OSHA Inspection: NORTHWOODS PAPER CONVERTING INC.

Issued

Apr 18, 2017

Abate by

May 16, 2017

Penalty

Initial $12,549 · Current $6,157 Reduced

Hazardous substances M110

General-duty citation text

29 CFR 1910.1200(h)(3)(ii): Employee training did not include the physical and health hazards of the chemicals in the work area:    On or about November 01, 2016 employees shredding paper and working around paper dust were not trained on the combustible nature of paper dust.

Issued

Apr 18, 2017

Abate by

Aug 1, 2017

Penalty

Initial $17,927 · Current $12,313 Reduced

Hazardous substances M110

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 was causing or were likely to cause death or serious physical harm to employees in that employees were exposed to combustible dust explosion, deflagration, or other fire hazards presented by cartridge-media dust collectors handling combustible paper dust that were installed and operated in a manner to expose employees to the byproducts of internal deflagrations and fire:        On or about November 01, 2016 employees were exposed to the following conditions:                           a)  An indoor cartridge media dust collector  (Donaldson Torit) was used to collect combustible paper dust from the upstream paper sheeters and bailing process:      (i) T he dust collector lacked deflagration (flame front) propagation protection (isolation) for the following connections:  The upstream process (dirty air inlet), the return air exhaust (clean air outlet), and the unit?s material discharge hopper (material outlet).   This exposed employees to flame front hazards.      (ii) The dust collector exhausted filtered air directly indoors and lacked recognized means to protect building occupants from the hazardous byproducts of a developing fire (i.e. smoke, embers, toxic gases).  This exposed employees to fire hazards.      b) An outdoor cartridge media dust collector (Farr Tenkay) was used to collect combustible paper dust from the upstream paper shredding, sheeters and bailing process:      (i)  The dust collector lacked deflagration (flame front) propagation protection (isolation) for the following connections:  The upstream process (dirty air inlet), the return air exhaust (clean air outlet), and the unit?s material discharge hopper (material outlet).   This exposed employees to flame front hazards.      (ii)  The dust collector exhausted filtered air directly indoors and lacked recognized means to protect building occupants from the hazardous byproducts of a developing fire (i.e. smoke, embers, toxic gases).  This exposed employees to fire hazards.      (iii)  The dust collector lacked recognized means of safe explosion protection.  Explosion venting was installed, but the vent was oriented toward the building and located approximately 45 inches from the building.  In addition, the employer did not maintain vent closure design parameters and documentation necessary to demonstrate that the vent area and the vent?s distance from the building were sufficient to prevent deflagration pressure from exceeding the enclosure strength.       Among other methods, feasible methods to correct these hazards would be to follow the applicable guidance in the following National Fire Protection Association?s (NFPA) Standards:       NFPA 652 ?Standards on the Fundamentals of Combustible Dust, 2016 ed.? ? Sections 8.9.4 (equipment isolation), 8.3.5 (clean air exhaust), and 8.9.2 (deflagration venting in accordance with NFPA 68).      NFPA 654 ?Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2017 ed.? ? Sections 7.1.6 (equipment and upstream work area isolation), 7.1.4.1 (deflagration venting in accordance with NFPA 68), and 7.13.1.6 (clean air exhaust).      NFPA 68 ?Standard on Explosion Protection by Deflagration Venting, 203 ed.? ? Sections 6.5.1 (free and clear vent closures), 5.2.3/6.6.1/8.9 (directing venting to an outside, safe location), 11.2 (design parameters and documentation).      NFPA 69 ?Standard on Explosion Prevention Systems, 2014 ed.?  Chapter 11 (deflagration control by passive isolation) and Chapter 12 (deflagration control by active isolation).      Specifically, for the indoor dust collector:        (1) Provide a deflagration propagation (isolation) device between the indoor dust collector and the bailer(s) in accordance with NFPA 69.  One example of a likely feasible isolation device that likely work in this location is a flow-actuated flap valve.        (2) Duct exhaust air to a safe outdoor location and away from air intakes or alternatively provide (a) a deflagration propagation (isolation) device such as a passive float valve on the dust collector?s exhaust ducting to prevent the transmission of flame and pressure effects from a deflagration and (b) a spark detection and extinguishment/abort system to prevent the transmission of smoke and flame from a fire.       (3) Provide a deflagration propagation (isolation) device between the dust collector?s material discharge hoppers.  An example of a feasible isolation device for this location is a rotary valve designed and installed in accordance with the deflagration isolation principles found in NFPA 69.      Specifically, for the outdoor dust collector:       (1) Ensure that the vent closure will effectively relieve pressure in the event of a deflagration occurring in the dust collector by following the guidance in NFPA 68.  The vent closure may need to be reoriented and/or resized to ensure appropriate protection.       (2) Ensure that the vent closure discharges to a safe outdoor location away from where employees have access.  Access to spaces in which deflagration vents discharge should be restricted to minimize risk of injury from flame front and pressure.       (3) Provide a deflagration propagation (isolation) device between the outdoor dust collector and the bailer(s) in accordance with NFPA 69.  One example of a likely feasible isolation device that likely work in this location (provided that effective deflagration venting can be assured) is a flow-actuated flap valve.        (4) Prohibit the recycling of exhaust air back into the building or alternatively provide (a) a deflagration propagation (isolation) device  such as a passive float valve (provided that effective deflagration venting can be assured) between the dust collector and the building to prevent the transmission of flame and pressure effects from a deflagration and (b) a spark detection and extinguishment/ abort system between the dust collector and building to prevent the transmission of smoke and flame from a fire.    (5) Provide a deflagration propagation (isolation) device between the dust collector?s material discharge hoppers and the 55-gallon drums or restrict access to the area around the collector?s material discharge during operation of the collector.  An example of a feasible isolation device for this location is a rotary valve designed and installed in accordance with the deflagration isolation principles found in NFPA 69.    Northwoods Paper Converting Inc. was previously cited for a violation of the OSH ACT of 1970 Section (5)(a)(1) for combustible dust which was contained in OSHA inspection number 844144, citation number 1, item number 2 and was affirmed as a final order on July 30, 2013, with respect to a workplace located at 830 Crowe Street, East Stroudsburg, PA 18301.