OSHA Inspection: BAY STATE PELLET COMPANY, LLC

Issued

May 8, 2014

Abate by

Sep 16, 2014

Penalty

Initial $2,800 · Current $2,500 Reduced

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1): Section 5(A)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish to each of his employees employment and a place of employment which were free from recognized hazards that were causing or were 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 absence of preventive and/or protective measures in the wood pellet processing system and related equipment, such as the following, on or about November 13, 2013:     Instance A Floor trench area in cooler room.     Fire/deflagration/explosion hazards to employees were posed by combustible dust hazards located within the floor trench areas which had no spark detection, no explosion suppression, no fire/explosion isolation and no explosion venting devices.       On November 13, 2013, an explosion occurred in the floor trench area in the cooler room, spreading fire throughout the building, causing employee injury and heavy damage to the building.       The floor trench area where the explosion occurred is a confined space that contains mechanical conveying equipment including a screw conveyor and other associated equipment that was not readily accessible for cleaning and it had multiple interior ledges with horizontal surfaces that permitted accumulations of dust.     This conveying system moves fine wood dusts from the hammer mills to a bucket elevator in the cooler room for transfer to, and storage in, bin #25.  The equipment located within the floor trench area in the cooler room was not protected by any spark/ember detection equipment, fire/explosion isolation equipment or explosion venting devices.       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:   Chapter 4 General Requirements, paragraph 4.7: Compliance Options, and selecting EITHER of the following:    (1) Performance based provisions per 4.7.2 (chapter 5)   OR   (2) Prescriptive based provisions per 4.7.3. (chapters 6 through chapter 11)   Additional Abatement Note as to the instance outlined above:    Another feasible and acceptable abatement method is to comply with NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, including without limitation Chapters 4, 6, 7, 8 and 10 ["General Requirements", "Processes, Operations, and Special Systems," "Building Construction", "Prevention of Ignition and Control of Ignition Sources" and "Human Element"], some portions of which are recited and/or quoted below:    4.3 Process Analysis;   4.4 Management of Change;   4.5 Designer & Installer Qualifications;   8.2.1 Hazard Determination for Particulate Conveying and Dust Collection Systems;   8.2.3 Mechanical Conveying Systems;          8.2.4 Conveying System Isolation;    8.4.1 and 8.4.2.1 Hazard Analysis for Particulate Size Reduction Equipment;     10.2 Inspection and Maintenance;    10.3 Record Retention; and    10.7 Management of Change       and implement the measures that follow from the steps set forth therein.      4.3  Process Analysis     4.3.1      The design of the fire and deflagration safety provisions of the facility shall be based upon an analysis of the facility, the process, and the fire or deflagration hazards encompassed by the facility and process.     4.3.2      The design of systems and facilities that handle combustible particulate solids shall address the physical and chemical properties and hazardous characteristics of the materials in the hazard area,     4.3.3      The results of the facility and process analysis shall be permanently documented.     4.3.4      The facility and process analysis shall be reviewed and the documented results revised when the process is changed in accordance with the management-of-change criteria in Section 4.4 of this standard.     4.3.5      The results of the process analysis shall he maintained for the life of the facility and process.     4.4         Management of Change. Written procedures to manage change to process materials, technology, equipment, procedures, and facilities shall be established and implemented. The requirements of 4.4.1 and 4.4.2 shall he applied retroactively.     4.4.1   The management-of-change procedures shall ensure that the following issues are addressed prior to any change:     (1) Technical basis for the proposed change   (2) Safety and health implications   (3) Whether the change is permanent or temporary   (4) Modifications to operating and maintenance procedures   (5) Employee taming requirements   (6) Authorization requirements for the proposed change     4.4.2       Implementation of the management-of-change procedures shall not be required for replacements-in-kind.     4.4.3       Design documentation, as required by Section 4.3, shall be updated to incorporate the change.     4.5          Designer and Installer Qualifications. Systems that handle combustible wood particulates shall be designed by and installed under the supervision of qualified engineers who are knowledgeable of these systems and their associated hazards.       7.15        Spontaneous Ignition     7.15.2     Wood or wood substitute particulates that are determined to have a spontaneous ignition potential shall be stored in one of the following locations:     (1)  Outside    (2)  Inside in accordance with Section 8.10    (3)  In separate buildings    (4)  In bins designed such that the particulate flow occurs in a first-in/first-out basis.           8.2          Particulate Conveying and Dust Collection Systems     8.2.1       Hazard Determination. The hazard associated with the particulate conveying system shall be determined through a hazard analysis.     8.2.1.1     The analysis of the fire and deflagration hazard shall address the moisture content and particle size distribution of the particulate comprising the process stream downstream of each point of material entry to determine whether the material is green, dry non-deflagrable, or deflagrable.     8.2.1.2     The analysis of the fire and deflagration hazard shall identify the minimum explosible concentration (MEC) for all deflagrable material.     