OSHA Inspection: PIONEER POWDER COATINGS, LLC

Issued

Sep 12, 2014

Abate by

Oct 30, 2014

Penalty

Initial $1,700 · Current $1,190 Reduced

Hazardous substances M110

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 combustible powder coating dust fire and deflagration hazards associated with the improper location, installation, and design of dust collection systems:    a) The indoor CMT-1 fabric filter bag-type dust collector used to collect dust from the upstream CMT-1 size reduction process (grinder) lacked a means of 1) explosion protection, 2) fire protection, 3) deflagration propagation protection (isolation).  In addition, the dust collector discharged exhaust air directly into the building.  Also, the collector was not electrically bonded to the upstream equipment as a section of non-conductive flexible plastic ducting was installed upstream of the collector.      b) The outdoor Donaldson Torit #1 fabric filter cartridge-type dust collector lacked a means of deflagration propagation protection (isolation) to occupied upstream process areas (pre-weigh, tumbler, and grinding areas).  In addition, the dust collector returned exhaust air back into the building.      c) The outdoor Donaldson Torit #2 fabric filter cartridge-type dust collector lacked a means of deflagration propagation protection (isolation) to occupied upstream process areas (spray, mixing, and extruder areas). Non-conductive flexible plastic duct was installed upstream between the extruders and the main branch ducting.    Among other methods, a feasible method to correct these hazards would be to follow the 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 ed.  Sections 7.1.4, 7.1.6, 7.1.7, 7.6.2, 7.6.4, 7.13.1.1.1, 7.13.1.2.1, 9.3.2.1    Specifically for the indoor dust collector: 1) relocate the indoor dust collector to an outdoor location, 2) provide a method of explosion protection such as, but not limited to, as explosion venting to a safe location in accordance with NFPA 68, Standard on Explosion Protection by Deflagration Venting, 3) provide a method of deflagration propagation protection (active or passive system) in accordance with NFPA 69, Standard on Explosion Prevention Systems, and 4) prohibit the return of exhaust air into the building.  Alternatively, provide the indoor dust collector with 1) a method of explosion and deflagration propagation (isolation) protection such as chemical deflagration suppression, 2) a method of fire protection as described in NFPA 654 Chapter 10, and 3) a method of exhausting filtered air to a safe, outdoor location.    Specifically for the outdoor dust collectors: 1) provide a method of deflagration propagation protection (active or passive system) in accordance with NFPA 69, Standard on Explosion Prevention Systems in the inlet (dirty) air ducting between the collector and the upstream process equipment and 2) exhaust filtered (clean air) from each collector directly to atmosphere and prohibit its return back into the facility unless all of the criteria in NFPA 654 Section 7.13.1.6.3 can be met.