovery ducting  ii. 3rd floor fines recovery cyclone #1 and associated  ducting  iii. 3rd floor fines recovery cyclone #2 and associated ducting  iv. fluid bed/sieve/hopper unit and associated product and fines recovery ducting  v. 1st floor fines recovery cyclone and associated ducting    (b)Means of combustible dust deflagration (flame front propagation) isolation protection was not provided between processing equipment and fines recovery equipment such as, but not limited to:    i. Between the prill tower and the 3rd floor recovery cyclone #1 (via the air-material inlet)  ii. Between the prill tower and the 3rd floor recovery cyclone #2 (via the air-material inlet)  iii. Between the 3rd floor recovery cyclone #1 and the downstream exhaust fan and dust collection (via the air exhaust outlet)  iv. Between the 3rd floor recovery cyclone #2 and downstream exhaust fan and dust collection (via the air exhaust outlet)  v. Between the 3rd floor recovery cyclone #1 and the downstream dust collection (via the material discharge cone)  vi. Between the 3rd floor recovery cyclone #2 and the downstream dust collection (via the material discharge cone)  vii. Between the prill tower and the fluid bed/sieve/hopper   viii. Between the fluid bed/sieve/hopper and the basement bagging station  ix. Between the fluid bed/sieve/hopper and the 1st floor fines recovery cyclone (via the  x. Between the 1st floor fines recovery cyclone and the fluid bed/sieve/hopper (via the air-material inlet)  xi. Between the 1st floor fines recovery cyclone and the downstream dust collection (via the material discharge cone)  xii. Between the 1st floor fines recovery cyclone and the downstream exhaust system (via the air exhaust outlet).    (c) Means of combustible dust fire protection (internal vessel detection and extinguishment) was not provided for processing equipment and fines recovery equipment such as, but not limited to:    i. prill tower  ii. 3rd floor fines recovery cyclone #1  iii. 3rd floor fines recovery cyclone #2  iv. 1st floor fines recovery cyclone  v. fluid bed/sieve/hopper unit    (d) The automatic sprinkler fire suppression system for the building was non-functional as the supply had been shut off at several main supply valves in the basement.    (e) The Company's hot work permit system was not followed on the day in question on the third floor of the prill tower.    (f) The employer did not provide annual training for portable fire extinguishers when available for use.    Among other methods, one feasible method to correct this hazard would be to comply with applicable and related provisions of National Fire Protection Association (NFPA) Standard 654 Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids (2013 Edition).      For equipment and vessels requiring explosion protection as recognized in NFPA 654 (2013) Sections such as, but not limited to, 6.1.7, 7.1.4.1, 7.2.3.2, 7.13.1.1, and 7.13.1.2, provide explosion protection such as through chemical deflagration suppression, deflagration venting to a safe location, or deflagration venting through a listed dust retention and flame arresting device.  Refer to the current versions of NFPA 68 and 69 for additional guidance as applicable.    For interconnected equipment and vessels requiring deflagration propagation isolation as recognized in NFPA 654 (2013) Sections such as, but not limited to, 7.1.6, 7.1.7, 7.13.1.4, provide either an active method of isolation such as chemical isolation through flame front extinguishment, a fast-acting mechanical valve, actuated float valve, or actuated pinch valve; or provide a passive method of isolation such as flame front diverters, passive float valves, material chokes (rotary valves), or back blast damper.  Refer to the current version of NFPA 69 for additional guidance as applicable.    For equipment and vessels requiring fire detection and suppression as recognized in NFPA 654 (2013) Sections such as, but not limited to, 7.1.9, 7.13.1.2.1, 7.13.1.2.3, and 10.1, provide a method of fire detection and suppression designed and maintained to an applicable standard such as NFPA 11, 12, 15, 16, 17, 25, 750, or 2001.    For building areas requiring protection by an automatic sprinkler fire suppression system as recognized in NFAP 654 (2013) Sections such as, but not limited to, 4.6.1, 4.6.4, 10.1, and 10.5.2, ensure that water is supplied to the system when a combustible dust process is in operation.  Refer to the current version of NFPA 13 for additional guidance.     For maintenance or production activities using open-flame and requiring control as recognized in   NFPA 654 (2013) Section 9.5.2, ensure strict implementation of a hot work permit system.  Refer to the current version of NFPA 51B for additional guidance.    For processes requiring a fire and explosion event evacuation plan as recognized in NFPA 654 (2013) Sections such as, but not limited to, 11.2.3, 11.2.4, 11.3.1, and 11.3.2, provide initial and refresher training so that exposed staff is knowledgeable of the establishments emergency response plan.

Issued

Mar 25, 2013

Abate by

Apr 18, 2013

Penalty

Initial $7,000 · Current $4,900 Reduced

General-duty citation text

29 CFR 1910.132(a): Protective equipment was not used when necessary whenever hazards capable of causing injury and impairment were encountered:    On or about October 11, 2012, an employee performing hot work on top of the prill tower was not using fall protection when exposed to an approximate 15 foot fall to the lower level.