8.2.1.3     Fire and deflagration hazards shall be deemed nonexistent where only green material is collected or conveyed and construction of the equipment handling and storing the material is all noncombustible.    8.2.1.4     A fire hazard shall be deemed to exist in the system wherever dry wood particulate is collected or conveyed or wherever components of the conveying system are constructed of combustible materials.     8.2.1.5     In addition to the fire hazard, a deflagration hazard shall also be deemed to exist where deflagrable wood dust is, or could be, suspended in air during operation at a maximum concentration above 25 percent of the MEC.     8.2.3        Mechanical Conveying Systems.  8.2.3.1     General Requirements.   8.2.3.1.1   All equipment shall be designed, installed, and operated to maintain alignment and lubrication to avoid excessive heat buildup from friction, hot bearings, and so forth.  8.2.3.1.2   All equipment shall be designed to minimize fugitive dust emissions from the equipment.  8.2.3.1.3   Dusttight ball or roller bearings shall be used wherever practicable.   8.2.3.1.4   All bearings and bushings shall be dusttight.  8.2.3.1.5   Bearings and bushings shall be located outside the equipment.    Exception: Bearings and bushings shall be permitted inside equipment where there is no practical location.  8.2.3.1.6   Shaft seals shall be provided where rotating shafts penetrate equipment walls.  8.2.3.1.7   Access hatches and removable equipment covers shall be tight fitting and securely fastened for dusttight operation.   8.2.3.2      Mechanical Conveying Equipment with a Fire Hazard.  Where provided, sprinkler protection for rubber belt and other conveyors shall be designed, installed and maintained in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems.   8.2.3.3      Mechanical Conveying Equipment with a Deflagration Hazard.  8.2.3.3.1   Enclosed conveyors with a deflagration hazard shall comply with the criteria in 8.2.2.2.3.  8.2.3.3.2   Access hatched and removable equipment covers shall be secured with fasteners capable of withstanding design deflagration pressure in accordance with 8.2.2.2.3.       8.2.4 Conveying System Isolation.     8.2.4.1     Conveying systems with fire and deflagration hazards shall be isolated to prevent propagation of fire and deflagration both upstream and downstream into occupied areas or other critical process equipment....     8.2.4.2     Isolation devices shall be listed for the use intended....    8.2.4.3     Ducts shall be isolated to prevent propagation of deflagration to other vessels.    8.2.4.4     Where provided, explosion isolation devices shall be installed, inspected, and maintained in accordance with Chapter 15 of NFPA 69, Standard on Explosion Prevention Systems.   8.4           Particulate Size Reduction Equipment.     8.4.1        Hazard Analysis and Design Criteria.    8.4.1.1     Unless the particulate size reduction equipment is strictly dedicated to handling green material or is pressurized with steam, it shall be considered a high-frequency ignition source.     8.4.1.2     The hazard associated with the particle size reduction equipment shall be based on the physical properties of particulate, including the following:     (1)  Minimum explosible concentration    (2)  Minimum ignition energy (MIE)    (3)  Particle size distribution    (4)  Moisture content as received and as tested    (5)  Maximum explosion pressure at optimum concentration    (6)  Maximum rate of pressure rise at optimum concentration    (7)  KSt (normalized rate of pressure rise) as defined in ASTM E 1226, Standard Test Method for Pressure and  Rate of Pressure Rise for Combustible Dusts    (8)  Layer ignition temperature    (9)  Dust cloud ignition temperature    (10)  Limiting oxidant concentration (LOC) to prevent ignition    (11)  Electrical resistivity    (12)  Charge relaxation time    (13)  Chargeability"       10.2         Inspection and Maintenance.     10.2.1      An inspection, testing, and maintenance program shall be developed to ensure that fire and explosion protection systems are in accordance with Chapter 9.    10.2.2      The inspection, testing, and maintenance program shall be a documented program detailing the equipment inspected, testing performed, test results formulated, and maintenance or repair requirements.     10.2.3      Process controls, equipment, and machinery shall be inspected, tested, and maintained in accordance with the manufacturer's recommended guidelines and safe practices.       10.3 Record Retention.     10.3.1      Records requiring retention shall include, but are not limited to, drawings and supporting documents relating to initial installation/purchase of equipment, routine equipment inspections, testing and repair history, fire and safety inspection or audit reports, service records, and manufacturer's data sheets.     10.3.2      Records of inspections, tests, and maintenance of fire protection equipment and components shall be retained and made available to the authority having jurisdiction upon request.     10.3.3      All records required to be kept shall be retained until their usefulness has been served or until no longer required by the applicable standard or authority having jurisdiction.     10.3.4      Records shall be maintained on-site by the owner.     10.3.5      Retained records shall indicate the procedure performed (e.g., installation, inspection, testing, training, or maintenance), the organization that performed the work, the results, and the date the work was performed.       10.7         Management of Change.   Management shall implement and maintain a system to evaluate proposed changes to the facility and processes, both physical and human, for the impact on safety, loss prevention, and control.      10.7.1      Management of change shall include review by all relevant authorities having jurisdiction.     10.7.2      Management of change shall include review of all projects involving the following:

