OSHA Inspection: ARMACELL, LLC

Issued

Jul 13, 2016

Abate by

Aug 28, 2017

Penalty

Initial $3,375 · Current $2,500 Reduced

Hazardous substances E200

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 exposed to combustible deflagration, explosion or other fire hazards while working at or near an indoor combustible dust system which was not adequately designed to prevent or minimize employee exposure in the event of a deflagration, explosion or fire event:         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 exposed to combustible deflagration, explosion or other fire hazards while working at or near an indoor combustible dust system which was not adequately designed to prevent or minimize employee exposure in the event of a deflagration, explosion or fire event:     (a) On or about February 25, 2016, in the compounding area, the indoor Tenkay Dust Collector located in the compounding area was used for collecting combustible polyethylene homopolymer and modified azodicarbonamide dust.  The collector 1)  lacked means of deflagration, explosion protection; 2) lacked means of deflagration propagation protection (isolation) for the upstream processes and the area below the unit's material discharge; and 3) exhausted air directly back into the facility.       Among other methods, feasible and acceptable means of abatement include following the guidance contained in 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 4.2.1, 7.1.4.1, 7.1.6.1, 7.1.7, 7.13.1.1.1, 7.13.1.2.2, 7.13.1.4, 7.13.1.6, 9.1.2, and 9.3. *       For explosion protection, options include, but are not limited to, the following:   1)      Deflagration venting that discharges to a safe outdoor location or a safe manner in accordance with NFPA 68 "Standard on Explosion Protection by Deflagration Venting".  This includes safe discharge to an outdoor location through relief ducting provided that consideration is given to the reduction in deflagration venting efficiency caused by the ducts, that the ducting is restricted to no more than 20 ft., and the ducting is able to withstand the maximum pressure developed in the vented enclosure (Pred).  If deflagration venting through relief ducting is not feasible due to the proximity of the indoor vented enclosure to an outdoor wall, deflagration venting through a listed dust retention and flame-arresting device may be a suitable alternative.  ? or-       2)      Chemical deflagration suppression systems in accordance with NFPA 69 "Standard on Explosion Prevention Systems"*.       For ensuring the safe handling of exhaust air, options include, but are not limited to, the following:       1)      Discharging exhaust air to a restricted area and away from air intakes. ?or-       2)      Incorporating provisions to prevent the transmission of flame and pressure effects from an internal deflagration and also smoke and flame from an internal fire directly into the facility.  These provisions may include the use of dust retention and flame-arresting devices, passive and active deflagration isolation devices (i.e. passive float valves, actuated fast-acting mechanical valves, flame front extinguishing systems, etc.) for preventing the transmission of flame and pressure effects from an internal deflagration directly into the building and fire detection and extinguishment/abort gate systems for preventing the transmission of smoke and flame from an internal fire directly  into the building.       For deflagration propagation protection (isolation) for upstream processes, options include, but are not limited to, the following:   1)  The use of a passive isolation device located between the dust collector and the upstream processes (usually mounted on the dirty air inlet duct at some specified distance from dust collector) in accordance with NFPA 69.  An example of a commonly used passive isolation device is a passive flap valve as outlined in NFPA 69.   ?or-       2)  The use of a passive isolation device located between the dust collector and the upstream processes (usually mounted on the dirty air inlet duct at some specified distance from dust collector) in accordance with NFPA 69.  An example of a commonly used active isolation device is a chemical deflagration isolation system (aka flame front extinguishing system) as outlined in NFPA 69*.       For deflagration propagation protection (isolation) for the area beneath the unit?s material discharge, options include, but are not limited to, the following:   1)  A material choke (rotary valve isolation device) designed and installed in accordance with NFPA 69. ?or-       2)  A chemical deflagration isolation system (aka flame front extinguishment system) as outlined in NFPA 69*.       *Note: A chemical deflagration detection suppression system can be installed on an indoor dust collector to provide both explosion protection and deflagration propagation protection.

Issued

Jul 13, 2016

Abate by

Aug 29, 2016

Penalty

Initial $2,700 · Current $1,500 Reduced

General-duty citation text

29 CFR 1910.22(a)(2): The floor of every workroom shall be maintained in a clean and, so far as possible, a dry condition. Where wet processes are used, drainage shall be maintained, and false floors, platforms, mats, or other dry standing places should be provided where practicable.      On or about February 25, 2016, in the facility, employees required to work in the compounding room  were exposed to the hazard of fire and deflagration due to accumulations of blowing agent dust on electrical equipment, pipes and floors.

Issued

Jul 13, 2016

Abate by

Aug 29, 2016

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(h)(3)(ii): The physical and health hazards of the chemicals in the work area;    a. On or about February 25, 2016, in the work area, employee training did not include at least the physical and combustible dust hazards of the chemicals in the work area such as azodicarbonamide.