OSHA Inspection: COREY STEEL COMPANY

Issued

Apr 11, 2016

Abate by

Apr 17, 2017

Penalty

Initial $6,300 · Current $3,780 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 combustible metal (steel) dust deflagration, explosion, or other fire hazards while working at or near dust collection systems consisting of multiple unprotected indoor dry-type cartridge filter media dust collectors:     On or about February 11, 2016, in Building 18 shot-blast room, six indoor DISA dry-type cartridge filter media dust collectors utilized to collect steel dust generated from an industrial abrasive blasting process (wire descaling) lacked means of (1) explosion protection, (2) deflagration propagation protection (isolation) and (3) fire protection.  Additionally, the dust collectors recycled exhaust air directly into the building.     Among other methods, a feasible method to correct this hazard would be to follow National Fire Protection Association (NFPA) Standards 484 "Standard for Combustible Metals, 2015 Ed." - Sections 9.4.13.2, 9.4.13.3.4, 9.4.13.9, 9.4.13.11, 9.4.13.13.1, 9.4.13.13.3, 9.4.13.13.3.1, 9.4.13.14, 9.4.13.14.4, 9.4.13.15, 9.4.13.15.7, and 9.4.13.15.7.9(2).     In addition to other guidance outlined in NFPA 484 (2015), following the NFPA guidance outlined above would entail actions such as, but not limited to, the following:       Conduct a detailed dust hazard analysis (DHA) of the process and the associated fire and explosion hazards. Within the DHA, determine the specific properties of the combustible dust being collected through applicable ASTM test methods (i.e. Pmax and Kst via ASTM E1226 and MIE via ASTM E2019).  If the Pmax is determined to be less than 8 bar-g, the Kst is determined to be less than 150 bar-m/s, and the MIE is determined to be greater than 100 mJ, then the continued use of indoor dry-type dust collectors may be appropriate [provided that additional fire prevention measures outlined in NFPA 484 (2015) Section 9.4.13.14.3 are met and appropriate methods of explosion protection, fire protection, and deflagration propagation protection (isolation) are provided].  If the Pmax is determined to be greater than 8 bar-g, the Kst is determined to be greater than 150 bar-m/s, and the MIE is determined to be less than 100 mJ through applicable ASTM test methods, then the use of indoor dry-type dust collectors is not considered appropriate.       1)    For justified use of dry-type media dust collectors:        a)    Relocate indoor dry-type media dust collectors to an outdoor location; provide dry-type dust collectors with a method of explosion protection such as deflagration venting to a safe location/in a safe manner in accordance with NFPA 68, deflagration suppression in accordance with NFPA 69, or oxidant concentration reduction in accordance with NFPA 69; prohibit the recycling of exhaust air from dry-type dust collectors back into the building;  and provide methods of deflagration propagation protection (isolation) to prevent the propagation of a flame front from any dust collector experiencing a deflagration into the upstream processes and through the collector?s material discharge in accordance with NFPA 69 (note: deflagration propagation protection may not be necessary on a system protected by oxidant concentration reduction).       -OR-       b)    Provide indoor dry-type media dust collectors with a method of explosion protection such as deflagration venting to a safe outdoor location in accordance with NFPA 68, deflagration suppression in accordance with NFPA 69, oxidant concentration reduction in accordance with NFPA 69, or deflagration venting through a listed dust retention and flame-arresting device in accordance with NFPA 68; duct each collector?s exhaust air ducting to an outdoor location away from any building air intakes; provide methods of deflagration propagation protection (isolation) to prevent the propagation of a flame front from any dust collector experiencing a deflagration into the upstream processes and through the collector?s material discharge and into the work area in accordance with NFPA 69 (note: deflagration propagation protection may not be necessary on a system protected by oxidant concentration reduction); and provide an automatic fixed fire detection and suppression system with a fire extinguishing agent that has been shown to be effective with the material collected.       2)    For use of indoor wet-type dust collectors:       a)    Ensure that the design, installation, and maintenance of wet-type dust collectors follows recognized and generally accepted good engineering practice such as the guidance contained in NFPA 484 (2015) Section 9.4.12.       3)    For use of outdoor cyclone dry-type dust collectors:       a)    Provide outdoor cyclone dry-type dust collectors with a method of explosion protection such as deflagration venting to a safe location/in a safe manner in accordance with NFPA 68, deflagration suppression in accordance with NFPA 69, or oxidant concentration reduction in accordance with NFPA 69; prohibit the recycling of exhaust air from dry-type dust collectors back into the building;  and provide methods of deflagration propagation protection (isolation) to prevent the propagation of a flame front from any dust collector experiencing a deflagration into the upstream processes and through the collector?s material discharge in accordance with NFPA 69 (note: deflagration propagation protection may not be necessary on a system protected by oxidant concentration reduction).