Issued

May 8, 2014

Abate by

May 30, 2014

Penalty

Initial $2,800 · Current $2,500 Reduced

General-duty citation text

29 CFR 1910.132(f)(1)(ii): The employer did not provide training to each employee who is required by this section to use PPE on knowing what PPE is necessary:    a) In the wood pellet manufacturing plant at 22 Kimball Place Fitchburg, MA: On or about November 13, 2013, the employer did not train employees on the requirement of using flame retardant clothing while working in the pellet mill in areas subject to the accumulation of combustible dust to mitigate against burns in the event of a deflagration.

Issued

May 8, 2014

Abate by

Jun 20, 2014

Penalty

Initial $5,600 · Current $3,000 Reduced

General-duty citation text

29 CFR 1910.22(a)(1): All places of employment, passageways, storerooms, and service rooms were not kept clean and orderly.    a) In the room below Bin 25 at 22 Kimball Place Fitchburg, MA: On or about November 13, 2013, wood dust was allowed to accumulate to depths equal to or greater than 1/8th of an inch on elevated surfaces in the room.  The dust upon sampling and testing was found to be a combustible dust.  Combustible dust deposition in layers this deep on elevated surfaces are a deflagration and explosive hazard when disturbed and dispersed in the air.    Creative Biomass, Inc. was previously issued for a violation of this occupational safety and health standard which was contained in inspection number 313201899, citation number 1, item number 1a, and was affirmed as a final order on March 3, 2010, with respect to a workplace located at 22 Kimball Place in Fitchburg, MA.

Issued

May 8, 2014

Abate by

May 22, 2014

Penalty

Initial $5,600 · Current $3,000 Reduced

Hazardous substances E200

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:    a) Establishment: Employees did not wear easily removable flame-retardant and non-static generating clothing in areas where combustible wood dusts was present on or about November 13, 2013.     Creative Biomass, Inc. was previously issued for a violation of this occupational safety and health standard which was contained in inspection number 313201899, citation number 1, item number 6 and affirmed as a final order on March 3rd 2010, with respect to a workplace located at 22 Kimball Place in Fitchburg, Ma.